Open Recommendations

The Bureau of Fiscal Operations should submit a detailed indirect cost rate proposal in support of its allowable and allocable indirect labor costs to Centers for Medicare and Medicaid Services for approval prior to reimbursement.

The Bureau of Fiscal Operations should work with the Centers for Medicare and Medicaid Services to determine, adjust, and correct any erroneous reimbursements resulting from the allocation of all of the Railroad Retirement Board’s indirect labor and non-labor costs beginning with fiscal year 2010 to current.

The Bureau of Fiscal Operations should determine the correct Medicare direct labor reimbursement amount using the compliant employee profiles.

The Executive Committee should perform a time study of Medicare work performed by all agency staff.

The Executive Committee should establish an Office of Management and Budget Circular A-87 compliant and Centers for Medicare and Medicaid Services approved personnel activity report based system that will ensure the capture and reporting of actual Medicare work performed.

The Executive Committee should update the Railroad Retirement Board employee direct labor profiles to represent actual work performed based on an Office of Management and Bduget Circular A-87 compliant system methodology.

The Bureau of Fiscal Operations should adopt and implement Office of Management and Budget Circular A-87 as an agency requirement.

The Bureau of Fiscal Operations should work with the Centers for Medicare and Medicaid Services to update the Medicare interagency agreement and establish procedures for maintaining and updating the agreement.

The Bureau of Fiscal Operations should re-evaluate the Railroad Retirement Boards’s cost allocation plan and implement an Office of Management and Budget Circular A-87 compliant methodology for future Medicare direct labor costs using appropriate specialists and expertise.

The Bureau of Fiscal Operations should utilize and maintain Office of Management and Budget Circular A-87 compliant personnel activity reports and employee certifications through authorization by the Railroad Retirement Board’s Executive Committee to ensure that reimbursed Medicare direct labor costs represents costs for actual and allowable Medicare work performed.

The Bureau of Fiscal Operations should work with the Centers for Medicare and Medicaid Services to determine, adjust, and correct any erroneous reimbursement of Medicare direct labor costs beginning with fiscal year 2010 to current based on actual work performed.

The Executive Committee should conduct a thorough investigation and determine if the Purpose Statute and/or Antideficiency Act was violated as a result of the RRB’s Medicare reimbursement process and report violations in accordance with Office of Management and Budget Circular A-11.

The Bureau of Fiscal Operations should develop and certify an indirect cost methodology and rate that complies with Office of Management and Budget Circular A-87 using appropriate specialists and expertise.

The Bureau of Fiscal Operations should obtain Centers of Medicare and Medicaid Services approval for the indirect cost methodology and rate developed based on the recommendations in this report.

The Bureau of Fiscal Operations should determine the correct Medicare indirect cost reimbursement amount for fiscal years 2010 to current using the compliant indirect cost rate for the period.

The Bureau of Fiscal Operations should establish procedures requiring annual certification of the cost allocation plan and indirect cost rate prior to reimbursement that complies with Office of Management and Budget Circular A-87.

The Bureau of Fiscal Operations should establish a variance analysis control process that will help to identify indirect cost reimbursement miscalculations and ensure timely corrective action.

Complete the anti-backsliding study on the air quality impacts of the Renewable Fuel Standard as required by the Energy Independence andSecurity Act.

Determine whether additional action is needed to mitigate any adverse air quality impacts of the Renewable Fuel Standard as required by the Energy Independence and Security Act.

The General Access Control Policy and attendant procedures should be updated to include the elements outlined in the report.

Develop, document, and maintain a software inventory including license management policies and procedures.

Comply with and enforce HSPD-12 multifactor authentication supported by the Personal Identity Verification Card.