Open Recommendations

(U) Rec. 3.a: The DoD OIG recommended that the Commander of Air Mobility Command, in conjunction with the Chief of the Air Force Reserve and the Director of the National Guard Bureau develop plans to ensure that Air Refueling Wing facilities meet Air Mobility Command Instruction 13-520 and Air Force Manual 32-1084 requirements. (ARFC)

(U) Rec. 3.a: The DoD OIG recommended that the Commander of Air Mobility Command, in conjunction with the Chief of the Air Force Reserve and the Director of the National Guard Bureau develop plans to ensure that Air Refueling Wing facilities meet Air Mobility Command Instruction 13-520 and Air Force Manual 32-1084 requirements. (NGB)

(U) Rec. 4: The DoD OIG recommended that the Deputy Chief of Staff of the Air Force for Manpower, Personnel, and Services, in conjunction with the Chief of the Air Force Reserve and the Director of the National Guard Bureau, determine the anticipated future manning levels for aircrew, security forces, and maintenance crews, and develop recruiting and retention efforts to ensure that the U.S. Strategic Command nuclear mission can be performed. (AF/A1)

(U) Rec. 4: The DoD OIG recommended that the Deputy Chief of Staff of the Air Force for Manpower, Personnel, and Services, in conjunction with the Chief of the Air Force Reserve and the Director of the National Guard Bureau, determine the anticipated future manning levels for aircrew, security forces, and maintenance crews, and develop recruiting and retention efforts to ensure that the U.S. Strategic Command nuclear mission can be performed.

We recommend that the FWS require the Commission to implement a financial management system with sufficient internal controls to provide for a reconciliation of all grant claims to actual expenditures recorded in the Commonwealth's System Analysis and Program Development (SAP) accounting system.

We recommended that the State agency consider having Complaint Intake be the initial recipient of all incident reports from nursing facilities to assist in conducting more effective and timely investigations of all aspects of an allegation within incident reports.

We recommend that the Deputy Commissioner of CBP develop and implement policies to ensure CBP's covert testing groups: a. develop risk-based annual covert test plans and identify systemic tests; b. distribute test results throughout the organization; c. make recommendations; and d. implement and track corrective actions.

We recommend that the Assistant Commissioner of Office of Intelligence and Border Patrol's Chief of Law Enforcement Operations Directorate direct covert testing entities to develop and implement both performance measures and standard operating procedures including: a. processes for determining data to be included in test reports, b. data quality monitoring, and c. supervisory review.

We recommend that the Assistant Commissioner of the Office of Intelligence direct all Operational Field Testing Division staff to review all prior and future classified reports to ensure they are properly marked to protect national security information.

Identify and recover capitation payments made on behalf of deceased beneficiaries before and after our audit period, and repay the Federal share of amounts recovered

Create system edits to help identify overpayments and failures in the automated interfaces between the eligibility, payment, and death data

Use additional sources of date of death consistently to help reduce unallowable payments

Refund $13,696,760 Federal share to the Federal Government

We recommend FEMA develop guidance, including the appropriate milestones in the grant lifecycle, for assessing costs under a T&M contract for reasonableness and eligibility.

We recommend that the New Jersey Department of Human Services continue to work with ACF to reach substantial compliance with criminal background check requirements.

We recommend that the New Jersey Department of Human Services develop a system that provides notifications to State agency staff when criminal background checks need to be conducted for prospective and current employees and household members.

Given the sensitivity of our review, this recommendation is restricted.

Direct the MACs to recover the $41,613 in identified overpayments made to HHAs for the sampled claims.

Require the MACs to perform data analysis and risk assessments of claims with visits slightly above the applicable LUPA threshold and target these claims for additional review.

Instruct the MACs to educate HHA providers on properly billing for home health services with visits slightly above the applicable LUPA threshold, which could have saved Medicare as much as $191,773,995 during our audit period.

We recommend that the Health Resources and Services Administration ensure that it follows its policy for timely responding to health centers’ requests to carry over grant funds.

We recommend that the Health Resources and Services Administration assess health centers’ progress toward meeting AIMS grant award conditions to increase personnel and patients’ access to care and follow up with appropriate corrective action, such as providing technical assistance or discontinuing or reducing future AIMS grant funds.

We recommend that the Health Resources and Services Administration review BPRs to identify health centers that did not report progress toward meeting their health IT or training goals.

We recommend that On-Site Psychological Services, P.C.refund to the Medicare program the estimated $3,373,440 overpayment.

We recommend that On-Site Psychological Services, P.C. based upon the results of this audit, exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule25 and identify any of those returned overpayments as having been made in accordance with this recommendation

Work with CMS to determine whether the remaining $300,266 ($185,066 Federal share) for claims for other physician-administered drugs could have been billed to the manufacturers to receive rebates and, if so, upon receipt of the rebates, refund the Federal share of the manufacturers’ rebates for those claims.

