Open Recommendations

We recommend that the New York State Department of Health refund $308,972,87027 to the Federal Government or provide documentation that it can reasonably support, under the circumstances, its allocation of health services costs to Medicaid without using unverifiable IEP ratios.

We recommend that the New York State Department of Health ensure that its contractor (1) collects sufficient information so the State agency can validate the contractor's coding of sampled moments and (2) correctly offsets and supports intergovernmental agreement transactions.

We recommend that the New York State Department of Health revise its certified public expenditures SSHSP to (1) include September days worked in its random moment time study and (2) develop an accurate, supportable method to identify Medicaid costs instead of unverifiable IEP ratios.

We recommend that Palmetto GBA, LLC, discontinue using its internal policies of waiving certain overpayment collections related to lookback years and start collecting all hospice cap overpayments and paying refunds in accordance with CMS requirements.

We recommend that Palmetto GBA, LLC develop processes for communication between the departments directly and indirectly involved in hospice cap oversight.

Reassess its policies to more precisely describe for FBI employees when they are required to promptly contact and coordinate with applicable state and local law enforcement and social service agencies after receiving allegations of crimes against children that potentially fall under state jurisdiction, even when the allegations also potentially fall within the FBI's jurisdiction.

Clarify its policies as to what type of file FBI employees should use to retain documentation received during Pre-Assessment activities that continue for more than 5 days.

Train FBI employees on the policies discussed in the first three recommendations and any changes made to them.

Develop and implement a process to segregate non-CDL holder convictions from all Commercial Driver's License Information System reports and workbooks utilized to evaluate State's compliance with CDL regulations.

We recommend that Partners In Care, Inc. refund to the Federal Government the portion of the estimated $11,278,891 for hospiceservices that did not comply with Medicare requirements and that are within the 4-yearreopening period.

We recommend that Partners In Care, Inc. based upon the results of this audit, 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 Partners In Care, Inc. strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend the Federal Emergency Management Agency Administrator address unresolved implementation issues, publish proposed regulations for notice and comment within 1 year, and issue final regulations within 3 years of issuance of this report for implementation of the Disaster Mitigation Act of 2000, 42 U.S.C. § 5172(b)(2).

We recommend the Federal Emergency Management Agency Administrator review and resolve hazard mitigation challenges, such as: 1. ensuring education and training of states and applicants on mitigationprograms and availability of funding at the state and applicant levels;2. revising criteria and instructions for completing benefit-cost analyses toclarify and streamline the process and assist applicants with meeting therequired benefit-cost threshold;3. streamlining the processes from application submission to approval todecrease applicants’ wait time for mitigation; and4. considering existing flexibilities to adjust the cost share for applicantsexperiencing financial hardships.

Update Agency guidance on practical enforceability to more clearly describe how the technical accuracy of a permit limit should be supported and documented. In updating such guidance, the Office of Air and Radiation should consult and collaborate with the Office of Enforcement and Compliance Assurance, the Office of General Counsel, and the EPA regions.

In consultation with the EPA regions, develop and implement an oversight plan to include: a. An initial review of a sample of synthetic-minor-source permits in different industries that are issued by state, local, and tribal agencies to assess whether the permits adhere to EPA guidance on practical enforceability, including limits that are technically accurate; have appropriate time periods; and include sufficient monitoring, record-keeping, and reporting requirements. b. A periodic review of a sample of synthetic-minor-source permits to occur, at a minimum, once every five years. c. Procedures to resolve any permitting deficiencies identified during the initial and periodic reviews.

Assess recent EPA studies of enclosed combustion device performance and compliance monitoring and other relevant Air and Radiation information during the next statutorily required review of 40 C.F.R Part 60 Subparts OOOO and OOOOa to determine whether revisions are needed to monitoring, record-keeping, and reporting requirements for enclosed combustion devices to assure continuous compliance with associated limits, and revise the regulatory requirements as appropriate.

Revise the Agency's guidance to communicate its key expectations for synthetic-minor-source permitting to state and Air and Radiation local agencies.

Identify all state, local, and tribal agencies in which Clean Air Act permit program implementation fails to adhere to the public Air and Radiation participation requirements for synthetic-minor-source permit issuance and take appropriate steps to assure the identified states adhere to the public participation requirements.

We recommend that Mission Hospice & Home Care, Inc.: refund to the Federal Government the portion of the estimated $10,564,396 for hospice services that did not comply with Medicare requirements and that are within the 4-year reopening period.

We recommend that Mission Hospice & Home Care, Inc.: strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services, as part of its ERM program, implement a process to assess all of its programs for national security risks in accordance with OMB Circular No. A-123's requirement to include new or emerging risks in the risk profile.

We recommend the Associate Administrator, FEMA Office of Response and Recovery ensure its direct housing information system provides flexibility implementing alternative direct housing options; provides support to states, territories, and tribal governments administering direct housing assistance; and facilitates data exchange and sharing with non-FEMA information systems.

Reassess the cost estimate for Electronic Health Record Modernization program-related information technology infrastructure and refine as needed to comply with VA’s cost-estimating standards.

Develop procedures for cost-estimating staff that align with VA cost-estimating guidance.