Open Recommendations

(U) Rec. 2.a: The DoD OIG recommended that the Director of the Defense Health Agency, after the new DoD implementing guidance for supply chain risk management is published, develop and publish implementing guidance for supply chain risk management specifically for pharmaceuticals, that includes the Component responsible for policy execution.

(U) Rec. 2.b.1: The DoD OIG recommended that the Director of the Defense Health Agency complete the implementation of its Drug Supply Chain Security Act Compliance Strategy by establishing policies and procedures for drugs purchased with Government Purchase Cards or local contracts to comply with the Drug Supply Chain Security Act.

(U) Rec. 2.b.2: The DoD OIG recommended that the Director of the Defense Health Agency complete the implementation of its Drug Supply Chain Security Act Compliance Strategy by, in coordination with the Commander of Defense Logistics Agency Troop Support, establishing policy and procedures for drugs purchased with Defense Logistics Agency-managed processes, including Defense Logistics Agency Depot Stock, Direct Vendor Delivery, and Defense Logistics Agency Electronic Catalog.

Update Customs Directive No. 4320-003, July 1990 (TECS Directive) to clarify the appropriate bases for placing lookouts and provide training to all CBP officials who have the authority to place lookouts.

Develop and implement procedures to ensure CBP officials update and remove lookouts in accordance with the TECS Directive.

CMS should share information to help States address challenges with using telehealth to provide behavioral health services to Medicaid enrollees

CMS should conduct monitoring for fraud, waste, and abuse, and support State efforts to oversee telehealth for behavioral health services.

CMS should ensure that the three States that are unable to distinguish telehealth from in-person services implement indicators to identify which services are provided via telehealth.

CMS should conduct evaluations, and support State efforts to evaluate the effects of telehealth on access, cost, and quality of behavioral health services.

Develop and implement an action plan to reduce turnover of management and staff and to ensure continuity of Unit operations should turnover occur

Ensure that all convictions and adverse actions are reported to Federal partners within the appropriate timeframes

Revise the Unit's MOU with the State Medicaid agency to establish procedures by which the Unit will receive referrals of potential fraud from MCOs

Ensure that costs associated with non-MFCU activities are excluded from the Unit's Federal reimbursement request

IHS should solicit feedback from CCRTs regarding their observations of potential need for broader IHS-wide improvements

IHS should compile the CCRTs' recommendations to individual facilities and share them across all IHS and Tribal facilities.

IHS should assess whether IHS could use the CCRT model to provide support and training to facilities needing assistance with non-COVID-19-related care.

Determine the allowability of $185,339 in ineligible questioned costs on pages 7 and 8 of the audit report and recover any amount that is unallowable.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Near Eastern Affairs, discontinue its practice of awarding noncompetitive contracts for Operations Maintenance Support Services and Baghdad Life Support Services. The bureau should award Mission Iraq-specific task orders under the Diplomatic Platform Support Services contract or use an alternative mechanism to competitively replace the Operations and Maintenance Support Services and Bagdad Life Support Services contracts.

CMS should provide oversight of the 20 MA companies that had a disproportionate share of the risk-adjusted payments from chart reviews and HRAs.

CMS should take additional actions to determine the appropriateness of payments and care for the one MA company that substantially drove risk-adjusted payments from chart reviews and HRAs.

CMS should perform periodic monitoring to identify MA companies that had a disproportionate share of risk-adjusted payments from chart reviews and HRAs.

We recommend CBP’s Component Acquisition Executivereview the Multi-Role Enforcement Aircraft and the Medium Lift Helicopterprograms to ensure they comply with all DHS Acquisition Lifecyclerequirements. Specifically, CBP’s Component Acquisition Executive shoulddetermine whether the Acquisition Program Baseline for the Medium LiftHelicopter program reflects revised requirements accurately.

We recommend CBP AMO conduct a postimplementation review of the Medium Lift Helicopter program to determinewhether the deployed system is meeting capability needs, take correctiveactions as appropriate, and apply lessons learned for future acquisitions.

The under secretary for health makes certain that policies and procedures are developed to require VA police, and other VHA staff as appropriate, to conduct searches for all persons who are reported missing on medical center campuses.

The assistant under secretary for health for operations, in consultation with the VA chief security officer, requires VA police chiefs at medical centers to obtain approval from the facility associate director or the medical center director prior to excluding a building or area of the medical centers campus from regular patrols, and, if the building or area is subject to an enhanced-use lease, confirms with the Office of Enterprise Asset Management and the Office of General Counsel that the exclusion is not in conflict with the terms of the lease.