Strengthen its internal controls to ensure that it bills manufacturers for rebates for all physician-administered drugs that are eligible for rebates.

Work with CMS to determine the unallowable portion of $7,229 ($3,615 Federal share) for claims for other physician-administered drugs that were submitted with invalid NDCs and that may have been ineligible for Federal reimbursement and refund that amount.

Work with CMS to determine and refund the unallowable portion of Federal reimbursement for physician-administered drugs that were not billed for rebates after December 31, 2017.

We recommend that the PBM return $834,425 to the Carrier (to be credited to the FEHBP) for failing to provide pass-through pricing to the FEHBP at the full value of the PBM’s negotiated discounts with Walgreens and Rite Aid retail pharmacy claims for CYs 2014 through 2016.

We recommend that the PBM continue researching this issue and identify all other pharmacies whose full value of the negotiated discounts were not passed through to the FEHBP.

We recommend that the Carrier require the PBM to pay FEHBP pharmacy claims based on the full value of the PBM’s negotiated discounts with retail pharmacies at the time of adjudication. The guarantee found in the Agreement (between the Carrier and the PBM) should only be applied as a true-up when that guaranteed discount exceeds the pass-through transparent pricing for the period being analyzed.

We recommend that the Chief Financial Officer and Assistant Secretary for Administration update the PPMM to include guidance for OS commercial leasing. The Department should ensure other PPMM requirements do not similarly exclude OS.

We recommend that the Chief Financial Officer and Assistant Secretary for Administration update policies and procedures to include requirements for bureaus to maintain adequate documentation of vehicle usage.

We recommend that the Regional Administrator, FEMA Region IV direct the State of Florida to recover the $84,681 in unsupported and ineligible force account equipment costs from the County.

We recommend that the Regional Administrator, FEMA Region IV direct the State of Florida to require the County to either provide adequate support to validate the hours invoiced or remove the $1,080 in unsupported costs from its RFR.

Rec. 1: The DoD OIG recommended that the Office of the Under Secretary of Defense for Acquisition and Sustainment issue policy requiring all DoD biological select agents and toxins?registered laboratories to implement an internal technical and scientific peer review function that addresses both biosafety and biosecurity.

To the extent practicable, adjust the production schedules for Artemis 4 and 5 to better align with the successful demonstration of Artemis 2 to reduce schedule delays associated with potential rework.

We recommend HHS provide training to political appointees and senior leaders related to proper contract administration.

We recommend HHS determine whether any HHS contractors or subcontractors are performing inherently governmental functions and whether any active CMS service contracts or task orders are being administered as personal services contracts, and take action to correct their administration.

We recommend that the Regional Administrator, FEMA Region IV, assess the status and adequacy of FDEM's corrective actions with respect to establishing a subrecipient monitoring program and reviewing subrecipient Single Audit reports.

To address the 164 incorrectly billed hospital claims in our sample, we recommend that the Centers for Medicare & Medicaid Services: CMS notifies appropriate providers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the providers 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 the Centers for Medicare & Medicaid Services: review how hospitals are using diagnosis code E41 for nutritional marasmus and diagnosis code E43 for unspecified severe protein-calorie malnutrition and work with hospitals to ensure that they correctly bill Medicare when using severe malnutrition diagnosis codes.

To address the 164 incorrectly billed hospital claims in our sample, we recommend that the Centers for Medicare & Medicaid Services: collect the portion of the $914,128 for the incorrectly billed hospital claims that are within the reopening period.

Make a determination regarding the allowability of questioned costs identified in this report and recover those costs determined to be unallowable.

Make a determination regarding the allowability of questioned costs identified in this report and recover those costs determined to be unallowable;

We recommend that the Centers for Medicare & Medicaid Services issue guidance, such as an Informational Bulletin, to inform States that performing a data analysis to identify Medicaid claims containing one or more diagnosis codes indicating potential child abuse or neglect could help identify incidents of potential child abuse or neglect and help ensure compliance with the States’ mandatory reporting laws.

We recommend that the Centers for Medicare & Medicaid Services assess the sufficiency of existing Federal requirements to report suspected child abuse and neglect of Medicaid beneficiaries to determine whether it should strengthen those requirements or seek additional authorities to provide oversight over the reporting of suspected child abuse and neglect of Medicaid beneficiaries.

We recommend that the Texas Health and Human Services Commission implement a system to ensure that it can track complaints not closed within 10 days.

We recommend that the Texas Health and Human Services Commission implement procedures to ensure that ensure that procedures are followed to detect unreported deaths.