Open Recommendations

With the assistance of the Scientific Integrity Committee, finalize and release the procedures for addressing and resolving allegations of a violation of the Scientific Integrity Policy, and incorporate the procedures into scientific integrity outreach and training materials.

With the assistance of the Scientific Integrity Committee, develop and implement a process specifically to address and resolve allegations of Scientific Integrity Policy violations involving highprofile issues or senior officials, and specify when this process should be used.

The Acquisition Program Management Assistant Administrator to develop an effective monitoring strategy and implementation plan, including necessary policies and procedures for ensuring probability of detection through defined continued monitoring and assessment of the deployed AIT system.

We recommend that Retirement Services develop and implement additional cost effective corrective actions, aimed at the root cause(s) of improper payments, to further reduce the improper payments rate.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Texas to require Houston to return to the Restart grant $34,065 in personnel expenditures that it charged for four teachers whose extra duty work was not for the purposes of the grant.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Texas to review a random, statistically valid sample of the remaining payroll expenditures for teachers whose extra duty pay Houston charged to the Restart grant, determine whether the personnel expenditures were allowable under the grant, and require Houston to return funds to the grant for unallowable costs

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Texas to provide additional guidance to ESCs providing equitable services and assistance to nonpublic schools that specifies how to handle items purchased by nonpublic schools using Federal funds. The instructions should ensure that the appropriate public agency holds the title to materials and equipment.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Texas to verify transfer of the title for the materials and equipment purchased by the Region 4 ESC on behalf of nonpublic schools using Restart program funds or require the ESC to return funds to the grant for unallowable costs.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Texas to review the other ESCs that are providing equitable services and assistance to nonpublic schools to ensure that the ESCs have maintained control and ownership to materials and equipment purchased using Restart program funds.

We recommend that HHS 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 these new requirements.

We recommend that HHS continue to work with OMB and other stakeholders to develop and implement an approach to reporting on TANF improper payments in FY 2020.

We recommend that HHS 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 these new requirements.

We recommend that HHS continue to explore alternative vehicles to conduct recovery audits that will fit into the larger Medicare Part C

We recommend that HHS develop and publish corrective action plans after implementing an approach.  HHS continue to focus on developing and implementing an approach to reporting on TANF improper payments, as this process will aid in identifying root causes of TANF improper payments.

Determine the allowability of the questioned transactions and recover $2,227,535, if applicable.

We recommended that CMS direct the MACs to based upon the results of this audit, notify the appropriate providers 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 recommended that CMS direct the MACs to educate outpatient providers on how to correctly bill nonphysician outpatient services provided within 3 days before the date of admission, on the date of admission, or during IPPS stays.

We recommended that CMS ensure that all necessary information is included in the CWF edits to accurately identify and prevent incorrect payments for nonphysician outpatient services provided within 3 days before the date of admission, on the date of admission, or during IPPS stay.

We recommended that CMS direct the Medicare contractors to recover the portion of $11.7 million in identified overpayments (for claims within the 4-year reopening period) resulting from the 40,984 incorrectly billed services and instruct the outpatient providers to refund the portion of the $2,785,607 in deductible and coinsurance amounts (for claims within the 4-year reopening period) that may have been incorrectly collected from beneficiaries or from someone on their behalf.

Rec. 1: The DoD OIG recommended that the Under Secretary of Defense for Acquisition and Sustainment and the Under Secretary of Defense for Personnel and Readiness collaboratively establish or revise appropriate DoD policy(s) to address health and safety hazards-including lead'based paint, asbestos'containing material, radon, fire and electrical safety, drinking water quality, window fall prevention, mold, carbon monoxide, and pest management-in military family housing to manage health, safety, and environmental risks to acceptable levels for military family housing residents.

Rec. 1: The DoD OIG recommended that the Under Secretary of Defense for Acquisition and Sustainment and the Under Secretary of Defense for Personnel and Readiness collaboratively establish or revise appropriate DoD policy(s) to address health and safety hazards-including lead'based paint, asbestos'containing material, radon, fire and electrical safety, drinking water quality, window fall prevention, mold, carbon monoxide, and pest management-in military family housing to manage health, safety, and environmental risks to acceptable levels for military family housing residents.

Rec. 2.a: The DoD OIG recommended that the Office of the Assistant Secretary of the Army for Installations, Energy and Environment update Service policies to align with revisions to DoD policy for health and safety hazard management

Rec. 2.c: The DoD OIG recommended that the Office of the Assistant Secretary of the Army for Installations, Energy and Environment direct installation officials to correct the specific lead-based paint, asbestos-containing material, radon, and fire safety health and safety hazard management deficiencies discussed in this report.

