Open Recommendations

3. We recommend that Alta Bates Summit 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) procedure and diagnosis codes are supported in the medical records and staff are properly trained, (3) all inpatient beneficiaries meet Medicare requirements for inpatient hospital services, (4) the use of bypass modifiers is supported in the medical records, and (5) staff are properly trained.

We recommend that the Assistant Secretary for Elementary and Secondary Education ensure that OESE strengthens its policy for creating and retaining records so those records demonstrate adequate and proper documentation of OESE’s functions, policies, decisions, procedures, and essential transactions relevant to the review and approval of the McKinney-Vento Act section of State plans.

We recommend that the Assistant Secretary for Elementary and Secondary Education ensure that OESE makes publicly available all submissions and resubmissions of States’ plans, including individual and consolidated plans, to promote full transparency.

We recommend that the Assistant Secretary for Elementary and Secondary Education ensure that OESE adheres to its policy and considers all conflict of interest information collected from peer reviewers before assigning them State plans to review.

Ensure that all case file documents are accurately timestamped to the date they are actually completed and that all staff are trained on how to properly maintain accurate and up-to-date case files

Strengthen existing procedures to ensure that family reunification packets are sent within required timeframes

Develop policies and procedures for promptly notifying DHS of the imminent release of a child to a sponsor and document and maintain all correspondence

Ensure that all employees follow policies and procedures requiring Federal and State background investigations to be completed before staff begin working with children, provide relevant training to appropriate staff, and document and maintain documentation of all results.

Implement procedures and controls for collecting and reconciling information contained in its performance reports by developing protocols for collecting required data, handling system failures, and resolving discrepancies to ensure that all performance reports are accurate, verifiable, and reviewed before release to ORR.

Work with ORR to develop allowable methodologies to allocate salaries, develop a procedure or system to capture what programs each employee actually worked on, and determine what portion of the $1,500,218 in salaries charged based on budget estimates was accurately charged to the UAC program and refund to the Federal Government any unallowable portion

Work with ORR to determine an allocation methodology or plan to claim shared direct expenditures in proportion to benefits received, develop a policy to reflect this methodology or plan, determine whether any of the $1,352,027 in direct expenditures and up to $235,253 in related indirect expenditures allocated using the unreasonable allocation ratio was allowable, and refund to the Federal Government any unallowable portion

Develop policies and procedures for identifying allowable shared UAC program costs, including items that need advance approval, determine whether any of the $210,037 in potentially unallowable and $23,390 in potentially unallowable unapproved expenditures would be allowable under the newly approved allocation methodology or plan, and refund to the Federal Government any unallowable or unapproved portion

Develop policies and procedures for identifying shared UAC program costs not in compliance with Federal requirements and refund $10,336 in unallowable employee appreciation expenditures

Develop policies and procedures for identifying direct UAC program costs not in compliance with Federal requirements and refund $6,515 in unallowable expenditures not related to the UAC program

Develop policies and procedures for claiming indirect expenditures based on the approved indirect cost rate.

Assess, confirm, and recover the previously issued improper WHIP payments of $4,268,395 to program participants.

FDA should use the new TIRF REMS patient registry to monitor for known areas of risk, such as inappropriate conversions and off-label prescribing.

FDA should strengthen the REMS for opioid analgesics (the successor to ER/LA opioids) by requiring prescriber training.

FDA should enhance its REMS assessment review process.

FDA should seek additional authority to ensure that manufacturers are held accountable when appropriate.

We recommend the FEMA Administrator establish robust transportation, supply chain, and general logistics contingency contracts to provide more timely and effective delivery of disaster support.

We recommend the FEMA Administrator develop internal controls over contract administration from initiation to closeout. These controls should: 1) ensure all contract requirements are met in accordance with the Federal Acquisition Regulation and corresponding DHS and FEMA policies and procedures; 2) ensure training needs are met by procurement personnel and appropriate approvals are obtained prior to the award or modification of contracts; and 3) ensure contract oversight officials adequately review invoices, including verifying costs, to theextent possible, based on source documentation to ensure billed costs are supported and allowed.

