Open Recommendations

We recommend that the Vermont Agency of Human Services, Department of Vermont Health Access refund to the Federal Government $47,389 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.

We recommend that the Vermont Agency of Human Services, Department of Vermont Health Access • work with CMS to determine the unallowable portion of $78,363 (Federal share) for other claims for multiple-source physician-administered drugs that may have been ineligible for Federal reimbursement, refund that amount, and consider invoicing drug manufacturers for rebates for these drugs if CMS determines that the drug claims are allowable.

We recommend that the Vermont Agency of Human Services, Department of Vermont Health Access work with CMS to determine and refund the unallowable portion of Federal reimbursement for physician-administered drugs that were not invoiced for rebates after December 31, 2017.

We recommend that the Vermont Agency of Human Services, Department of Vermont Health Access strengthen its internal controls to ensure that all physician-administered drugs eligible for rebates are invoiced.

We recommend that Southwest Key Programs implement procedures to review leases and ensure that any ancillary costs claimed comply with Federal regulations.

We recommend that Southwest Key Programs maintain supporting documentation that shows employees who receive a bonus qualify for the bonus and that bonuses paid comply with Southwest Key’s bonus policy and Federal regulations.

We recommend that Southwest Key Programs revise the bonus policy to establish a maximum percentage when calculating bonuses paid with Federal funds and to ensure that all bonuses are reasonable.

We recommend that Southwest Key Programs ensure that no Federal funding, direct or indirect, is used for future compensation that exceeds the statutorily allowed rate for executive compensation.

We recommend that Southwest Key Programs develop a quality control procedure to ensure that costs claimed are accurate, adequately supported, and benefit the award.

We recommend that Southwest Key Programs maintain documentation to support the FFRs.

We recommend that the Office of Refugee Resettlement review Southwest Key’s remaining UAC facility leases to determine whether they qualify as capital leases, and recover any unallowable costs.

We recommend that the Office of Refugee Resettlement review the capital leases identified in our audit to determine the amount of unallowable costs associated with the leases since their inception and after our review, and recover any unallowable costs.

We recommend that the Office of Refugee Resettlement review UAC facility leases since their inception and after our review to ensure the leases meet Federal requirements and include only allowable costs, and recover any unallowable costs.

We recommend that the Office of Refugee Resettlement ensure that Southwest Key adheres to the statutorily allowed rate for executive compensation.

We recommend that the Office of Refugee Resettlement review Southwest Key’s bonus policy to ensure that it meets Federal requirements.

We recommend that the Office of Refugee Resettlement provide guidance to Southwest Key related to allowable renovation costs and when prior approval for renovations is required.

Develop and implement policies and procedures to (1) identify beneficiaries transferring from traditional Medicare to MA, and (2) evaluate whether the acute stroke diagnosis codes submitted under traditional Medicare comply with Federal requirements.

In coordination with the Office of Chief Financial Officer, engage relevant Centers and technical capability leaders to implement budgetary and accounting system options to support critical discipline capabilities.

We recommend that Mercy Health Visiting Nurse Services refund to the Medicare program the portion of the estimated $1,074,136 in overpayments for claims incorrectly billed that are within the 4-year reopening period.

CMS should work with the manufacturers associated with errors to correct and resubmit accurate product data.

Establish and implement procedures to ensure E2 account management practices enforce DOL’s security policies.

Establish and implement procedures to ensure E2 is managed in compliance with contractual security requirements and DOL computer security policies for contracted information systems.

To enhance its stewardship activities, we recommend that the National Institutes of Health: establish an oversight body that ensures property accountability management responsibilities and control activities for Government property are performed

To enhance its stewardship activities, we recommend that the National Institutes of Health: appoint a Board of Survey and Survey officers at each IC and complete investigations and reviews on incidents to accountable property, and conduct them going forward according to property management policy and procedures

To enhance its stewardship activities, we recommend that the National Institutes of Health: formalize and implement a performance indicator for the completion of investigations for lost, damaged, stolen, or destroyed accountable property and risk indicators to use together with other performance indicators in its accountable personal property management program;

To enhance its stewardship activities, we recommend that the National Institutes of Health: implement routine mandatory training for ICs’ procurement personnel and Property Custodial and Accountability officers on its Personal Property Management policies and procedures;

To enhance its stewardship activities, we recommend that the National Institutes of Health: complete corrective actions for FYs 2017 and 2018 FMFIA audits’ control deficiency record;

To enhance its stewardship activities, we recommend that the National Institutes of Health: develop relevant milestones with estimated milestone completion dates that support the implementation of a standardized agencywide operating model that centralizes and integrates software asset management and software license management;

To enhance its stewardship activities, we recommend that the National Institutes of Health: employ a primary software asset management tool that centralizes and automates the capture of software inventory and entitlement data into each IC operating environment.

