Open Recommendations

Establish and implement a process to ensure that The Office of Multifamily Housing Programs' policies, procedures, and supervisory controls are effective. This process should include addressing postdisaster damage assessments, properly updating iREMS, and executing loan forbearances. This process should also integrate with other HUD program offices as appropriate to improve consistency with HUD's overall disaster response and to ensure the effectiveness of disaster controls.

(U) Rec. A.1.b: The DoD OIG recommended that the Under Secretary of Defense for Acquisition and Sustainment revise DoD Instruction 4715.18 to include requirements for Emerging Chemical Program officials to develop risk management options and initiate proactive risk management actions which may be warranted to identify and mitigate the contaminant effects of emerging chemicals as early as possible in the Emerging Chemical Process, regardless of whether an emerging chemical is on the Emerging Chemical Watch List or the Emerging Chemical Action List.

(U) Rec. A.2: The DoD OIG recommended that the Deputy Assistant Secretary of Defense (Environment and Energy Resilience) complete the Emerging Chemical Process for potential perfluoroalkyl and polyfluoroalkyl substances exposure caused by DoD activities from perfluoroalkyl and polyfluoroalkyl substance-containing materials other than Aqueous Film Forming Foam by developing and presenting validated risk management options for the perfluoroalkyl and polyfluoroalkyl substances on the Emerging Chemical Action List to the Emerging Chemicals of Concern Governance Council, as required by DoD Instruction 4715.18.

(U) Rec. B: The DoD OIG recommended that the Assistant Secretary of Defense (Readiness) develop a plan to track, trend, and analyze DoD firefighter perfluoroalkyl and polyfluoroalkyl substances blood test results at a DoD-wide level, in accordance with DoD Instruction 6055.05.

We recommend that the Texas Health and Human Services Commission refund $856,456 to the Federal Government.

We recommend that the Texas Health and Human Services Commission identify and recover additional unallowable CHIP payments made before and after our audit period for the 572 beneficiary-matches and repay the Federal share.

We recommend that the Texas Health and Human Services Commission identify any other beneficiaries who are assigned more than one identification number and refund any unallowable CHIP payments associated with those beneficiaries.

We recommend that the Texas Health and Human Services Commission strengthen its procedures for determining whether applicants are already enrolled in any medical or public assistance benefits throughout the State and ensure that no beneficiary is assigned more than one identification number.

Direct TSU to strengthen the administrative and management controls and processes over obtaining and maintaining sufficient supporting documentation.

Direct TSU to strengthen its administrative and management controls and processes over the proper allocation of costs.

Direct TSU to update its administrative and management processes and internal control procedures related to assigning participant support costs within its accounting system.

Direct TSU to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice system.

Direct TSU to strengthen the administrative and management procedures over certifying time and effort reports in a timely manner.

Direct TSU to strengthen the administrative and management procedures to require the inclusion of pertinent information on time and effort reports such as fund codes, award numbers, and work descriptions.

We recommend that the New York State Department of Health refund to the Federal Government or provide documentation of such refund, totaling $97,998,292. Specifically refund to the Federal Government $77,152,491 related to random moments that could not be supported as Medicaid-eligible health services; refund to the Federal Government $1,238,102 for intergovernmental agreement payments that the State agency did not support that it did not double-claim; and refund to the Federal Government or provide documentation of the refund to CMS of $19,607,699 for excess costs claimed on the Form CMS-64 for 1 year.

We recommend that the New York State Department of Health refund $32,267,478 to the Federal Government or provide documentation to CMS to establish that it met an exception to use SY 2013 RMTSs to allocate costs for SY 2012.

We recommend that the New York State Department of Health refund $308,972,87027 to the Federal Government or provide documentation that it can reasonably support, under the circumstances, its allocation of health services costs to Medicaid without using unverifiable IEP ratios.

We recommend that the New York State Department of Health ensure that its contractor (1) collects sufficient information so the State agency can validate the contractor's coding of sampled moments and (2) correctly offsets and supports intergovernmental agreement transactions.

We recommend that the New York State Department of Health revise its certified public expenditures SSHSP to (1) include September days worked in its random moment time study and (2) develop an accurate, supportable method to identify Medicaid costs instead of unverifiable IEP ratios.

We recommend that Palmetto GBA, LLC, discontinue using its internal policies of waiving certain overpayment collections related to lookback years and start collecting all hospice cap overpayments and paying refunds in accordance with CMS requirements.

We recommend that Palmetto GBA, LLC develop processes for communication between the departments directly and indirectly involved in hospice cap oversight.

Clarify its policies as to what type of file FBI employees should use to retain documentation received during Pre-Assessment activities that continue for more than 5 days.

Reassess its policies to more precisely describe for FBI employees when they are required to promptly contact and coordinate with applicable state and local law enforcement and social service agencies after receiving allegations of crimes against children that potentially fall under state jurisdiction, even when the allegations also potentially fall within the FBI's jurisdiction.

Train FBI employees on the policies discussed in the first three recommendations and any changes made to them.

Develop and implement a process to segregate non-CDL holder convictions from all Commercial Driver's License Information System reports and workbooks utilized to evaluate State's compliance with CDL regulations.

We recommend that Partners In Care, Inc. refund to the Federal Government the portion of the estimated $11,278,891 for hospiceservices that did not comply with Medicare requirements and that are within the 4-yearreopening period.