We recommend the FEMA Administrator Investigate FEMA’s transportation contracts in response to the Puerto Rico disaster for potential Anti-Deficiency Act violations and appropriately report the results of the review.

The Deputy Commissioner for Services and Enforcement should continue efforts to close the virtual currency information gap by issuing guidance clarifying the proper information reporting associated with virtual currency transactions.

We recommend the DHS Chief Information Officer work with the Geospatial Information Officer tocoordinate with internal and external stakeholders to ensure a commondefinition of geospatial data, including the classification of Law EnforcementSensitive Information, as it applies to the DHS mission and operatingenvironment.

CMS should ensure that all States receive training on CMS’s updated triage guidance.

CMS should identify new approaches to address those States that are consistently failing to meet the required timeframes for investigating the most serious nursing home complaints.

We recommend CBP’s Assistant Commissioner for the Office of Information and Technology implement all mitigation and policy recommendations to resolve the 2019 data breach identified in CBP’s Security Threat Assessments, including implementing USB device restrictions and applying enhanced encryption methods.

We recommend the Deputy Executive Assistant Commissioner, Office of Field Operations coordinate with the CBP Office of Information and Technology to ensure that all additional security controls are implemented on relevant devices at all existing Biometric Entry-Exit program pilot locations.

We recommend the Deputy Executive Assistant Commissioner, Office of Field Operations establish a plan for the Biometric Entry-Exit Program to routinely assess third-party equipment supporting biometric data collection to ensure partners’ compliance with Department security and privacy standards.

We recommend that the Oregon Health Authority provide additional guidance to CCOs on the processes for provider credentialing and for beneficiary grievances and appeals.

We recommend that the Oregon Health Authority provide additional guidance to CCOs on monitoring subcontractors.

We recommend that the Oregon Health Authority take actions to ensure that CCOs do not subcontract the adjudication of final appeals.

We recommend that the Oregon Health Authoritytake actions to ensure that the data that CCOs submit on grievances and appeals in the grievance workbooks are accurate and complete.

We recommend that the Connecticut Department of Social Services work with CMS to review Medicaid payments made to HPS after our audit period and refund any overpayments.

We recommend that the Connecticut Department of Social Services strengthen its oversight of the SBCH program by working with DAS to develop a detailed review process for claims submitted by the LEAs to ensure that all claims meet Federal and State requirements.

We recommend that the Connecticut Department of Social Services refund $761,179 to the Federal Government.

Implement controls, such as systems alerts and management reports, to identify beneficiaries in miscellaneous suspense status and ensure employees take corrective actions timely.

Include a Numident match in the Death Information Processing System, or similar process, to assess Online Verification System discrepancies before rejecting an Electronic Death Registration report.

We recommend that the North Carolina Department of Health and Human Services follow up with the 18 nursing homes to verify that corrective actions have been taken. regarding the life safety and emergency preparedness deficiencies identified in this report;

We recommend that the North Carolina Department of Health and Human Services work with CMS to develop life safety training for nursing home staff.

We recommend that the North Carolina Department of Health and Human Service conduct more frequent site surveys at nursing homes with a history of multiple high-risk deficiencies.

We recommend that the North Carolina Department of Health and Human Service work with LEM agencies to develop a process to monitor the submission of emergency plans.

5. We recommend that the North Carolina Department of Health and Human Services increase collaboration with LEM agencies to: clarify roles and responsibilities; make them aware of pending, or newly licensed, nursing homes in their counties; provide LEM agencies with survey results, to the extent possible, from individual nursing homes to identify specific vulnerabilities.

6. We recommend that the North Carolina Department of Health and Human Services increase collaboration with RHCs and communication with nursing home administrators to ensure nursing homes are aware of resources available to them.

We recommend that the Vermont Agency of Human Services, Department of Vermont Health Access refund to the Federal Government $357,706 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.

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.