Open Recommendations

1. We recommend that the Florida Agency for Health Care Administration, Division of Health Quality Assurance work with CMS to provide clear guidance to nursing facilities regarding what constitutes a reportable incident.

We recommend that the Florida Agency for Health Care Administration, Division of Health Quality Assurance establish procedures that include documenting assessment start and end dates and priority level assignments.

We recommend that the Florida Agency for Health Care Administration, Division of Health Quality Assurance establish and implement written policies and procedures for incident report processing.

We recommend that the Florida Agency for Health Care Administration, Division of Health Quality Assurance evaluate its staffing levels to determine whether staffing is adequate.

We recommend that the Florida Agency for Health Care Administration, Division of Health Quality Assurance improve the intake process by: (a) assessing all Federal 24-Hour Reports to identify whether potential noncompliance with quality of care standards caused the incidents and whether the incident occurred after the last standard survey; (b) assessing the severity and urgency of harm to the resident(s) that may have been caused by abuse, neglect, or nursing facility noncompliance with CoPs to assign a priority level; and (c) using ACTS to create an incident record with start and end dates for all Federal 24-Hour Report assessments and…

6. We recommend that the Florida Agency for Health Care Administration, Division of Health Quality Assurance establish and implement written policies and procedures for managing incident report late filings and consider immediately initiating onsite surveys of nursing facilities that file Federal 24-Hour Reports late.

7. We recommend that the Florida Agency for Health Care Administration, Division of Health Quality Assurance establish and implement written policies and procedures for managing APS complaint notifications and conducting assessments of APS complaints to identify and survey more facilities where resident harm may have been caused by nursing facility noncompliance.

Identify minimum training (baseline) requirements and follow through by providing, tracking, and documenting this training for project reviewers, including Program Delivery Managers, Document Validation Specialists, and Quality Assurance Specialists, before they perform their duties.

Strengthen the project review process by evaluating FEMA’s internal controls and making improvements that, at a minimum, ensure:(a) projects return to the prior review queue if the projects do not complywith Federal procurement requirements or FEMA guidelines,including when insufficient documentation is provided;(b) roles and responsibilities for procurement reviews and qualityassurance are clearly defined;(c) project review policies are followed, such as the use of DeterminationMemos and Quality Assurance Checklists, as appropriate; and(d) controls are tracked and an auditable file is created in FEMA systems

Ensure the Regional Administrator, Federal Emergency Management Agency Region IV, review debris removal procurements and projects and either disallow or acquire support documentation for $25,594,524 ($23,282,276 Federal share) in questionable debris costs.

(U) Rec. 1.d: The DoD OIG recommended that the Commander of the U.S. Central Command develop and memorialize COVID-19 lessons learned and incorporate them into U.S. Central Command Pandemic Influenza and Infections Disease Concept Plan, supporting component plans, and Central Command Regulation 525-40, "Continuity of Operations Plan," August 20, 2020. The Continuity of Operations Plan should include information on quarantine processes and contractor personnel.

Utilize the most recent threat assessment to enhance biological agent detection capabilities to respond to the most up-to-date threats.

We recommend that the Centers for Medicare & Medicaid Services work with Treasury and QHP issuers to recover the $43,455 in improper APTCs identified in our sample, or take other remedial action.

We recommend that the Centers for Medicare & Medicaid Services work with Treasury and QHP issuers to recover the remaining improper APTCs, which we estimate to be $950 million, or take other remedial action for policies for which the payments were not allowable.

We recommend that the Centers for Medicare & Medicaid Services develop a process for qualified health plan issuers to provide (a) information related to individuals’ premium payments paid during the benefit year, and (b) enrollees’ policy termination information so that enrollment data provided to the Internal Revenue Service is accurate.

ACF should conduct oversight activities to identify States that may not appoint a GAL to every child victim who undergoes a judicial proceeding, seeking statutory authority as necessary.

ACF should proactively provide technical assistance to States that face challenges in appointing a GAL for every child victim.

ACF should proactively identify and address obstacles that States face in reporting complete and accurate GAL data.

Monitor facility compliance with the use of an approved inventory management system for completeness and accuracy.

Establish standardized systems and requirements for facility staff to appropriately record necessary biologic implant attributes for accurate and accessible tracking of recipients to advance patient safety.

We recommend the Principal Deputy Assistant Secretary for Occupational Safety and Health. Compare remote inspections to onsite inspections, and at a minimum provide analysis that addresses their frequency and timeliness for identifying and abating worksite hazards.

We recommend that Brookdale Home Health, LLC strengthen its procedures to ensure that: the homebound statuses of Medicare beneficiaries are verified and continually monitored and the specific factors qualifying beneficiaries as homebound are documented and beneficiaries are receiving only reasonable and necessary skilled services

We recommend that Blue Cross Blue Shield of Michigan: We recommend that Blue Cross Blue Shield Michigan refund to the Federal Government the $14,534,375 of net overpayments.

We recommend BCBSM identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before or after our audit period and refund any resulting overpayments to the Federal Government.

We recommend that BCBSM examine its existing compliance procedures to identify areas where improvements can be made to ensure diagnosis codes that are at high risk for being miscoded comply with Federal requirements (when submitted to CMS for use in CMS’s risk adjustment program) and take the necessary steps to enhance those procedures.