Open Recommendations

CMS should use self-reported race and ethnicity information to improve data for current beneficiaries.

CMS should develop a process to ensure that the data are as standardized as possible.

CMS should educate beneficiaries about CMS's efforts to improve the race and ethnicity information.

We recommend that CAS update its Review Guide to conform with applicable Federal regulations and CAS internal policies and procedures.

We recommend that CAS take steps to ensure that branch chiefs and negotiators follow all Federal and internal CAS requirements.

We recommend that CAS include all federally required documents on checklists provided to the nonprofit organizations and on checklists used by CAS officials.

We recommend that CAS review its staffing levels and determine whether resources are aligned efficiently, and adjust as needed, to ensure that the indirect cost rate-setting process is conducted in a timely manner.

We recommend that CAS seek clarification on whether the policy of including executive compensation higher than the Level II statutory cap in its indirect cost pool calculation complies with Federal law and governmentwide policy.

We recommend that CAS ensure that negotiated final indirect cost rates are calculated based on actual costs.

NIH should specifically require grantees to provide trainings and maintain a written policy regarding investigators' disclosure of other support.

NIH should modify reporting mechanisms to require grantees to report whether investigators' significant financial interests and other support involve foreign entities.

NIH should conduct outreach to grantees with R13 conference grants to clarify requirements regarding the disclosure and review of investigators' significant financial interests and other support.

We recommend that the Centers for Medicare & Medicaid Services instruct the DME MACs to recover $41,137 in overpayments for PMD repairs made to PMDs that belonged to 76 sampled beneficiaries.

We recommend that the Centers for Medicare & Medicaid Services instruct the DME MACs to based upon the results of this audit, notify appropriate suppliers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the suppliers 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 also recommend that the Centers for Medicare & Medicaid Services work with the DME MACs to do the following, which could have saved Medicare an estimated $7,948,182 during our audit period; Implement a system edit that applies to all PMD repairs and identifies PMD repairs for review of supplier documentation to help ensure that PMD repairs are adequately documented and that the PMD repair charges are reasonable and necessary.

We also recommend that the Centers for Medicare & Medicaid Services work with the DME MACs to do the following, which could have saved Medicare an estimated $7,948,182 during our audit period; Implement a system edit to determine whether PMD repair charges exceed the estimated cost to replace the PMDs being repaired.

We recommend that the Centers for Medicare & Medicaid Services establish Medicare requirements that: (1) include the documentation standards established by guidance for PMD repairs; (2) specify that accumulated costs of repairs made to power wheelchairs during their 5 year RUL must not exceed a certain threshold; and (3) specify that suppliers must provide warranties for repairs made to PMDs, which could have saved Medicare an estimated $3,739,346 during our audit period.

The FBI should clarify its policies regarding the approved methods for transmitting child sexual abuse material (CSAM) and other contraband to prosecutors and other government employees with a need to view the material in their official capacity.

Establish clearly defined and detailed roles, responsibilities, and processes for all SBA offices and officials responsible for managing and handling potentially fraudulent PPP loans to reduce the risk of ineligible applicants receiving PPP forgiveness and the risk of fraud and financial loss in the PPP and when implementing similar future programs.

Provide lenders formal guidance to effectively and consistently handle potentially fraudulent PPP loans and ensure lenders have sufficient guidance when implementing similar future programs.

Improve Agency systems to automate benefit computations and reduce the need for manual processing.

We recommend that Peoples Health Network refund to the Federal Government the $3,312,219 in estimated overpayments.

We recommend that Peoples Health Network 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 Peoples Health Network enhance 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 Vanderbilt University Medical Center improve procedures and provide education to staff to ensure that claims billed to Medicare are accurate

We recommend that Vanderbilt University Medical Center implement changes to its billing system to ensure that claims billed to Medicare are accurate.

Strengthen information system controls to make certain that complete and accurate claims information is transferred between applicable current and future Community Care payment systems and the Consolidated Patient Account Centers’ workflow tool and VistA patient treatment files.

Conduct an assessment to determine if staffing resources and workload are sufficiently aligned to process the anticipated volume of claims to be billed to veterans’ private health insurers and make adjustments as needed.

Establish controls to ensure staff and contractors follow existing requirements to test single adults for COVID-19 before transfer usingdomestic commercial flights.

Clarify existing COVID-19 testing policies to include modes of transportation and timeframes for mandatory testing beforetransport.

We recommend that the FWS resolve the questioned costs related to unsupported indirect costs totaling $435,624.

We recommend that the FWS work with the Department to develop and implement a mechanism to hold its staff accountable for following Federal regulations related to indirect costs and record retention, and its own SOPs.

We recommend that the FWS resolve the questioned costs related to unsupported other direct costs totaling $201,708.

We recommend that the FWS work with the Department to develop a mechanism to hold staff accountable for following its SOPs related to purchase requests and documentation retention.

We recommend that the FWS resolve the questioned costs related to drawdowns totaling $169,989.

We recommend that the FWS work with the Department to develop a mechanism to hold staff accountable for following its SOPs for conducting drawdowns and maintaining adequate documentation for expenditures in the accounting system.

We recommend that the FWS resolve the questioned costs related to unallocated leave payouts totaling $6,480.

We recommend that the FWS require the Department to update and implement its SOPs to ensure that leave payouts are properly allocated in accordance with Federal regulations.

On June 15, 2021, we alerted IRS management of our concerns with the systemic calculation of the allowable RRC amount. We recommended that IRS management review the returns we identified and provide us with any corrective actions they intended to take.

Determine the allowability of the questioned transactions and recover $3,534,794, if applicable.

Include additional terms and conditions within future AmeriCorps General Grant and Cooperative Agreement Terms and Conditions policy documents aimed at addressing the root causes of improper payments.

Implement financial consequences or additional reporting requirements for grantees that have confirmed improper payments.
Modified repeat recommendation

We recommend that the Washington State Health Care Authority review all managed-care health home encounters from July 1, 2013, through March 31, 2017, to determine the enhanced Federal reimbursement that should have been claimed for Medicaid managed-care health home service expenditures based on the portion of the MCOs' capitation payment rate that was specifically attributable to health home services and refund to the Federal Government any unallowable amounts.

We recommend that the Washington State Health Care Authority review all managed-care health home encounters from July 1, 2013, through March 31, 2017, to identify whether the encounters used to support claims for enhanced Federal reimbursement have since been removed from the encounter data and refund to the Federal Government any amounts that are no longer supported.

We recommend that the Washington State Health Care Authority review all managed-care health home encounters from July 1, 2013, through March 31, 2017, to identify whether the encounters exceeded the number of reportable encounters that were allowed for an enrolled beneficiary and refund to the Federal Government any amounts related to unallowable encounters.

We recommend that the Washington State Health Care Authority implement a procedure to identify whether encounters used to support journal vouchers have been removed from the encounter data and refund to the Federal Government any Federal reimbursement that was claimed and is no longer supported.

We recommend that the Washington State Health Care Authority strengthen its MMIS edits to limit the reporting of an encounter for a tier-1 health home service to only once in a beneficiary's lifetime and ensure that only one encounter per beneficiary is reported each month.

We recommend that the Washington State Health Care Authority determine the portion of the remaining $1,367,120 that should have been claimed for managed-care health home service expenditures based on the portion of the MCOs' capitation payment rate that was specifically attributable to health home services, and refund any unallowable amounts.

We recommend the DHS OCHCO designate, direct, and oversee component representatives to maintain rosters of essential employees in each category defined by existing DHS policy.

We recommend the DHS OCHCO designate, direct, and oversee component representatives to maintain rosters of essential employees in each category defined by existing DHS policy.