Rec. B.1.a: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness develop policy that specifies how installation commanders should address serious juvenile-on-juvenile misconduct incidents.

Rec. B.1.b: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness develop policy that identifies which support agency will provide counseling support services to victims and offenders of serious juvenile-on-juvenile misconduct incidents.

Rec. B.2: The DoD OIG recommended that the Secretaries of the Army, Navy, and Air Force update Military Law Enforcement Organization and Military Criminal Investigative Organization policies to require personnel to document in all investigative case files all notifications to civilian legal authorities and installation commanders, and, when possible, the legal and administrative actions taken.

Rec. B.2: The DoD OIG recommended that the Secretaries of the Army, Navy, and Air Force update Military Law Enforcement Organization and Military Criminal Investigative Organization policies to require personnel to document in all investigative case files all notifications to civilian legal authorities and installation commanders, and, when possible, the legal and administrative actions taken.

Rec. B.2: The DoD OIG recommended that the Secretaries of the Army, Navy, and Air Force update Military Law Enforcement Organization and Military Criminal Investigative Organization policies to require personnel to document in all investigative case files all notifications to civilian legal authorities and installation commanders, and, when possible, the legal and administrative actions taken.

CMS should require MAOs to implement best practices to ensure care coordination for HRAs.

CMS should provide targeted oversight of the 10 parent organizations that drove most of the risk-adjusted payments resulting from in-home HRAs.

CMS should provide targeted oversight of the 20 MAOs that drove risk-adjusted payments resulting from in-home HRAs for beneficiaries who had no other service records in the 2016 encounter data.

CMS should reassess the risks and benefits of allowing in-home HRAs to be used as sources of diagnoses for risk adjustment and reconsider excluding such diagnoses from risk adjustment.

CMS should require MAOs to flag any MAO-initiated HRAs in their MA encounter data.

We recommend that Baylor Scott & White-College Station refund to the Medicare contractor the portion of the $189,27637 in estimated overpayments for incorrectly billed claims that are within the 4-year reopening period.

We recommend that Baylor Scott & White-College Station improve procedures and provide education to ensure claims billed to Medicare are accurate.

We recommend that Baylor Scott & White-College Station implement changes to billing system to ensure claims billed to Medicare are accurate.

We recommend the Administrator for the Federal Emergency Management Agency revise FEMA's approach to ensure equitable and timely distribution of mitigation funding. At a minimum, FEMA should: - devise a plan and conduct outreach to communities with a large number of SRL properties to identify and address barriers to their participation in the Flood Mitigation Assistance (FMA) grant program; - update regional, state, and community training to address inconsistent practices and requirements that hinder NFIP-insured participation in the FMA grant program; and - develop and implement policies and procedures to monitor and enforce grant requirements.

We recommend the Administrator for the Federal Emergency Management Agency devise a plan to strengthen its management of SRL properties and ensure the accuracy of the SRL list. The plan should: - assign specific roles and responsibilities to ensure cross-division integration, implementation, and monitoring of FEMA's SRL strategy; - improve its workflow tracking system to monitor all requested changes to the SRL list and capture resulting outcomes; and - evaluate alternatives for updating the SRL list apart from Form AW-501, such as permitting updates to a property's mitigation status based on submission of a proper elevation certificate.

CMS should require that participating States consistently submit data that allow for CMS and each State to calculate determinations of ineligibility.

update the CBMS by implementing an automatically accessible eligibility history that retains all beneficiary histories when retroactive changes occur, thereby eliminating the need for manual interventions to identify changes in eligibility status

ensure that the MMIS retains all beneficiary eligibility changes and reconcile the beneficiaries’ data contained in the MMIS to the data in the CBMS to determine whether discrepancies in Medicaid eligibility groups are occurring

ensure that the CBMS has automated edits to enroll Transitional Medicaid beneficiaries in the correct eligibility group

(U) Rec. 2: This recommendation is Controlled Unclassified Information

The Chief of Management and Administration and the Chief Operating Officer ensure the Risk Executive, Chief of Management and Administration, Chief Operating Officer, and Senior Accountable Official for risk management roles and responsibilities are fully and accurately defined in NARA policies.