Open Recommendations

The Chief of Management and Administration develop, document, implement, and disseminate an organizational risk management strategy and policy, in accordance with NIST 800-39, and a process for coordination between cybersecurity and enterprise risk management.

We recommend that the Texas Health and Human Services Commission refund $83,833,972 in Federal funds it inappropriately received because it used IGTs derived from impermissible provider-related donations to fund the State share of DSRIP Program payments.

We recommend that the Texas Health and Human Services Commission provide its IGT entities with guidance about arrangements that may result in impermissible provider-related donations, such as those outlined in CMS’s clarifying letter.

We recommend that the Texas Health and Human Services Commission request that its IGT entities disclose if similar arrangements exist and provide the State agency with action plans on ending the arrangements.

Develop and implement a Department-wide structure and designate an office to manage and oversee forfeiture activities across DHS, including: - reviewing component policies and procedures to ensure alignment with CAFRA; - developing performance objectives, measures, and plans; and - periodically requesting and reviewing component administrative forfeiture data for alignment with departmental and component goals.

Develop Department-wide policies and procedures, including: - consistent CAFRA notices and forms that meet Federal plain language writing requirements; and - consistent interpretation on managing CAFRA claims and use of a Hold Harmless Agreement.

CMS should establish and implement “reject edits” that (1) reject encounter records in which the ordering provider NPI is not present when required and (2) reject encounter records that contain an ordering provider NPI that is not a valid and active NPI in the NPPES registry.

CMS should require MAOs to submit the ordering provider NPI on encounter records for DMEPOS and for laboratory, imaging, and home health services.

Develop and implement an action plan that includes sufficient policies, procedures, and controls that address households living in multifamily housing units having a sufficient supply of safe drinking water []

Status

We recommend that the New Jersey Department of Human Services (NJDHS) work with the New Jersey Department of Health to reinforce guidance to nursing facilities for ensuring potential incidents of abuse or neglect are reported in accordance with Federal and State requirements.

We recommend that the New Jersey Department of Human Services work with the New Jersey Department of Health to develop additional procedures for its survey site visits, including reviewing nursing facilities’ records related to hospital transfers for certain beneficiary injuries or conditions that could be the result of potential abuse or neglect.

The U.S. Mint Director before processing any mutilated or uncurrent redemptions should ensure the Mint strengthens and finalizes standard operating procedures for all coin exchange programs before accepting any redemptions. This would include using tests and subject matter experts to authenticate the genuineness of coins redeemed, as well as working with the Board of Governors of the Federal Reserve System to develop appropriate interagency procedures to assure the integrity of the coin redemption process for uncurrent coins.

We recommend that the Rhode Island Department of Human Services conduct or renew all required criminal background checks for the 108 individuals we reviewed who did not have all required checks or who had expired background checks at the time of our data request and site visits

We recommend that the Rhode Island Department of Human Services determine whether it is feasible to increase the ratio of State licensing inspectors to child care providers to meet industry standards so that it can review all employee criminal background checks at all child care providers

We recommend that the Rhode Island Department of Human Services require the State licensing agency to increase the number of current employees it reviews at all child care centers to ensure child care provider compliance with criminal background check requirements

We recommend that the Rhode Island Department of Human Services determine whether it is feasible to develop a centralized process to monitor both family homes and childcare centers.

Rec. A.1.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to identify and track all the DoD civilian employees who provide any support to the security assistance programs.

Rec. A.1.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to determine whether their current staff level is adequate to support their security assistance mission and request additional security assistance-funded positions, as needed.

Rec. A.1.c: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to identify and recover all security assistance-related salary expenses for each DoD civilian employee between FYs 2014 and 2019 from the Defense Security Cooperation Agency.

Rec. A.1.d: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to develop, document, and implement Component-level policies and procedures to identify, track, and recover salary expenses for DoD civilians who support security assistance programs in future years.

Rec. A.1.e: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to identify all DoD civilians who support security assistance programs full-time and ensure their positions are designated as security assistance positions within the Defense Civilian Payroll System. Employees who support security assistance programs full-time should be paid directly from the Foreign Military Sales Trust Fund.

Rec. A.1.f: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to reprogram the Defense Civilian Payroll System to allow for DoD civilian employees to be paid from multiple appropriations.

Rec. A.1.g: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to recover the security assistance-related costs from the Defense Security Cooperation Agency for changes to the Defense Civilian Payroll System necessary to correct position records and to pay personnel from multiple appropriations.

Rec. A.1.h: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to identify and recover any storage costs that they did not recover for storing security assistance assets at all DoD facilities between FYs 2014 and 2019 from the Defense Security Cooperation Agency.

Rec. A.1.i: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to develop, document, and implement Component-level policies and procedures to identify, track, and recover storage expenses for storing security assistance assets at DoD facilities in future years.

Rec. A.1.j: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to recover all operating costs that the implementing agencies did not recover for providing administrative space to security assistance personnel at all DoD facilities between FYs 2014 and 2019 from the Defense Security Cooperation Agency.

Rec. A.1.k: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to develop, document, and implement Component-level policies and procedures to identify, track, and recover all operating costs for DoD facilities used to support security assistance programs in future years. This includes identifying where employees who support security assistance programs sit at all DoD facilities.

Rec. A.1.l: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the DoD Components to perform an assessment of DoD facilities to determine whether administrative space shortages exist and can be reduced by relocating security assistance personnel to commercial lease space. The assessment should be provided to the DoD Office of Inspector General for review.

