Open Recommendations

Continue to work with states to develop, operate, and maintain a modular set of technological capabilities to modernize the delivery of UI benefits that is sufficient to manage and process sudden spikes in claims volume during emergencies or high unemployment.

Assist states with claims, overpayment, and fraud reporting to create clear and accurate information. Then use the overpayment and fraud reporting to prioritize and assist states with fraud detection and recovery.

We recommend that Caretenders 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 Caretenders strengthen its procedures to ensure that the homebound status of Medicare beneficiaries is verified and continually monitored and the specific factors qualifying beneficiaries as homebound are documented; beneficiaries are receiving only reasonable and necessary skilled services; and HIPPS codes are billed correctly.

We recommend that Gateway refund $932,607 claimed in unallowable costs related to: (1) indirect costs ($356,121), (2) credits received from vendors ($338,363), (3) equipment that was not purchased in accordance with Federal open competition procurement regulations ($208,600), and (4) use of company vehicles ($29,523). Specifically, Gateway did not adjust its indirect costs claimed based on its provisional rate to reflect its final rate. As a result, Gateway claimed an excess of $356,121 applicable to our audit period. In addition, Gateway received reimbursement checks related to the FCC's E-Rate; however, it did not credit its Head Start grant through cost reductions…

We recommend Gateway update and follow its procedures to ensure compliance with all Federal requirements and the accuracy of cost information, including cost proposals, submitted to ACF. Gateway did not comply with Federal requirements related to new construction and major renovations of its Head Start facilities. Gateway inappropriately used Disaster Relief Act funds, did not establish that it had a lack of suitable facilities, and submitted an unreliable cost comparison for the construction of a $22 million facility. In addition, Gateway requested and received funds for major renovations based on a cost estimate that was neither accurate nor prepared by…

We recommend that Gateway ensure that costs are allocated to Federal awards in accordance with the relative benefits received.

We recommend that the Administration for Children and Families ensure that Gateway complies with Federal requirements and verify information submitted by Gateway to support Gateway's grant award applications, including requesting Gateway to obtain independent analyses of cost comparisons for Head Start facility construction and major renovations.

Determine the allowability of the questioned transactions and recover $8,008,786, if applicable.

Ensure costs for physical infrastructure upgrades funded by 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.

We recommend that BCBS of SC decrease its Excess Plan Partial Medicare Segment pension assets by $2,796,877 and recognize a negative $10,750 as the Excess Plan Partial Medicare Segment pension assets as of January 1, 2017.

We recommend that BCBS of SC develop and implement policies and procedures to ensure that going forward, it calculates Medicare segment pension assets in accordance with Federal requirements.

(U) Rec. 2.a-b: The DoD OIG recommended that the Commander of the Naval Aviation Warfighting Development Center develop guidance for Navy personnel maintaining Naval Aviation Warfighting Development Center aircraft that includes a clear definition of the: a. Minimum number of mission-capable aircraft that aligns with Naval Aviation Warfighting Development Center's readiness standards to complete the required operational flights to meet carrier air wing training requirements. b. Aircraft system requirements in the Mission-Essential Subsystems Matrix for aircraft used as adversary aircraft for carrier air wing training.

We recommend that the NOAA Deputy Under Secretary for Operations ensure that OMAO develop and regularly update a long-range vessel acquisition plan that lays out the dependencies between fleet objectives, funding, inventory, technology, and sustainment costs, among others, and supports program milestone requirements.

Annually conduct and document training for all staff and senior managers and policy makers to affirm the office's commitment to the Scientific Integrity Policy and principles and to promote a culture of scientific integrity.

We recommend that the Centers for Medicare & Medicaid Services direct the Medicare contractors to recover the $291,813 from physicians for instances in which the same physicians reported more than one CPT code and received MCPs for monthly ESRD-related services provided to the same beneficiary for the same month of service (for claims that are within the 4-year reopening period)

We recommend that the Centers for Medicare & Medicaid Services direct the Medicare contractors to instruct the physicians to refund beneficiaries the $1,092,149 in beneficiary cost-sharing (deductible and coinsurance) amounts that may have been incorrectly collected from beneficiaries or from someone on their behalf

We recommend that the Centers for Medicare & Medicaid Services direct the Medicare contractors to review the 1,598 claims totaling $289,169 in MCPs for potentially duplicate claims and $74,563 in associated beneficiary cost sharing (deductible and coinsurance amounts) and determine which of the claims should have been denied as a duplicate claim for ESRD-related services and o recover the portion of any MCPs from the physicians for claims for duplicate services (that are within the 4-year reopening period), and o instruct the physicians to refund beneficiaries the portion of the deductible and coinsurance amounts that may have been incorrectly collected…

We recommend that CMS based on the results of this audit, notify appropriate physicians (i.e., those for whom CMS determines that this audit constitutes credible information of potential overpayments) so that the physicians 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 recommend that CMS • implement improved claims processing controls, including improved system edits, to prevent and detect overpayments of claims for duplicate services.

We recommend that Anthem Community Insurance Company, Inc. refund to the Federal Government the $3,468,954 of net overpayments.

We recommend that Anthem Community Insurance Company, 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 Anthem Community Insurance Company, Inc. enhance its compliance procedures to focus on diagnosis codes that are at high risk for being miscoded by determining whether these diagnosis codes (when submitted to CMS for use in CMS’s risk adjustment program) comply with Federal requirements and educating its providers about the proper use of these diagnosis codes.

