Open Recommendations

We recommend that the contracting officer direct the Association to institute policies and procedures to run reports of claims with the X52 errors within 30 days of any software update effecting pricing, to issue to its local BCBS Plans for review and repricing.

We recommend that the contracting officer disallow $9,464,843 in overpayments estimated from our expanded sample. In addition, we recommend the contracting officer direct the Association to complete its review of the expanded sample and the appropriate amounts to be paid to determine the actual overpayment to the FEHBP.

We recommend that the contracting officer disallow $340,079 in overcharges to the FEHBP.

We recommend that the contracting officer direct the Association to update its FAM to instruct local BCBS Plans to manually price claim lines with modifiers requiring medical review/approval at the appropriate Medicare amount with applicable modifier price adjustments.

We recommend the contracting officer direct the Association to consider requiring its OBRA vendor to return a price for all claims initially, even if the claims require medical review/approval, to ensure that a price is available following the review.

1. The BOP should implement a process for assigning a cellmate following suicide watch or psychological observation, with criteria for exceptions based on the particular individual or security considerations.

2. The BOP should establish procedures to ensure inmates at high risk for suicide and for whom a cellmate is recommended will continue to have a cellmate until the recommendation is changed or rescinded, including establishing a contingency plan for cellmate re-assignment, with criteria for exceptions based on the particular individual or security considerations.

3. The BOP should evaluate its current process for obtaining and documenting approval for social or legal visits while an inmate is on suicide watch or psychological observation, which allows for institution-specific variations in the process, and provide guidance on standard components that each institution should include in its process to mitigate security issues that can arise when an inmate is on suicide watch or psychological observation.

4. The BOP should evaluate its methods of accounting for inmate whereabouts and wellbeing and make changes as may be appropriate to improve those methods through policy, training, or other measures.

5. BOP policy should clarify what is required of a Lieutenant when conducting a round.

6. The BOP should continue to develop and implement plans to address staffing shortages at its prisons.

8. The BOP should enhance existing policies regarding institutional security camera systems to ensure they specifically state that such systems must have the capacity to record video and that BOP institutions must conduct regular security camera system functionality checks.

We recommend that Noridian Healthcare Solutions, LLC update the educational material on its website as well as any previously provided webinars to include all Medicare requirements and guidance for billing and documenting ESRD-related services and continue to perform medical record reviews as part of the TPE program, which could have saved the Medicare program an estimated $8,844,899 and could have saved Medicare enrollees up to an estimated $2,204,799 for our audit period.

We recommend that Noridian Healthcare Solutions, LLC notify the physicians and qualified nonphysician practitioners to refund $1,162 in coinsurance that was collected for the 26 sampled enrollee-months.

We recommend that Noridian Healthcare Solutions, LLC based on the results of this audit, notify appropriate physicians and qualified nonphysician practitioners (i.e., those for whom Noridian determines this audit constitutes credible information of potential overpayments) so that the physicians and practitioners can exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule and identify any of those returned overpayments as having been made in accordance with this recommendation.

We recommend that Noridian Healthcare Solutions, LLC recover $4,663 in improper payments made to physicians and qualified nonphysician practitioners for the 26 sampled enrollee-months.

Rec. 2.c: The DoD OIG recommended that the Defense Manpower Data Center Director implement automated system input controls to prevent entries from processing unless users populate required fields in accordance with updated requirements.

We recommend that the FWS work with the Division to resolve the Federal share of questioned costs related to the unsupported drawdowns totaling $20,210.

We recommend that the FWS work with the Division to develop and implement controls to ensure drawdowns are performed on actual and allowable expenditures.

We recommend that the FWS work with the Division to develop and implement controls to ensure expenditures are not incurred and charged to a grant after the period of performance.

We recommend that the FWS work with the Division to resolve the Federal share of questioned costs related to equipment totaling $1,609.

We recommend that the FWS work with the Division to resolve the potential diversion of $11,586 related to unsupported equipment.

We recommend that the FWS work with the Division to complete a physical inventory immediately.

We recommend that the FWS work with the Division to identify any equipment items that are obsolete, damaged, or disposed of, and update items in the asset management database.

We recommend that the FWS work with the Division to develop and implement a mechanism to hold Division employees accountable for ensuring physical inventories are conducted once every 2 years and assets reflect the correct status.