Rec. A.2.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Deputy Under Secretary of the Air Force for International Affairs to relocate security assistance personnel and necessary equipment from Wright-Patterson Air Force Base to commercial lease space. The relocation expenses and commercial lease space should be paid with Foreign Military Sales administrative funds.

Rec. A.2.d: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, track the dollar amount of costs recovered for security assistance-related administrative expenses, including salary, storage, and facility expenses.

Rec. A.2.e: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, track the dollar amount of future savings for security assistance-related administrative expenses, including salary, storage, and facility expenses.

Rec. B.1.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Deputy Assistant Secretary of the Army for Defense Exports and Cooperation to recover funds from the Defense Security Cooperation Agency in the amount equal to the current market price of the chemical-biological masks that Army personnel shipped to foreign customers.

Rec. B.1.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Deputy Assistant Secretary of the Army for Defense Exports and Cooperation to initiate an investigation to determine why the Special Defense Acquisition Fund masks were misplaced and take appropriate action in accordance with DoD Regulation 7000.14-R, "DoD Financial Management Regulation," Volume 12, "Special Accounts, Funds, and Programs," Chapter 7, "Financial Liability for Government Property Lost, Damaged, Destroyed, or Stolen."

Rec. B.2.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Under Secretary of Defense for Acquisition and Sustainment and the DoD Components to develop, document, and implement Component-level inventory management policies and procedures to prevent DoD personnel from shipping DoD assets to foreign customers, unless a valid reason exists. The procedures should include a supervisory review of all materiel release orders to foreign customers. The review should be documented and maintained in the case files.

Rec. B.2.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Under Secretary of Defense for Acquisition and Sustainment and the DoD Components to develop, document, and implement an internal control environment at DoD facilities that prevents DoD assets from being misplaced in the future.

Rec. B.2.c: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Under Secretary of Defense for Acquisition and Sustainment and the DoD Components to incorporate all security assistance assets into their inventory and property management systems. The DoD Components should be able to identify the quantity, location, and value of security assistance assets in their custody on demand when requested by management and stakeholders.

We recommend that the Nebraska Department of Health and Human Services, Division of Medicaid and Long-Term Care refund $13,157,778 to the Federal Government.

Rec. 1: The DoD OIG recommended that the Commander, Navy Region Mid-Atlantic, and Commanding Officer, Naval Station Great Lakes, in coordination with the Public Works Officer, Public Works Department Great Lakes, Naval Facilities Engineering Command, Mid-Atlantic, assess and correct the deficiencies identified in this report to ensure compliance with current Unified Facilities Criteria and National Fire Protection Association requirements.

Rec. 5.a: The DoD OIG recommended that the Commander, Navy Region Mid-Atlantic, in coordination with the Public Works Officer, Public Works Department Great Lakes, Naval Facilities Engineering Command, Mid-Atlantic, inspect building 2801 for noncompliance with current Unified Facilities Criteria 4-730-10 and incorporate corrective actions into the planned renovation project for building 2801.

Rec. 5.b: The DoD OIG recommended that the Commander, Navy Region Mid-Atlantic, in coordination with the Public Works Officer, Public Works Department Great Lakes, Naval Facilities Engineering Command, Mid-Atlantic, inspect building 2801 for noncompliance with current National Fire Protection Association requirements and take corrective actions.

We recommend the Under Secretary, Office of Strategy, Policy, and Plans, in consultation with the Under Secretary of Management, coordinate with DHS JTTF contributors to: - ensure agreements governing participation in the JTTF are binding; - evaluate whether new agreements or terms governing JTTF participation are required; and - develop guidance defining each DHS JTTF contributors' authorities, roles and responsibilities, skill sets, and access to systems.

We recommend the HSI Executive Associate Director renegotiate and update the existing 2003 MOA with DOJ on terrorism financing investigations to ensure: - all appropriate action to align guidance on handling of terrorism cases with current operations; - essential requirements defined in DHS Management Directive 0450.1 are included; and - a review and modification process is established to reflect future operational changes.

We recommend the Under Secretary, Office of Strategy, Policy, and Plans, in consultation with the Under Secretary of Management, coordinate with DOJ and State to develop an agreement that facilitates the direct sharing of passport information within the JTTF environment through State's formal MOU process.

We recommend the Under Secretary of Management coordinate with the Information Sharing and Safeguarding Governance Board to ensure: - ICE and TSA develop an agreement for TSA to directly process Secure Flight data requested for use by JTTF or HSI JTTF agents investigating terrorism activities or performing task force specific missions, and - DHS JTTF contributors mitigate data restrictions or delays pertaining to law enforcement and intelligence investigations.

We recommend that Condado Home Care Program, Inc., for the remaining portion of the estimated $97,210 in overpayments that are outside of the Medicare reopening period, exercise reasonable diligence to identify and return 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 Condado Home Care Program, 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 Condado Home Care Program, Inc. strengthen its procedures to ensure that: - the homebound status of Medicare beneficiaries are verified and continually monitored and the specific factors qualifying beneficiaries as homebound are documented; - beneficiaries are receiving only reasonable and necessary skilled services; - home health episodes are billed correctly; and - plans of care comply with Medicare requirements.

We recommend that Condado Home Care Program, Inc. refund to the Medicare program the portion of the estimated $97,210 in overpayments for claims incorrectly billed that are within the 4-year claim reopening period.

We recommend that Visionquest Industries, Inc.: refund to the DME MACs the portion of the $2,504,829 in estimated overpayments for claims that are within the 4-year reopening period.

We recommend that Visionquest Industries, Inc.: exercise reasonable diligence to identify and return any additional similar overpayments in accordance with the 60-day rule,20 and identify any of those returned overpayments as having been made in accordance with this recommendation