Open Recommendations

We recommend that the Centers for Medicare & Medicaid Services issue guidance to providers on not billing Medicare for a medical service that was authorized by VHA.

We recommend that Crow/Northern Cheyenne Hospital, Billings Area Office, and Indian Health Service Headquarters work together to take action to complete background investigations for staff members identified in this report as not having a satisfactory background investigation and adjudicate the investigations that were still pending adjudication.

We recommend that Crow/Northern Cheyenne Hospital, Billings Area Office, and Indian Health Service Headquarters work together to update standard operating procedures for background investigations to address the deficiencies we identified in this report.

We recommend that Crow/Northern Cheyenne Hospital, Billings Area Office, and Indian Health Service Headquarters work together to establish a monitoring system to ensure all elements of required background investigations in accordance with Federal requirements are completed within required timeframes.

We recommend that Crow/Northern Cheyenne Hospital, Billings Area Office, and Indian Health Service Headquarters work together to determine which staff members in contact with Indian children currently have a pending background investigation and take immediate action to ensure that there is adequate documented evidence that these staff members meet IHS sight and supervision requirements when children are in their care.

We recommend that Crow/Northern Cheyenne Hospital, Billings Area Office, and Indian Health Service Headquarters work together to update standard operating procedures for provisional staff supervision to address the deficiencies we identified in this report.

We recommend that Crow/Northern Cheyenne Hospital, Billings Area Office, and Indian Health Service Headquarters work together to establish a monitoring system to ensure that the Hospital meets sight and supervision requirements for staff with pending background investigations and documents that they are met.

Examine its domain assessment process - including the Top 100 Initiative and recall inspection activities - and refine its strategies for identifying and tracking risks, deploying resources, and accomplishing goals.

Implement a process to conduct ongoing formal, data-based, comprehensive reviews of inspections results to ensure consistent application of the standards and assist ATF in reaching its inspection program goals of reducing the possibility of firearms being diverted from legal commerce and maintaining the traceability of firearms.

Adopt mechanisms to improve the accuracy of its information-sharing data and the completeness of its information about the outcomes of internal and external referrals and use this information to better assess the value and effectiveness of its information sharing practices, with the goal of providing enhanced oversight of FFLs.

Refine the CGIC performance review process to include sufficient information to allow for an assessment of the outcomes and effectiveness of the CGIC intelligence that is shared with Industry Operations.

Establish a recurring process to assess the risk indicators that contribute to the selection of FFLs for inspection and evaluate the results of the inspections to ensure that field divisions are effectively identifying high-risk FFLs.

Rec. 1.b: The DoD OIG recommended that the Army Contracting Command-Rock Island Executive Director request a refund from the contractor for any excess payment or arrange for payment to the contractor for any under-billed costs identified by the Defense Contract Audit Agency.

Rec. 1.c: The DoD OIG recommended that the Army Contracting Command-Rock Island Executive Director issue guidance to reinforce the importance of the contracting officer and contracting officer's representative roles and involvement in review of invoices prior to payment.

OIG recommends that the Bureau of Overseas Buildings Operations, working collaboratively with Caddell Construction Co, LLC, develop and implement an action plan to ensure the Project Execution Schedule meets all the purposes outlined in Contract Specification 013205, paragraph 1.4 for Contract SAQMMA17C0287, NEC Mexico City, Mexico.

Revise Security and Hazardous Materials Safety Order 1600.20 guidance to avoid overlap or contradiction with similar procedures contained in FAA Order 1600.38.

We recommend that the Centers for Medicare & Medicaid Services correct the inaccurately reported deficiencies that we identified for the sampled nursing homes.

We recommend that the Centers for Medicare & Medicaid Services correct existing programming in ASPEN that prevented the 56 emergency preparedness deficiencies from being reported on Care Compare.

We recommend that the Centers for Medicare & Medicaid Services strengthen its processes for reviewing inspection results reported on Care Compare by requiring State survey agencies to verify that deficiencies shown in ASPEN are also shown in CASPER when they are preparing to conduct an inspection.

We recommend that the Centers for Medicare & Medicaid Services strengthen its processes for reviewing inspection results reported on Care Compare by providing technical assistance and additional training to State survey agencies that are not following procedures in the State Operations Manual and ASPEN Central Office Procedures Guide for reporting deficiencies in ASPEN.

We recommend that the Centers for Medicare & Medicaid Services strengthen its processes for reviewing inspection results reported on Care Compare by including in its manual quality assurance check a verification that nursing home inspection results are accurately reported.

We recommend that HumanaChoice refund to the Federal Government the $480,295 of net overpayments.

We recommend that HumanaChoice 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 HumanaChoice examine its existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk for being miscoded comply with Federal requirements and take the necessary steps to enhance those procedures.

Ensure all cloud-based systems are appropriately authorized by Federal officials,including selection and assessment of all relevant security controls;