Open Recommendations

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

HHS should continue to work with the Office of Management and Budget and other stakeholders to develop and implement an approach to reporting on Temporary Assistance for Needy Families (TANF) improper payments in FY 2021, which will aid in identifying root causes of TANF improper payments and allow HHS to develop and report corrective action plans

Provide guidance identifying programs and/or activities as a part of its internal guidance and in accordance with achieving its mission requirements.

Align programs and/or activities with applicable reporting requirements.

Report programs and/or activities in accordance with applicable Federal criteria.

Provide training to CPSC program managers on how to develop and implement a formal internal controls program in accordance with Standards for Internal Control in the Federal Government, OMB Circular A-123, and CPSC policies and procedures.

Develop a formal internal controls program over operations for CPSC programs.

Establish formal lines of communication between the Office of Financial Management, Planning and Evaluation and CPSC program management for the purpose of assessing and monitoring internal control programs and compliance with FMFIA requirements.

Standardize acquisition and assistance award requirements to include (a) codes of conduct specific to sexual exploitation and abuse for all implementers and (b) requirements for implementers to review and certify that subimplementers establish sexual exploitation and abuse-related internal controls and codes of conduct.

Issue guidance to Agency staff on roles and responsibilities for assessing implementers' internal controls designed to protect beneficiaries from sexual exploitation and abuse when conducting pre-award risk assessments.

We recommend that the New York State Department of Health refund $9,325,338 to the Federal Government

We recommend that the New York State Department of Health identify and recover improper managed care payments made to the same MCO on behalf of beneficiaries with more than one Medicaid ID number prior to and after our audit period, and repay the Federal share of the amounts recovered

We recommend that the New York State Department of Health ensure that improvements made to its processes for determining whether an individual applying for Medicaid has already been assigned a Medicaid ID number are effective by verifying that: - system queries are adequate to identify all individuals with existing Medicaid ID numbers and - local district and Marketplace staff are following guidance on identifying individuals with Medicaid ID numbers and using all available resources to identify and prevent the issuance of more than one Medicaid ID number to the same individual.

We recommend that the Centers for Medicare & Medicaid Services direct the Medicare contractors to educate providers on the billing of direct LDL tests in addition to lipid panels (e.g., by providing guidance about the requirements for separately billing direct LDL tests).

We recommend that Suncoast Hospice refund to the Federal Government the portion of the estimated $47,363,971 for hospice services that did not comply with Medicare requirements and that are within the 4-year claims reopening period.

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

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

Conduct new residual risk reviews for Group I polymers and resins that cover neoprene production, synthetic organic chemical manufacturing industry, polyether polyols production, commercial sterilizers, and hospital sterilizers using the new risk values for chloroprene and ethylene oxide and revise the corresponding National Emission Standards for Hazardous Air Pollutants, as needed.

Revise National Emission Standards for Hazardous Air Pollutants for chemical manufacturing area sources to regulate ethylene oxide and conduct a residual risk review to ensure that the public is not exposed to unacceptable risks.