Open Recommendations

Evaluate and revise as necessary the Agency processes, including Compliance Assessment Program reviews, to include an oversight methodology that can generate accurate, statistically valid, and representative compliance results for change orders.

Develop and implement guidance for use by FHWA and States that a. includes a consistent definition of "change order," b. delineates the differences between a major change and a significant change; and c. further clarifies what may constitute a major change.

Update FHWA's Contract Administration Core Curriculum Manual, dated October 2014, to clearly reflect that FHWA may assign its change order approval responsibilities to State DOTs through Stewardship and Oversight Agreements.

We recommend that the FWS require the Department to implement or revise policies and procedures to ensure leave allocated to a grant code does not exceed the value of leave earned on that grant.

Design and implement a comprehensive migration plan for the COVID-19 EIDL program, to include defined acceptance criteria and robust testing, with detailed project milestones and defined areas of responsibility for program management, information technology, and procurement groups so that data is preserved to meet the needs of all stakeholders.

We recommend that Lahey Clinic, Inc. refund to the MAC $6,015 in overpayments for critical care services.

We recommend that Lahey Clinic, Inc. based on 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 returned overpayments as having been made in accordance with this recommendation.

We recommend that Cariten Health Plan, Inc. refund to the Federal Government the $9,212,531 of estimated net overpayments.

We recommend that Cariten 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 Cariten Health Plan, Inc. 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.

Provide documentation, or a full and detailed written explanation, of the process Oklahoma used to determine the initiatives it supported with GEER grant funds and the entities it selected to administer the initiatives.

Develop and implement a process to ensure that it documents the criteria and decisions made for awarding future GEER grant funds in accordance with applicable requirements.

Develop and implement internal controls to ensure that it administers current and future GEER grants in accordance with applicable Federal laws and grant requirements, including ensuring that grant subrecipients are provided the proper award documentation; and that any entity that is awarded Federal funds retains records relating to those awards in accordance with Federal requirements.

Perform a 100 percent review, or review a statistical sample, of the Stay in School Fund microgrant recipients to confirm that all students were eligible to receive GEER grant funds.

Develop and implement written policies and procedures to describe the specific circumstances under which deviations from procurement rules are warranted, including procedures about required documentation of such decisions for procurements that do not use competitive bidding but use Federal education funds.

Take appropriate action if the documentation and other information provided by Oklahoma in response to the above recommendations does not support that the State followed applicable requirements.

Return $652,720 to the Department for the unallowable Bridge the Gap expenditures we identified or provide documentation to support that the expenditures were allowable or the items were purchased with personal funds.

Perform a 100-percent review, or review a statistical sample, of the $5,473,894 in Bridge the Gap expenditures that we did not review to determine whether the expenditures were allowable, and if applicable, return the funds for any unallowable expenditures to the Department.

Develop and implement additional internal controls for the Skills to Rebuild, Learn Anywhere Oklahoma, Bridge the Gap, and Stay in School Fund initiatives that include written monitoring procedures for those processes that are already in place, and for additional procedures that include a review of expenditures and supporting documentation, and a review of documentation that supports the information in initiatives’ weekly status reports.

Develop and implement internal controls to ensure that fiscal agents for Federal grant programs obtain an understanding of the rules and regulations surrounding the grant programs they are tasked with overseeing.

Develop and implement controls to ensure that Oklahoma’s State agencies that receive Federal funds have written cash management policies and procedures, including policies for the draw down and disbursement of grant funds in accordance with Federal requirements.

Return to the Department any unexpended GEER grant funds applicable to our audit scope that are being held by GEER grant subrecipients.

Develop and implement internal controls to ensure that fiscal agents for Federal grant programs obtain an understanding of the rules and regulations surrounding the grant programs they are tasked with overseeing.

Require its fiscal agent or State program representative to work closely with the Department to ensure that other GEER grants are administered in compliance with cash management rules and with any actions the Department determines are needed, if warranted.

We recommend the Assistant Secretary for Trade and Economic Security of DHS’ Office of Strategy, Policy, and Plans, in coordination with ICE and CBP, develop, implement, and monitor a departmental strategic, risk-based approach for managing and enforcing intellectual property rights.

We recommend the Executive Assistant Commissioner for CBP Office of Field Operations direct the coordinated establishment and implementation of a national database for recording non-seizure events, such as abandonments and return-to-sender.

We recommend that the Centers for Medicare & Medicaid Services work with State survey agencies to require mandatory participation in standardized life safety training for nursing home staff.

We recommend that the Centers for Medicare & Medicaid Services propose regulations requiring nursing homes and inspection contractors to notify State survey agencies when fire alarm and sprinkler systems are not working or may be in jeopardy of not working.

