Open Recommendations

Assess facilities patient safety reports identified during this audit to determine if additional actions need to be taken and, if so, provide an action plan.

Develop a mechanism to better identify major performance incidents and negative patient outcomes and provide a plan to prioritize and address their causes.

Provide guidance to EPA regions and authorized states on methods that they can use to verify land-use control status, such as reporting or onsite assessments.

Define the minimum frequency for region and state verification that land-use controls remain operational—for example, verification every one, three, or five years.

Update RCRAInfo to capture data on the operational status of land-use controls. This could be achieved by establishing national event codes for land-use control activities in RCRAInfo—for example, using Region 3's event codes as nationally defined event codes.

Provide training to help regions and authorized states input and maintain land-use control data in RCRAInfo.

Implement mechanisms to monitor land-use control status at the national level, such as annual reports from RCRAInfo that identify land-use controls that have not been verified at the minimum frequency to ensure they remain operational.

We recommend that Humana Health Plan, Inc. refund to the Federal Government the $6,777,385 of estimated overpayments.

We recommend that Humana Health Plan, Inc. 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 Humana Health Plan, Inc. continue to 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 (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

We recommend that CVS Health refund to the Federal Government the $4,256,568 of estimated overpayments.

We recommend that CVS Health 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 CVS Health continue its examination of 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 (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Obtain a revised ARP EANS application from the 73 nonpublic schools thatused proportionality data (in whole or in part) to estimate its low-income student count and ensure that the schoolsinclude a revised low-income student count that is based on a proper data source. FDOE should use the revised countsto reassess the eligibility of the 73 schools and any EANS funds used to provide services to ineligible nonpublic schoolsmust be reverted to Florida’s Governor to be used for…

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Formally document its expenditure review and approval procedures to guideFDOE personnel through the expenditure review and approval processes. The procedures should be designed to ensurecompliance with applicable requirements, including those pertaining to EANS in both CRRSA and ARP EANS as well asthe regulations at 2 C.F.R. Part 200 (Uniform Guidance).

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Retroactively obtain prior written approval from the Department for the 5equipment expenditures or return the $187,660 expended for those equipment purchases and perform a review of theremaining equipment expenditures to determine whether there are additional purchases that require prior written approval.FDOE should also incorporate into its grants management policies and procedures a step to determine whether it isrequired to obtain prior approval from the Department for certain expenditures related to any Department grants, orwhether it can provide…

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Develop a process to track and periodically check on the use ofEANS-funded supply purchases with a unit cost under $5,000 to ensure that all supplies are accounted for and used forallowable purposes.

Develop a means of identifying and documenting acquisition-specific team members from the Program Offices, Division of Administration Acquisition Services Branch, Legal Division, and Office of Minority and Women Inclusion.

Update the Acquisition Procedures and Guidance Manual to (1) define “reasonable planning,” (2) require the documentation of “reasonable planning” for all acquisitions, and (3) require a written description of potential or actual acquisition-specific conflict of interest-related risks in planning documentation.

Develop procedures requiring acquisition team members, as defined in response to Recommendation 1, to complete a conflict of interest certification in which each team member is to assess and document that they do not have a potential or actual conflict of interest related to the specific acquisition prior to participating in any phase of the acquisition lifecycle (from planning to closeout). These procedures should require that evidence of acquisition team members’ conflict of interest certifications is maintained in accordance with requisite FDIC records retention schedule requirements.

Develop procedures requiring acquisition team members, as defined in response to Recommendation 1, to re-certify annually that they remain free of actual or potential conflicts of interest as long as the acquisition is in place.

Develop and deliver specialized acquisition-related conflict of interest training on at least an annual basis to all acquisition team members to strengthen employee knowledge and skills related to ethics laws and regulations.

Evaluate whether there should be minimum qualifications and requirements for appointed Deputy Ethics Counselors (DEC), a desired ratio of DECs to filers across FDIC Divisions and Offices, and whether DEC duties should be incorporated into FDIC employee position descriptions to better equip DECs to monitor and respond to employees’ potential and actual conflicts of interest.

Develop and implement an action plan utilizing Deputy Ethics Counselor survey results and other relevant information to help identify strengths and opportunities for continuous improvement in the FDIC’s financial disclosure review program.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Iowa torequire Des Moines to return to the U.S. Department of Education the $164,580 that Des Moines improperly charged tothe ARP ESSER grant for LEA advertising and public relations or reallocate the funds to other allowable costs. Identifyany additional improper charges to ESSER grants for LEA advertising and public relations, including those made duringperiods not covered by our review, and if applicable, return the funds to the U.S. Department of Education or reallocatethem to other allowable costs.