Open Recommendations

CMS should actively review current guidance related to the areas identified in this report and determine whether additional guidance would ensure more accurate and consistent ASP calculations.

We recommend the Office of the Secretary establish aDHS oversight entity to ensure National Instant Criminal Background CheckSystem compliance in DHS, which should include:a. coordinating with the Attorney General to resolve open dispositions thatno longer have available information and discontinue use ofadministrative closure dispositions; andb. developing a risk-based strategy for components to assess missingcriminal history records and submit missing dispositions.

We recommend the DHS Office of the Secretary establisha mechanism to track and ensure timely responses to NICS inquiries anddevelop and implement a process to include immigration status at the time ofinquiry for immigration-related inquiries.

We recommend the United States Coast Guard,Assistant Commandant for Human Resources, establish a process for thePersonnel Service Center to notify the Coast Guard Investigative Service of thecompletion of dishonorable discharges and that CGIS personnel enter theminto NICS data.

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

Work with ACF to develop a viable plan for refunding $153,052 in unallowable costs to the Federal Government.

Develop and implement procurement policies and procedures to avoid acquiring unnecessary items and to perform analyses to determine the most reasonable approach for future vehicle purchases.

Develop and implement written policies and procedures to ensure that criminal background checks on employees are completed within required time frames.

We recommend that the State agency refund up to $9,832 to the Federal Government.

We recommend that the State agency enhance the monitoring of provider compliance by conducting periodic reviews of telehealth payments for compliance with requirements.

We recommend that the State agency establish a list of acceptable telehealth procedure codes.

(U) Transfer to the Stagehand program the field division FSL already used by Stagehand or determine an alternative approach that gives Stagehand appropriate control over its staffing to ensure the operational effectiveness, continuity, and security of the Stagehand program.

(U) Work with NSD and other Department stakeholders to develop an integrated system for tracking requests for AGEs and Otherwise Illegal Activity from initiation through final approval that can meet the FBl's and the Department's operational needs, provide visibility about the status of a given request. and identify specific and systemic delays in the AGE and Otherwise Illegal Activity approval process.

(U) Establish reasonable and attainable qualifications for UCCs to better ensure UCCs have appropriate undercover experience, grade level. and adequate time to effectively conduct their undercover-related
duties. Once the UCC qualifications are established, the FBI should update its policies and procedures to reflect the new requirements

(U) Develop a comprehensive training plan for both UCEs and OCEs that includes certification. annual refresher training, and advanced training in specialty skills, managed by NCOS.

We recommend that Keystone First HealthChoices coordinate with the Pennsylvania Department of Human Services, Office of Medical Assistance Program, to update Keystone First's administrative process to require that medical directors assess whether overnight care requests meet the medical necessity requirement based on the documentation Keystone First has received even if some documentation, such as the caregiver's work verification documentation, is missing.

Review all pediatric skilled nursing service requests for which overnight care was completely denied and determine whether the overnight care requests meet the medical necessity requirement regardless of whether the caregiver provided work or school verification documentation.

Implement a revised initial denial notice to explain that a beneficiary has the right to request a State fair hearing after exhausting the MCO's appeals process.

We recommend that the Pennsylvania Department of Human Services, Office of Medical Assistance Program, revise the initial denial notice template referenced under Exhibit N in the HealthChoices Agreement to include information regarding the beneficiary's right to request a State fair hearing after exhausting the MCO's appeals process.

We recommend that CMS update the HH Pricer logic to check for missing and invalid FIPS codes on all home health claims and work with MACs to ensure that these claims are returned to providers for correction.

We recommend that CMS re-educate providers on the requirement for all home health claims to be submitted with the FIPS code for the county where the service was provided.

In a timely manner, ensure that complaints are filed with the relevant state appraiser licensing authorities for each appraisal from its December 2021 review in which FHFA found overt references to race, color, and other prohibited bases.

We recommend the El Centro Sector Chief, Border Patrol, U.S. Customs andBorder Protection, and Director of Field Operations, San Diego Field Office,Office of Field Operations, U.S. Customs and Border Protection: Conduct refresher training on recording information incustody logs, highlighting the importance of accurately accounting for allactions completed by CBP and contract personnel, such as health interviews,meals, and showers.

Rec. 2.a: The DoD OIG recommended that the Assistant Secretary of Defense for Sustainment, in coordination with the Deputy Assistant Secretary of Defense for Global Partnerships develop risk assessment procedures to identify and plan for future temporary housing and facility usage operations, such as those experienced during Operation Allies Welcome and Operation Allies Refuge, so installations can return to normal operations in a timelier manner.