We recommend that Partners In Care, Inc. based upon 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 of those returned overpayments as having been made in accordance with this recommendation.

We recommend that Partners In Care, Inc. strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend the Federal Emergency Management Agency Administrator address unresolved implementation issues, publish proposed regulations for notice and comment within 1 year, and issue final regulations within 3 years of issuance of this report for implementation of the Disaster Mitigation Act of 2000, 42 U.S.C. § 5172(b)(2).

We recommend the Federal Emergency Management Agency Administrator review and resolve hazard mitigation challenges, such as: 1. ensuring education and training of states and applicants on mitigationprograms and availability of funding at the state and applicant levels;2. revising criteria and instructions for completing benefit-cost analyses toclarify and streamline the process and assist applicants with meeting therequired benefit-cost threshold;3. streamlining the processes from application submission to approval todecrease applicants’ wait time for mitigation; and4. considering existing flexibilities to adjust the cost share for applicantsexperiencing financial hardships.

Update Agency guidance on practical enforceability to more clearly describe how the technical accuracy of a permit limit should be supported and documented. In updating such guidance, the Office of Air and Radiation should consult and collaborate with the Office of Enforcement and Compliance Assurance, the Office of General Counsel, and the EPA regions.

In consultation with the EPA regions, develop and implement an oversight plan to include: a. An initial review of a sample of synthetic-minor-source permits in different industries that are issued by state, local, and tribal agencies to assess whether the permits adhere to EPA guidance on practical enforceability, including limits that are technically accurate; have appropriate time periods; and include sufficient monitoring, record-keeping, and reporting requirements. b. A periodic review of a sample of synthetic-minor-source permits to occur, at a minimum, once every five years. c. Procedures to resolve any permitting deficiencies identified during the initial and periodic reviews.

Assess recent EPA studies of enclosed combustion device performance and compliance monitoring and other relevant Air and Radiation information during the next statutorily required review of 40 C.F.R Part 60 Subparts OOOO and OOOOa to determine whether revisions are needed to monitoring, record-keeping, and reporting requirements for enclosed combustion devices to assure continuous compliance with associated limits, and revise the regulatory requirements as appropriate.

Revise the Agency's guidance to communicate its key expectations for synthetic-minor-source permitting to state and Air and Radiation local agencies.

Identify all state, local, and tribal agencies in which Clean Air Act permit program implementation fails to adhere to the public Air and Radiation participation requirements for synthetic-minor-source permit issuance and take appropriate steps to assure the identified states adhere to the public participation requirements.

We recommend that Mission Hospice & Home Care, Inc.: refund to the Federal Government the portion of the estimated $10,564,396 for hospice services that did not comply with Medicare requirements and that are within the 4-year reopening period.

We recommend that Mission Hospice & Home Care, Inc.: strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services, as part of its ERM program, implement a process to assess all of its programs for national security risks in accordance with OMB Circular No. A-123's requirement to include new or emerging risks in the risk profile.

We recommend the Associate Administrator, FEMA Office of Response and Recovery ensure its direct housing information system provides flexibility implementing alternative direct housing options; provides support to states, territories, and tribal governments administering direct housing assistance; and facilitates data exchange and sharing with non-FEMA information systems.

Reassess the cost estimate for Electronic Health Record Modernization program-related information technology infrastructure and refine as needed to comply with VA’s cost-estimating standards.

Develop procedures for cost-estimating staff that align with VA cost-estimating guidance.

Ensure costs for all information technology infrastructure upgrades funded by the Office of Information and Technology and the Veterans Health Administration or other sources needed to support the Electronic Health Record Modernization program are disclosed in program life-cycle cost estimates presented to Congress.

Formalize agreements with the Office of Information and Technology and the Veterans Health Administration identifying the expected contributions from each entity toward information technology infrastructure upgrades in support of the Electronic Health Record Modernization program.

Establish procedures that identify when life-cycle cost estimates should be updated and ensure those updated estimates are disclosed in the program’s congressionally mandated reports.

We recommend that Puerto Rico Department of Health revise its EOP, including adding or updating procedures, to comply with HPP-PHEP Cooperative Agreement requirements related to: (1) conducting annual public health and medical preparedness exercises or drills that include at-risk populations in all of its planning and activities; (2) identifying resources for at-risk populations; (3) anticipating storage needs for a surge of human remains; (4) implementing and identifying emergency procurement procedures; (5) clearly defining HCC Specialists' responsibilities; (6) obtaining public comment and input on its EOP; (7) utilizing EMAC or other public health mutual aid agreements to support coordinated activities when…

We recommend that the Puerto Rico Department of Health consider working with ASPR to develop an effective method for contacting healthcare volunteers when there are communication challenges.

We recommend that Puerto Rico Department of Health consider coordinating with appropriate organizations to develop guidance on accurate cause-of-death certifications focusing on whether underlying causes of death were disaster-related.

We recommend that the New York State Department of Health (State agency) refund $6,027,566 to the Federal Government.

Based on the results of this audit, we recommend that the Centers for Medicare & Medicaid Services notify appropriate providers (i.e., those for whom CMS determines that this audit constitutes credible information of potential overpayments) so that the providers 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.

Based on the results of this audit, we recommend that the Centers for Medicare & Medicaid Services implement claims processing controls, including system edits, to prevent and detect overpayments for TCM.