Open Recommendations

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to require that OT justification memos include explicit statements as to why a traditional award instrument could not be used for a project.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to require that justifications for the continued use of OT authority be documented throughout the life of OT agreements with reconsideration required at a defined frequency.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to specify requirements for determining and documenting the fairness and reasonableness of award amounts or cost estimates provided by OT award applicants.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to specify requirements for determining and documenting the allowability of costs charged to OT awards.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to specify requirements for determining and documenting its compliance with Federal funding requirements including the proper establishment of bona fide needs through specific work requirements prior to the obligation of OT funds.

Review the modified National Pollutant Discharge Elimination System mining permits issued by West Virginia based on the 2019 revisions to its National Pollutant Discharge Elimination System program to determine whether the permits contain effluent limits for ionic pollution and other pollutants that are or may be discharged at a level that causes, has the reasonable potential to cause, or contributes to an excursion above any applicable water quality standard, as required by Clean Water Act regulations. If a permit lacks required effluent limits, take appropriate action to address such deficiencies.

Rec. 1.e: The DoD OIG recommended that the Principal Director, Defense Pricing and Contracting clarify its policy for determining the approval level required for project awards when using consortiums and ensure the guidance is uniformly applied and implemented by contracting personnel.

Rec. 1.g: The DoD OIG recommended that the Principal Director, Defense Pricing and Contracting establish Department of Defense-level training specific to awarding other transactions through consortiums that ensures Agreements Officers receive training to demonstrate expertise in executing, managing, and administering complex acquisition instruments, and can function in a less structured environment where prudent judgment is essential.

Rec. 1.j: The DoD OIG recommended that the Principal Director, Defense Pricing and Contracting establish requirements to vet consortium members upon membership to identify which members meet applicable security requirements for future opportunities.

Rec. 1.m: The DoD OIG recommended that the Principal Director, Defense Pricing and Contracting develop procedures to require security reviews of solicitation and supplementary information, including the aggregate of all information being provided in the solicitations to ensure potential sensitive information is not revealed by the compilation of information.

We recommend that Humana, Inc. refund to the Federal Government the $197,720,651 of net overpayments

We recommend that Humana, Inc. enhance its policies and procedures to prevent, detect, and correct noncompliance with Federal requirements for diagnosis codes that are used to calculate risk-adjusted payments.

Establish a data strategy implementation project plan with milestones that consider mission priorities and current and expected staffing levels to track the progress of the data management program maturation against the current Data and Analytics Strategy Implementation Plan.

Develop and implement a Data Quality Plan that supports the collection and maintenance of data related to identified key CPSC open data sets.

Identify and assign responsibilities to all of the resources who have data governance roles and responsibilities. These resources should include, at a minimum, data owners and data stewards, and those resources should be trained on their responsibilities.

Dedicate resources to the data management program based on a needs assessment, which should be revisited as the FDS action plans are published. Supplementary resources to consider adding may include data architects, data scientists, data analysts, and training resources.

We recommend that the Georgia Department of Community Health remind nursing facilities of Federal and State requirements for reporting incidents of potential abuse or neglect.

We recommended that the Georgia Department of Community Health strengthen its procedures for monitoring nursing facilities and follow up with those that may not be following required policies and procedures.

We recommended that the State agency ensure that it documents actions it takes when nursing facilities fail to report incidents and fail to report incidents on time.

We recommended that the State agency ensure that it assigns a priority level to all incidents or complaints by the mandatory deadline.

We recommend that Palmetto Government Benefits Administrator, LLC decrease its Excess Plan Medicare segment pension assets by $9,196 and recognize $737,271 as the Excess Plan Palmetto Medicare segment pension assets as of January 1, 2017.

We recommend that Palmetto Government Benefits Administrator, LLC improve policies and procedures to ensure that going forward, it calculates Medicare segment pension assets in accordance with Federal requirements.

We recommend that Palmetto Government Benefits Administrator, LLC decrease its Excess Plan Medicare segment pension assets by $9,196 and recognize $737,271 as the Excess Plan Palmetto Medicare segment pension assets as of January 1, 2017.

We recommend that Palmetto Government Benefits Administrator, LLC improve policies and procedures to ensure that going forward, it calculates Medicare segment pension assets in accordance with Federal requirements.

Rec. C.1: The DoD OIG recommended that the Assistant Secretary of Defense for Manpower and Reserve Affairs, in coordination with the Director of Manpower and Personnel for the National Guard Bureau, establish and implement a plan to identify whether the Challenge Program is achieving long-term benefits of providing opportunities for cadets to be productive citizens. The plan should include a process for collecting data beyond 1 year.

CMS should encourage MAOs to perform program integrity oversight using ordering NPIs.

We recommend EEOC's Office of Information Technology (OIT) review and remediate criticalrisk and high-risk vulnerabilities in accordance with EEOC OIT’s assessment of risk. Where risk acceptance is required for vulnerabilities based on EEOC's network operation, we recommend thatEEOC formally document the risk acceptance along with any associated mitigation activities.

We recommend that OPM modify FEHBP contract lanugage for all applicable records retention clauses to require the retention and accessibility of claims for 10 years plus the current year in a manner of OPM/HI's choosing.

