Open Recommendations

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to show that $156,940 paid for sales brochures, economic land analysis studies, and consultant fees was reasonable, necessary, supported, and for services that were performed in accordance with applicable requirements or reimburse any unsupported costs from non-Federal funds.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to show that $75,006 used for appraisal quality control reviews was for services that complied with applicable requirements or reimburse any unsupported costs from non-Federal funds.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to strengthen controls to ensure that future Disaster Recovery funds used for appraisal services and quality control reviews under the program are for costs that are reasonable, necessary, supported, and for services that comply with applicable requirements.

Reassess the process of isolating key project personnel from instrument selection to balance their additional insight in integration and cost estimation while maintaining fairness in the announcement and mitigating conflicts of interest risks.

Develop and implement a process for periodically assessing force account risk. Based on the risk assessment, develop and implement procedures for overseeing compliance with Federal force account regulations.

Revise force account guidance for the States to clarify when cost-effectiveness determinations are required.

Develop and implement a process for determining when force account can be used for work performed outside the Federal highway right-of-way without complying with Federal requirements.

For the estimated $2,979,377 overpayment for all claims 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

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

The Office of Programs should update all control documentation (including policies and procedures, charts of controls, and other related documentation) to reflect the changes that occurred to unapplied cash as a result of the migration to the Financial Management Integrated System.

The Office of Programs should test the updated unapplied cash controls to ensure that they are present and operating as intended.

The Office of Programs should work with the Railroad Retirement Board’s Bureau of Information Services to implement Overpayment Recovery Correspondence System modifications to ensure that unapplied cash historical files [carried over from prior years, and receipts disposed of (applied to debt)] are maintained for completeness and accountability.

The Office of Programs should work with the Bureau of Fiscal Operations to establish and implement control activities to ensure that the Overpayment Recovery Correspondence System Unapplied Cash Application is fully interfaced with the Financial Management Integrated System so that all unapplied cash transactions are properly processed and recorded in the Overpayment Recovery Correspondence System Unapplied Cash Application.

The Bureau of Fiscal Operations should update all control documentation (including policies and procedures, charts of controls, and other related documentation) to reflect the changes that occurred to unapplied cash as a result of the migration to the Financial Management Integrated System.

The Bureau of Fiscal Operations should test the updated unapplied cash controls to ensure that they are present and operating as intended.

The Bureau of Fiscal Operations should develop and implement a formal reconciliation process to ensure accountability, completeness, and accuracy of unapplied cash transactions.

Review the 1,030 terminated contingently liable records and take action to adjust benefits.

Review and take action to remove the overpayment balance from the 4,690 terminated contingently liable beneficiaries and transfer the debt balance to the original debtor for an immediate payment of the overpayment or seek recovery through additional debt collection tools.

Establish controls to remove the outstanding debt from terminated contingently liable beneficiaries and transfer the balance to the original debtor for an immediate payment of the overpayment or seek recovery through additional debt collection tools when available.

Recommendation is not publicly available.

Work with CMS to determine the unallowable portion of $7,889 (Federal share) for other claims for covered outpatient physician-administered drugs that were submitted without NDCs and that may have been ineligible for Federal reimbursement and refund that amount,

Work with CMS to determine whether the remaining $1,109,110 (Federal share) of other physician-administered drug claims could have been invoiced 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 all physician-administered drugs eligible for rebates are invoiced.

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, 2016;

Develop and implement formal written policies and procedures for its drug rebate program.

Refund to the Federal Government $7,578,002 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement;

Refund to the Federal Government $561,937 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement;

Perform quarterly reviews of eligibility system records to ensure that beneficiaries with dates of death are removed from Medi-Cal

Identify and recover unallowable payments made to MCOs during our audit period on behalf of deceased beneficiaries, which we estimated to be at least $70,989,604

We recommend that the State Agency refund $53,425,143 to the Federal Government

Revise DOT financial assistance policies to specify what officials are authorized to approve justifications for awarding financial assistance without full and open competition.

Develop and issue guidance to OAs for clearly identifying awards as R&D.

We recommend that Essence enhance its policies and procedures to detect and correct noncompliance with Federal requirements for all diagnosis codes used to calculate risk-adjusted payments.

We recommend that Essence identify, for the diagnoses included in this report, instances of noncompliance in the enrollee-years that occurred (1) during our audit period, but were not included in our judgmental sample, and (2) before and after our audit period, and refund any resulting overpayments to the Federal Government.

Determine the allowability of $518,700 in questioned costs ($27,047
ineligible and $491,653 unsupported) identified on page 25, and further detailed on pages 26-27 of the audit report, and recover any amount that is unallowable.

We recommend that Children’s Village review its claimed expenditures for FYs 2016 and 2017 (the second and third years of the grant awards) to determine whether they were claimed in accordance with Federal requirements and refund to the Federal Government any unallowable amount.

We recommend that Children’s Village determine whether resources are aligned as needed to ensure that all required documentation is maintained in UAC case files and that ORR policies and procedures are followed when releasing UAC to sponsors.

We recommend that Children’s Village take corrective action to ensure that its facility is free from potentially harmful conditions.

We recommend that Children’s Village refund to the Federal Government $2,623,785 in unallowable grant expenditures.

We recommend that Children’s Village implement financial management system procedures to ensure Federal funds are drawn down only when needed, all related obligations are paid timely, and grant funds are separately identified and segregated.

We recommend that Children’s Village ensure that all medical exams and educational assessments are documented and performed as required by ORR.

We recommend that Children’s Village ensure that costs are properly approved, allocated, and adequately supported.

We recommend that Children’s Village ensure that all employee requirements pertaining to background investigations and experience are met and documented.

We recommend that the Office of the Director ensure that the CIO has adequate involvement and approval in all phases of annual and multi-year planning, programming, budgeting, and execution decisions in line with FITARA and OMB Circular A-130 requirements.

We recommend the Bureau of Fiscal Operations develop or update, and implement comprehensive written policies and step by step procedures for all write-off and waiver processes, to include day to day operations, documentation and approvals, roles and responsibilities, and threshold requirements, to ensure consistency and compliance with applicable laws, regulations, and guidance.

We recommend the Bureau of Fiscal Operations conduct training on new policies and procedures to ensure that decision making is consistent.