Open Recommendations

CMS should provide additional education to providers on appropriate billing for telehealth services.

CMS should improve the transparency of "incident to" services when clinical staff primarily delivered a telehealth service.

CMS should identify telehealth companies that bill Medicare.

CMS should follow up on the providers identified in this report.

We recommend that the Montana Department of Public Health and Human Services refund to the Federal Government $5,065,966 (Federal share) in overpayments.

We recommend that the Montana Department of Public Health and Human Services ensure that it always follows its established policies and procedures by: o reviewing TCM providers' case manager hiring practices to verify adherence with the State plan's experience requirements and to ensure that case managers'qualifications were documented, o implementing a process to review billed services to verify that they were allowable and properly documented, and o reviewing target group eligibility documentation to ensure that all individuals receiving services were eligible.

We recommend that the Montana Department of Public Health and Human Services require TCM providers to comply with established policies and procedures in order to ensure that: o case managers who render TCM services to recipients have the experience required by the State plan supplement, o TCM providers maintain documentation to support the TCM services rendered, o TCM providers maintain documentation to support that case managers are qualified to perform TCM services, o the State agency does not pay TCM providers or claim Federal Medicaid reimbursement for services that are not allowable TCM services, and o recipients receiving TCM services…

We recommend that the Director of HUD's Newark Office of Public Housing make a determination regarding outstanding agreement income, including whether those unspent funds should be returned to the public housing agencies, thereby putting up to $697,912 to better use, including $478,165 related to Asbury Park and $219,747 related to Red Bank.

We recommend that the Director of HUD's Newark Office of Public Housing provide technical assistance to Long Branch and require updates to its procedures to ensure that it properly classifies income received under any future agreements or activities.

We recommend that the Director of HUD's Newark Office of Public Housing require Long Branch to prepare and provide support for a reasonable estimate of the amount of employee time used to perform services for Asbury Park and Red Bank and the amount of Long Branch program funds used to pay for that time.

We recommend that the Director of HUD's Newark Office of Public Housing require Long Branch to reimburse Long Branch's program from non-Federal funds for any Long Branch program funds used for payroll expenses related to services provided to Asbury Park and Red Bank as established in recommendation 2A, estimated to be $1,014,660.

We recommend that the Director of HUD's Newark Office of Public Housing require Long Branch to prepare and provide support to show the reasonableness and eligibility of the $1,583,652 in employee incentive payments related to services performed for Asbury Park and Red Bank, which was paid from agreement income, or reimburse its program from non-Federal funds for any amount it cannot support.

We recommend that the Director of HUD's Newark Office of Public Housing require Long Branch to implement adequate controls to ensure compliance with applicable cost principle requirements for employees, including those covering compensation for personal services, such as wages, salaries, and incentive payments, at 2 CFR 200.430. Records should reasonably reflect the total activity for which Long Branch's employees are compensated by the non-Federal entity and support the distribution of compensation among specific activities and cost objectives.

Strengthen its controls to more effectively enforce implementation of the updated Agile guidance among projects and teams.

Develop, document, implement, and enforce additional VersionOne standards informed by best practices, including those we identified.

We recommend the DHS Chief Information Officer (CIO) update policies and procedures to implement National Institute of Standards and Technology standards to facilitate recovery from an adverse event and maintain operations during malware, ransomware, and phishing attacks.

We recommend the CBP CIO ensure all users complete initial and annual refresher security awareness training as required and document, monitor, and retain individual cybersecurity awareness training records.

We recommend the DHS HQ CIO ensure all users complete initial and annual refresher security awareness training as required and document, monitor, and retain individual cybersecurity awareness training records.

We recommend that Cigna HealthSpring of Florida, Inc. refund to the Federal Government $39,612 of net overpayments

We recommend that Cigna HealthSpring of Florida, Inc. improve its policies and procedures to prevent, detect, and correct noncompliance with Federal requirements for diagnosis codes that are used to calculate risk-adjusted payments.

Classified Report. Recommendation is SSI.

Classified Report. Recommendation is SSI.

Classified Report. Recommendation is SSI.

We recommend that OPM revise or replace the FEHBP MLR requirements to provide a reliable measure of the premium dollars spent on the FEHBP program, including the impact of carrier corporate structure and the current community-rated product market.

(U) Rec. 1: This recommendation is Controlled Unclassified Information

Develop and publish a public description of the purposes and benefits of, and the controls on, the drop-in meeting process.

Once the new guidance is developed, train all managers on the new guidance and controls for drop-in meetings and related interactions with external stakeholders.