We recommend OPM modify or add language in Section 1.9 of all FEHBP contracts to inlcude all relevant sections and attachments of CL 2017-13, or modify all FEHBP contracts to add relevant language stating that all CLs are an addendum to the contract language and enforceable as a contract requirement.

We recommend OPM modify or add language to the appropriate Section of the FFS and ER-HMO FEHBP contracts to state that all FWA-related recoveries must be deposited into the working capital or investment account within 30 days and returned to or accounted for in the FEHBP contingency reserve fund account within 60 days after receipt by the carrier.

We recommend that OPM add language to all FEHBP contracts requiring carriers to notify the OIG's Office of Investigations regarding their intention to share FEHBP fraudulent activity with outside parties, and obtain approval from OIG's Office of Investigations before sharing this information.

We recommend that OPM modify the ER-HMO and FFS contracts to require that vendors under Large Provider Agreements return all FWA-related recoveries to the carrier within 30 days, whereby carriers must deposit these recoveries into their working capital or investment account within 30 days. Once deposited into one of these accounts, the carrier must return the recoveries to the contingency reserve fund.

We recommend that OPM modify Section 2.3(g) and 2.3(g)(ii) to provide expectations for how carriers are to proactively identify overpayments and to define what it means by egregious errors.

We recommend that OPM modify Section 2.3(g) requring carriers to report on their collection efforts, including how promptly the carrier initiated collection once the erroneous payment was identified and the causes of the claim payment errors.

We recommend that OPM review the current recovery process in Section 2.3(g)(1) through (5) and consider whether the use of benefit offsets, after the first written notification is sent, would be more cost efficient.

We recommend that OPM modify FEHBP contracts to clarify the Agency's authority to recoup projected improper payments identified by statistical sampling.

We recommend modifying Section 2.6(g), in the amendment to the Coordination of Benefits section of the FFS contract, to allow for the recovery of low dollar claims that result from claims system errors.

We recommend the Assistant Secretary for Mine Safety and Health: Update system controls to improve compliance of MSHA violations with the Mine Act and MSHA guidance in the following instances: a. Verify only authorized violation types used; b. Include all required phrases automatically in the “Condition or Practice” entry when the inspector selects 103(a) citations, 104(g)(1) orders, 104(e)(1)/104(e)(2) orders, or 107(a) orders; c. Ensure 104(d) orders and 104(g)(1) orders cite eligible CFR sections; d. Verify the correlations between the CFR or Mine Act sections of 104(b) orders and the original violation; e. Verify 104(d)(1) orders, 104(d)(2) orders, 104(e)(1) orders, and…

We recommend the Assistant Secretary for Mine Safety and Health: Improve the violations termination process by decreasing the percentage of future untimely terminations, improving the use of 104(b) orders, and not allowing due dates to be extended unless for specific, justified reasons listed on the violation form.

We recommend the Assistant Secretary for Mine Safety and Health: Develop a metric to measure performance and an internal control to verify timely uploading of violations from the inspector’s laptop/tablet into MCAS.

We recommend the Assistant Secretary for Mine Safety and Health: Complete periodic reviews to determine whether MSHA personnel are meeting the timely upload and recording of violations in MCAS, terminating violations by the due date, and effectively using 104(b) orders.

We recommend the Assistant Secretary for Mine Safety and Health: Work with the Solicitor’s Office and the Federal Mine Safety and Health Review Commission to implement a process to ensure violations listed in settlement agreements or court decisions still comply with the Mine Act and Mathies test.

1. We recommend that Sunrise Hospital & Medical Center refund to the Medicare contractor $23,606,895 ($23,615,809 less $8,914 that the Hospital has already repaid) in net estimated overpayments for the audit period for claims that it incorrectly billed that are within the 4-year reopening period.

3. We recommend that Sunrise Hospital & Medical Center strengthen controls to ensure that: (1) all IRF beneficiaries meet Medicare criteria for acute inpatient rehabilitation and all required documentation is included in the medical records, (2) all inpatient beneficiaries meet Medicare requirements for inpatient hospital services, (3) outlier payments are calculated correctly by billing the correct units of service and charges on the claim and staff are properly trained, (4) the use of bypass modifiers is supported in the medical records and staff are properly trained, and (5) HCPCS codes are supported in the medical records and staff are properly…

We recommend that the DOI select and implement a CDM SWAM tool that is compatible with the DOI's computer environment.

We recommend that the DOI establish, implement, and continuously review and update approved software lists (blacklists and whitelists) to ensure that unapproved, unsupported, or potentially malicious software is not present on bureau computer networks.

Enforce standard operating procedures requiring clearly defined performance goals and include performance targets in all future SBDC and WBC cooperative agreements and grants to objectively measure performance results

Collect and analyze the CARES Act entrepreneurial development cooperative agreement recipient’s performance results and establish a framework for setting goals for technical assistance programs in response to future disasters. Retain the analysis in program files for future guidance.

We recommend the Executive Associate Director of Enforcement and RemovalOperations direct the Phoenix Enforcement and Removal Field Officeresponsible for LPCC to: Ensure compliance and remedial action is taken toaddress LPCC’s use of force incidents and allegations of detainee mistreatmentby staff when warranted.

Disallow the $592,737 in questioned match costs to recover the $254,014 in Federal costs from LearningWorks for the program years 2017 and 2018 due to inadequate documentation to support its in-kind match contributions: donated classroom and office space, and teaching and administrative staff hours;