For all medical centers that have property subject to enhanced-use leases, the assistant under secretary for health for operations, in consultation with the VA chief security officer, requires the medical center director or the directors designee to meet with the assigned oversight monitor at the Office of Asset Enterprise Management, the designated local site monitor, and a representative of the Office of General Counsel at least annually"or sooner if there is a change of lease terms or facility leadership"to discuss the terms of the enhanced-use leases and the lessees and VAs responsibilities with respect to the leased properties.

Develop specific guidance regarding communication withdetainees regarding their medical conditions and care and ensure facilitiesimplement this guidance.

We recommend the Director, U.S. Immigration and Customs Enforcement: Ensure all detention facilities that conduct whole-facilitytesting have submitted plans to ICE and that these plans have been approved.

We recommend the Director, Cybersecurity and Infrastructure Security Agency: Recommendation 1: Update the Dams Sector-Specific Plan as required, ensuring alignment with the updated National Infrastructure Protection Plan currently under development.

We recommend the Director, Cybersecurity and Infrastructure Security Agency: Formalize CISA's organizational structure to clarify roles, responsibilities, coordination processes, and reporting procedures across all divisions performing activities relating to CISA's role as the Sector-Specific Agency for the Dams Sector.

We recommend the Director, Cybersecurity and Infrastructure Security Agency: Establish policies, procedures, and performance metrics to help ensure CISA divisions consistently assess the impact of all programs and activities relating to CISA's role as the Sector-Specific Agency for the Dams Sector, and that CISA assess their effectiveness in the role of Sector-Specific Agency for the Dams Sector.

We recommend the Director, Cybersecurity and Infrastructure Security Agency: Develop and implement a strategy for Dams Sector stakeholders to use the HSIN-CI Dams Portal to its fullest potential. CISA should develop metrics on usage, performance, and training needs; update the HSIN-CI Dams Portal with clear instructions; and encourage sharing of lessons learned, after action reports, and best practices among stakeholders.

We recommend that the Colorado Department of Health Care Policy and Financing work with CMS to determine the total amount of claims that were eligible for rebates as well as the unallowable portion of the physician-administered drug claims, invoice drug manufacturers for the calculated rebates, and refund the Federal share of rebates collected for the years covered by our audit period and for years after our audit period.

We recommend that the Colorado Department of Health Care Policy and Financing develop and implement policies and procedures to ensure that all eligible physician-administered drugs, including those dispensed to MCO enrollees, are invoiced for rebate.

Develop a strategy to work with Federal agencies to reduce the eligible disposal backlog.

Review policies and procedures and determine which internal stakeholders, including the IG, should be notified and revise policies and procedures as necessary.

Prioritize creation of DEER and DCR Audit Reports under the ARCIS contract.

Develop a strategy to transition agencies to use the ARCIS Customer Portal Disposition Module.

Develop and implement an ARCIS internal user manual.

Take steps to ensure that all convictions and adverse actions are reported to Federal partners within the appropriate timeframes

Revise the Unit's MOU with the State Medicaid agency to establish procedures by which the Unit will receive referrals of potential fraud from managed care organizations

The Bureau of Fiscal Operations should develop and maintain comprehensive set of policies and procedures for the Debt Recovery Section, Financial Systems Section, and Treasury Section, using in-house personnel with adequate relevant expertise and experience, or outsource the task to an entity with the relevant expertise and experience.

The Bureau of Fiscal Operations should maintain documentary evidence of adequate periodic review of control activities performed.

The Bureau of Fiscal Operations should ensure that the Debt Recovery Section’s policies and procedures include guidance and process for developing and modifying thresholds, including those related to waivers and write-offs.

The Bureau of Fiscal Operations should maintain documentary evidence of adequate supervisory review of control activities around recording of transactions and reconciliations for the Debt Recovery Section.

The Bureau of Fiscal Operations should develop and maintain a comprehensive set of policies and procedures for outsourcing the Financial Systems Section functions.

Determine the allowability of the questioned transactions and recover $32,153,264, if applicable.

Establish review and monitoring standards for loans and report the results of those activities.

Review, update, and implement revised policies and procedures related to the loan program including, NARA 1572, Preventing Theft and Vandalism of NARA Holdings in NARA Facilities, NARA 1611, Loans of Archival Holdings to Federal Originators, NARA 1611 Supplement, Procedures for Loans to Originators, NARA 1612, Exhibition Loans and Traveling Exhibits, NARA 1612 Supplement 1, Procedures for Exhibition Loans, and NARA 1702, Transporting Holdings in NARA's Physical and Legal Custody, to ensure they are reflective of current practices and the organizational structure.

Ensure current Research Services and Legislative Archives, Presidential Libraries, and Museum Services employees are familiar with and properly trained on the updated loan program.