Rec. 3.a: The DoD OIG recommended that the Office of the Assistant Secretary of the Navy for Energy, Installations and Environment (on behalf of the U.S. Navy and U.S. Marine Corps) update Service policies to align with revisions to DoD policy for health and safety hazard management.

Rec. 3.c: The DoD OIG recommended that the Office of the Assistant Secretary of the Navy for Energy, Installations and Environment (on behalf of the U.S. Navy and U.S. Marine Corps) direct installation officials to correct the specific lead-based paint, asbestos-containing material, and radon health and safety hazard management deficiencies discussed in this report.

Rec. 4.a: The DoD OIG recommended that the Office of the Assistant Secretary of the Air Force for Installations, Environment and Energy update Service policies to align with revisions to DoD policy for health and safety hazard management.

ASPR should clarify to HPP awardees the flexibility available in meeting Cooperative Agreement requirements.

ASPR should continue to work with CMS to help health care entities comply with the CMS emergency preparedness CoPs.

ASPR should clarify HPP guidance that HCCs’ membership should ensure strategic, comprehensive coverage of their communities’ gaps in preparedness and response.

ASPR should identify ways to incentivize core member participation in HCCs.

We recommend the FWS develop and implement an action plan to require States that have not reconciled their records of lands purchased with Program funds for more than 5 years to do so by a specific date.

We recommend the FWS establish and implement controls and timelines to ensure real property records are reconciled in a timely manner.

We recommend that the Centers for Medicare & Medicaid Services increase the number of postpayment reviews of IPF claims to provide IPFs with more feedback on their compliance with Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services reassess the current CMS reimbursement policy for administrative necessary days that meet inpatient coverage requirements because the beneficiary has not met his or her discharge requirements to determine payment accuracy and effects on beneficiaries.

We recommend that the Centers for Medicare & Medicaid Services promulgate regulations to require that each IPF should have a policy compliant with State law to protect and promote the patient’s right to make informed decisions that includes standards for documenting the patient’s ability to make informed decisions.

We recommend that the Centers for Medicare & Medicaid Services research whether the physician certification and recertification requirements are useful in preventing inappropriate payments and: - if they are useful, continue to enforce them but - if they are not useful, take the steps necessary to eliminate or amend those requirements.

We recommend that the Centers for Medicare & Medicaid Services, while the certification requirements remain in place, revise regulations or guidance to IPFs to require that physician certifications and recertifications be in a specific form, format, or language.

We recommend that the Centers for Medicare & Medicaid Services determine whether patient in-hospital fall rates should be added to the IPFQR program and whether CMS should require present-on-admission indicators on claims as an aid to tracking in-hospital falls.

We recommend that Residential Home Health for the estimated $2,068,902 overpayment for claims that are outside of the Medicare reopening period, exercise reasonable diligence in identifying and returning 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 Residential Home Health exercise reasonable diligence to identify and return any additional similar overpayments outside of our audit period, in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.

We recommend that Residential Home Health strengthen its procedures to ensure that the homebound statuses of Medicare beneficiaries are verified and continually monitored and the specific factors qualifying beneficiaries as homebound are documented and beneficiaries are receiving only reasonable and necessary skilled services.

We recommend the Regional Administrator, FEMA Region II, provide training and technical assistance to COR3 on: - its roles and responsibilities as the PA grant recipient; - how to provide technical assistance to the subrecipient regarding PA grant requirements; and, - how to provide technical assistance to the subrecipient regarding its ability to use Category Z, Direct Administrative Cost, to support its recovery operation.

We recommend the Commission to ensure the Commission’s Agreements are harmonized with compliance enforcement protocol to ensure they are capable of meeting the regulatory requirements of the Agreements by the Commission and CNAs

We recommend New York State Department of Health work with CMS to determine whether the other pharmacy and physician-administered drugs were eligible for rebates and, if so, upon receipt of the rebates, refund up to an estimated $3,039,473 (Federal share) of rebates collected.

We recommend New York State Department of Health strengthen its internal controls to ensure that all pharmacy and physician-administered drugs eligible for rebates are invoiced.

We recommend that New York State Department of Health bill for and collect from manufacturers rebates for single-source and top-20 multiple-source pharmacy and physician-administered drugs and refund the estimated $7,846,147 (Federal share).

We recommend that the Iowa Department of Human Services, Iowa Medicaid Enterprise revise the State plan to define the documentation requirements that health home providers must follow to bill and receive IHH PMPM payments for outreach services, and educate providers on these requirements.

We recommend that the Iowa Department of Human Services, Iowa Medicaid Enterprise refund $37,132,109 to the Federal Government.

We recommend that the Iowa Department of Human Services, Iowa Medicaid Enterprise improve its monitoring of the health home program to ensure that health home providers comply with Federal and State requirements for maintaining documentation to support the services for which the providers billed and received PMPM payments.