We recommend that the Centers for Medicare & Medicaid Services propose regulations requiring carbon monoxide detectors to be installed in accordance with NFPA 72 and 720 for all nursing homes that utilize fuel-burning appliances or have an attached garage.

We recommend that the Centers for Medicare & Medicaid Services develop a plan in conjunction with State survey agencies to address the foundational issues preventing more frequent surveys at nursing homes with a history of multiple high-risk deficiencies.

Annually conduct an improper payment review in accordance with PIIA and follow the guidance outlined in OMB Circular A-136, section II.4.5 [Payment Integrity Information Act Reporting]

Annually conduct an improper payment review in accordance with PIIA andfollow the guidance outlined in OMB Circular A-136, section II.4.5 [Payment Integrity Information Act Reporting];

Annually conduct an improper payment review in accordance with PIIA andfollow the guidance outlined in OMB Circular A-136, section II.4.5 [Payment Integrity Information Act Reporting];

Complete the OMB Annual Data Call reporting, and if necessary, contact OMB via email at MBX.OMB.OFFM.PaymentIntegrity@omb.eop.gov to obtain access to the annual data call.

CDC should expand its efforts both to improve racial and ethnic data associated with COVID-19 and to supplement them with additional data sources.

Develop and implement internal controls to ensure that officials and staff responsible for gathering data used for Federal reporting requirements obtain an understanding of the rules and regulations surrounding the grant programs they are tasked with overseeing.

Develop and implement effective written policies and procedures and sufficient information system controls to ensure that accurate student enrollment and withdrawal data are entered in its student information system in a consistent manner.

Provide support for the inaccurate and unsupported displaced student counts or return $6.5 million in Emergency Impact Aid program funds received based on estimated inaccurate and unsupported displaced student counts.

Ensure mitigation actions for ICT products, especially mission-critical ICT products or services, are descriptive, actionable, and tailored to the user environment and operational contexts (including its anonymity of procurement statement); and work with OCIO and the SCRM Unit to create and resource a continuous monitoring program that monitors C-SCRM risks across the FBI, ensures that users understand and follow C-SCRM mitigations identified in the product vulnerability and procurement risk assessments, and develops procedures to periodically monitor and assess user compliance with its C-SCRM mitigation actions.

Enhance its policies, procedures, training and communication, and/or internal controls for the requisition and government purchase card systems to better ensure that purchasing officials understand the C-SCRM requirements and so that applicable requisitions and purchase requests undergo C-SCRM procedures, as required; and develop policies, procedures, and/or internal controls to periodically monitor FBI compliance by identifying and remedying purchases that improperly bypassed the process.

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

We recommend the Counterterrorism Coordinator use the results of the needs assessment to establish a long-term governing body to oversee and coordinate the Department’s efforts to counter domestic terrorismby creating:• a charter with business rules and roles and responsibilities for longterm action;• a formalized documented process to monitor and track completion ofaction items; and• a formalized documented feedback process to review, update, andmeasure the impact of priority actions taken in response to changesin the domestic terrorism threat environment.

We recommend the Deputy Under Secretary for Intelligence Enterprise Operations finalize and implement an overarching policyand standard operating procedures to guide the timely, complete, and accurate review and release of open source intelligence reports.

We recommend the Deputy Under Secretary for Intelligence Enterprise Operations establish a standard process to determinewhether additional oversight or review is needed for open source intelligence reports before their dissemination

Recover the $1.9 million of overpayments to a grant recipient in accordance with 2 CFR § 200.345-346.

Require the reconciliation of the grant recipient’s budget to the final award amount prior to awarding a grant, including ensuring receipt of revised budgets, when changes are needed, prior to disbursing grant awards. Furthermore, discontinue the disbursement of grant awards prior to the receipt of a revised budget.

ACF should encourage all States to evaluate the value of adding an assessment of risk for sex trafficking when children return to foster care after going missing.

ACF should conduct oversight activities to identify States that may not screen all children for sex trafficking when they return to foster care after going missing.

Rec. 2.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, in coordination with the Deputy Director of Enterprise Accounting and Audit Support for the Defense Finance and Accounting Service, use a sufficient sample size to support the improper payment estimate by calculating the sample size based on improper payment amounts instead of only using the paid amount. To reduce the required sample size, we recommend considering alternative improper payment estimation methodology, and conducting risk assessments of the payment types for each program.

The Bureau of Fiscal Operations and the Office of Programs should work together to develop and document written policies and procedures for the Railroad Unemployment Insurance Act process for debts identified for recovery from Railroad Retirement Act benefit payments, across all applicable organizational units involved in the process (both the automated and manual processes).