Rec. 1.c: The DoD OIG recommended that the Under Secretary of Defense for Research and Engineering and the Under Secretary of Defense for Acquisition and Sustainment revise DoD Instruction 5000.85 and its supplementary acquisition policy issuances to require program managers of major defense acquisition programs to use scientific test and analysis techniques to the maximum extent possible to develop the Test and Evaluation Master Plan.

Rec. 1.f: The DoD OIG recommended that the Under Secretary of Defense for Research and Engineering and the Under Secretary of Defense for Acquisition and Sustainment revise DoD Instruction 5000.85 and its supplementary acquisition policy issuances to require program managers of major defense acquisition programs to include the most critical or stressing test conditions in revised test plans when proposing elimination, deferral, or modification of planned tests that were originally documented in the Test and Evaluation Master Plan.

Require the Chicago PD to perform an in-depth review of its equitable sharing financial
activity and either: (1) provide detailed documentation to support its existing FY 2019 and
FY 2020 ESAC submissions, or (2) submit amended ESACs along with detailed documentation
to support the balance and expenditure figures reported.

We recommend that Sleep Management refund to the Federal Government the portion of the estimated $29,131,187 in Medicare overpayments for claim lines incorrectly billed that are within the 4-year reopening period.

We recommend that Sleep Management follow existing policies and procedures to help ensure that it: (1) obtains medical record documentation that is sufficient to satisfy Medicare medical necessity requirements and (2) discontinues service when beneficiaries do not continually use the device.

Conduct periodic reviews of the level of basic essential air service in accordance with Federal regulations.

We recommend that the New York State Office of Temporary and Disability Assistance work with its local districts and TANF-funded State programs to develop financial management procedures that would enable the State agency to determine if TANF and MOE expenditures are accurately reported to ACF, including the $4.8 billion in TANF and MOE expenditures reported for FY 2016.

We recommend that the New York State Office of Temporary and Disability Assistance improve its oversight of the TANF program by providing additional guidance and training to ensure that its local districts accurately report expenditures and maintain adequate documentation to support TANF and MOE expenditures reported.

We recommend that Franciscan: Refund to the Federal Government the portion of the estimated $13,027,841 for hospice services that did not comply with Medicare requirements and that are within the 4-year reopening period.

We recommend that Franciscan: strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

(U) Rec. 6.a: The DoD OIG recommended that the Under Secretary of Defense for Acquisition and Sustainment, in conjunction with the Under Secretary of Defense for Policy and U.S. Special Operations Command, develop a plan of action and milestones to establish policies related to the capability of United States defense contractors to meet DoD Counter Threat Finance mission needs.

(U) Rec. 6.b: The DoD OIG recommended that the Under Secretary of Defense for Acquisition and Sustainment, in conjunction with the Under Secretary of Defense for Policy and U.S. Special Operations Command, develop a plan of action and milestones to coordinate with the Under Secretary of Defense for Intelligence on innovative uses of technology to address intelligence-related Counter Threat Finance issues.

Recommendation 4 (Rolled Forward from FYs 2017 to 2019)11 We recommend that Retirement Services develop and implement additional cost effective corrective actions, aimed at the root causes of improper payments, to further reduce the improper payments rate.

We recommend the DHS Office of the Secretary establish an oversight structure with central policy guidance and direction to ensure DHS law enforcement components comply with the DNA Fingerprint Act of 2005and 28 C.F.R. § 28.12.

We recommend the DHS Office of the Secretary ensure ICE, FPS, CBP, and TSA fully implement DNA collection for arrestees and nonU.S. detainees to comply with the DNA Fingerprint Act of 2005 and 28 C.F.R § 28.12.

We recommend the DHS Office of the Secretary ensure ICE, FPS, CBP, and TSA implement internal controls, including modifying booking systems to track and verify DNA collection. If components pursue memorandums of agreement with other agencies to collect DNA samples, they must implement internal controls to track and verify DNA collection.

We recommend the Acting Director of ICE ensure that before removing parents who have minor children in the United States, ICE staff document and obtain supervisory acknowledgement for each parent’s preference for whether the children should remain in the United States or be removed with the parent.

We recommend that Alive Hospice, Inc.: • refund to the Federal Government the portion of the estimated $7,389,854 for hospice services that did not comply with Medicare requirements and that are within the 4-year reopening period

We recommend that Alive Hospice, 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; and

We recommend that Alive Hospice, Inc. strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend that Ambercare Hospice, 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; and

We recommend that Ambercare Hospice, Inc. strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

HHS should continue to work with OMB and other stakeholders to develop and implement an approach to reporting on CDC and OHS Disaster Relief improper payments in FY 2021

HHS should continue to work with OMB and other stakeholders, including considering recommendations from recent OIG audits, to develop and implement an approach to reporting on APTC improper payments in FY 2021

HHS should continue to explore a vehicle to conduct recovery audits that will fit into the larger Medicare Part C program in FY 2021

HHS should continue to follow up with States during the interim period to verify that corrective actions identified after the improper payment error rate measurement review for the Medicaid and CHIP programs are being implemented. NOTE: The current COVID-19 public health emergency may impact the ability of States to analyze and follow up on corrective action plans. Consequently, this will impact the information reported to CMS.

HHS should focus on the root causes of the improper payment percentage and evaluate critical and feasible action steps to assist States with their compliance efforts for new requirements of the Medicaid and CHIP programs