Refund to the Federal Government $14,281,626 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement

Refund to the Federal Government $241,533 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement

Work with CMS to determine the unallowable portion of $1,328,195 (Federal share) for other claims for multiple-source physician-administered drugs that may have been ineligible for Federal reimbursement, refund that amount, and consider invoicing drug manufacturers for rebates for these drugs if CMS determines that the drug claims are allowable

Work with CMS to determine and refund the unallowable portion of Federal reimbursement for physician-administered drugs that were not invoiced for rebates after December 31, 2019

Continue to review and strengthen its internal controls to ensure that all physician-administered drugs eligible for rebates are invoiced

(U) Rec. 2.a: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security update DoD Directive 5210.56, or other appropriate DoD policy, to standardize active shooter incident response procedures and planning, equipment, and training requirements for all Department and Service law enforcement organizations.

(U) Rec. 2.c: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security update DoD Directive 5210.56, or other appropriate DoD policy, to identify the roles, responsibilities, and actions to be taken by armed non-first responder law enforcement organization personnel during active shooter incidents.

(U) Rec. 2.d: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security update DoD Directive 5210.56, or other appropriate DoD policy, to require installation active shooter incident response plans to include the roles and responsibilities of armed non-first responder law enforcement organization personnel, such as the Defense Criminal Investigative Organization personnel.

(U) Rec. 2.e: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security update DoD Directive 5210.56, or other appropriate DoD policy, to require installation commanders at all military installations initiate, update, validate, and exercise installation support agreements with local law enforcement organizations for the joint response to active shooter incidents on military installations.

(U) Rec. 2.f: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security update DoD Directive 5210.56, or other appropriate DoD policy, to require Defense Criminal Investigative Organization personnel participation in active shooter incident response exercises using scenarios where the armed non-first responder law enforcement organization personnel are already at the scene of an active shooter incident.

(U) Rec. 2.g: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security update DoD Directive 5210.56, or other appropriate DoD policy, to require installation armed non-first responder law enforcement organization personnel, such as the Defense Criminal Investigative Organization field offices, to develop memorandums of understanding with installation law enforcement organizations, which describe the role and responsibilities of Defense Criminal Investigative Organization personnel during an active shooter incident response.

(U) Rec. 2.h: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security update DoD Directive 5210.56, or other appropriate DoD policy, to require law enforcement active shooter incident response training be provided to Defense Criminal Investigative Organization personnel.

We recommend the Office of Strategy, Policy, and Plans develop a unified strategy to improve DHS’ coordinated actions among the components and with other agencies to counter disinformation campaigns that appear in social media.

CMS should encourage Part D plans to increase access to and use of the authorized generic versions of Epclusa and Harvoni, within the authorities granted under statute.

CMS should pursue additional strategies—such as educating providers and pharmacies—to increase access to and use of lower-cost hepatitis C drugs in Medicare Part D.

Evaluate efficiency at the 10 facilities to identify inefficiencies in the mail flow (e.g., facility layout/location, space constraints, customer and service impacts, and equipment relocation costs) and, based on the results, consider properly aligning the impacted facilities to efficiently meet the challenges they face based on changes in market demand.

OIG recommends that until all 11 recommendations (see Appendix A for a list of the 11 recommendations) addressed to the Bureau of Near Eastern Affairs (NEA) referenced in this report (AUD-AOQC-22-33) are implemented and closed, the Under Secretary for Political Affairs monitor NEAs compliance responses to OIG and verify, at least quarterly, that the responses (a) are provided to OIG within the established due dates and (b) contain complete and accurate status updates that include either evidence of implementation or detailed corrective action plans with actual or proposed target dates for achieving these actions.

Recommendation 9: We recommended the Assistant Administrator for Protective Services, in coordination with the Ames Protective Services Office Chief and Ames Center Director: Within the next 3 years, conduct a Center-wide security vulnerability risk assessment, including the districts outside Ames Campus, to ensure compliance with federal and NASA requirements. 

Recommendation 10: We recommended the Assistant Administrator for Protective Services, in coordination with the Ames Protective Services Office Chief and Ames Center Director: Identify and implement mitigation strategies and resource requirements to address the security vulnerability assessment risks.

Review unprocessed felony referrals identified in this report, take corrective action as needed, and report the efforts taken to the OIG.

Determine the allowability of the questioned transactions and recover $7,148,093, if applicable.

Develop a framework for directing DHS components to deploy staff to support missions, including non-centrally funded, unplanned, or emergency operations, for which DHS resources are needed.

Develop a volunteer deployment strategy that includes provisions for supporting volunteers, regardless of funding source.