Open Recommendations

We recommend that Saint Francis Health Center for the remaining portion of the estimated $5,533,169 overpayment for claims 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 Saint Francis Health Center 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.

(U) Rec. A.3.b: Recommendation is Classified.

(U) Rec. A.6: The DoD OIG recommended that the Commander of U.S. Strategic Command and the Under Secretary of Defense for Research and Engineering develop and implement a plan to conduct independent evaluations of supply chain risk management for nuclear command, control, and communications systems. The plan should outline responsibilities for conducting the evaluations, criteria and methodology that will be used, and timeframes for conducting the evaluations.

(U) Rec. A.7.c: The DoD OIG recommended that the Under Secretary of Defense for Research and Engineering, in coordination with the Under Secretary of Defense for Acquisition and Sustainment and the DoD Chief Information Officer, establish performance measures to assess the effectiveness of the Joint Federated Assurance Center in assisting program offices with supply chain risk management practices.

We recommend that the Centers for Medicare & Medicaid Services correct the bona fide needs obligation violations totaling $164,606,982 ($155,866,794 related to the Federal marketplace) and, if CMS is unable to correct those violations, report the Antideficiency Act violations

We recommend that the Centers for Medicare & Medicaid Services correct the bona fide needs expenditure violations totaling $22,386,227 ($18,269,216 related to the Federal marketplace) and, if CMS is unable to correct those violations, report the Antideficiency Act violations

We recommend the Office of Response and Recovery, Associate Administrator take steps to maintain a complete set of supporting documentation, including invoices and bills of lading to support all of its MHU and TPS assets. FEMA should also align its recordkeeping with Office of Management and Budget Circular A-123 and the Federal Acquisition Regulation by establishing documentation processes that include audit trails and specific document retention periods.

We recommend that CHI St. Vincent Infirmary amend the 33 claims (10 incorrectly amended and 23 not amended) to identify and return any improper outlier payments that are within the 4-year claims reopening period

We recommend that CHI St. Vincent Infirmary exercise reasonable diligence to identify and return any additional similar overpayments (including overpayments received during our audit period for the remaining $1,072,249 in outlier payments that we did not review and 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 CHI St. Vincent Infirmary return the $362,999 in improper outlier payments for the 70 claims that have been amended correctly.

We recommend that CHI St. Vincent Infirmary improve procedures and provide education to ensure claims billed to Medicare are accurate.

Rec. 1.b: The DoD OIG recommended that the Secretary of the Navy take prompt action to require the Navy Security Forces to establish management oversight procedures to verify fingerprints and final disposition reports were submitted to the Federal Bureau of Investigation Criminal Justice Information Services Division.

Rec. 3.b: The DoD OIG recommended that the Secretary of Navy take prompt action to establish policy, processes, training, and management oversight procedures for Navy Security Forces personnel to collect and submit Deoxyribonucleic Acid samples to the U.S. Army Criminal Investigation Laboratory for entry into the Federal Bureau of Investigation Combined Deoxyribonucleic Acid Index System as required by DoD Instruction 5505.14.

Rec. 8: The DoD OIG recommended that the Secretary of the Navy revise Secretary of the Navy Instruction 5800.14A to require the DD Form 2791 be provided to the Naval Criminal Investigative Service and the U.S. Marshals Service National Sex Offender Targeting Center as required by DoD Instruction 5525.20.

We recommend that the New York State Department of Health refund $11,257,368 to the Federal Government

We recommend that the New York State Department of Health identify and recover improper managed care payments made to different MCOs on behalf of beneficiaries with multiple Medicaid ID numbers prior to and after our audit period, and repay the Federal share of the amounts recovered

We recommend that the New York State Department of Health strengthen its procedures for determining whether an individual applying for Medicaid has already been assigned a Medicaid ID number by ensuring that: - its system queries identify all individuals with existing Medicaid ID numbers and - local district and Marketplace staff follow guidance on identifying individuals with Medicaid ID numbers and use all available resources to identify and prevent the issuance of multiple Medicaid ID numbers to the same individual.

We recommend that the New York Department of Health refund to the Federal Government $146,672 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.

We recommended that the New York Department of Health work with CMS to determine the unallowable portion of $2,340,390 (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, and whether the remaining $714,777 (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.

We recommend that the New York Department of Health refund to the Federal Government $3,197,404 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement

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

Rec. 1.a: The DoD OIG recommended that the DoD Office of Small Business Programs Director conduct a review, in coordination with the Military Departments and Defense agencies, of all 17 contractors that received DoD Service-Disabled Veteran-Owned Small Business set-aside or sole-source contracts but were denied Service-Disabled Veteran-Owned Small Business status by the Department of Veterans Affairs Center for Verification and Evaluation to determine if they meet the requirements for Service-Disabled Veteran-Owned Small Business status. Based on the review, the Director should take action, as appropriate, against any contractors found to have misrepresented their Service-Disabled Veteran-Owned Small Business status to the…

Rec. 1.b: The DoD OIG recommended that the DoD Office of Small Business Programs Director conduct a review, in coordination with the Military Departments and Defense agencies, of all 16 contractors in our sample that received DoD Service-Disabled Veteran-Owned Small Business contracts that we determined to be ineligible Service-Disabled Veteran-Owned Small Businesses to determine if they meet the eligibility requirements. Based on the review, the Director should take action, as appropriate, against any contractors found to have misrepresented their Service-Disabled Veteran-Owned Small Business status to the DoD to obtain set-aside and sole-source contracts by coordinating with the applicable contracting officer…

Rec. 1.f: The DoD OIG recommended that the DoD Office of Small Business Programs Director implement procedures, in coordination with Defense Pricing and Contracting, requiring contracting personnel to track and monitor the amounts Service-Disabled Veteran-Owned Small Businesses spend on subcontractors that are not Service-Disabled Veteran-Owned Small Businesses throughout contract performance to ensure that contractors do not exceed the required limitations, as defined by the Code of Federal Regulations.

We recommend the Acting Director, U.S. Immigration and Customs Enforcement, conduct an independent workforce analysis to determine whether centralizing research of aliens and issuing detainers at the Pacific Enforcement Response Center would be more efficient than performing these tasks there as well as at local research centers.

We recommend that the Michigan Department of Health and Human Services refund $27,545,800 to the Federal Government

We recommend that the Michigan Department of Health and Human Services identify capitation payments made on behalf of deceased beneficiaries before and after our audit period and repay the Federal share of amounts recovered

We recommend that the Michigan Department of Health and Human Services identify and recover unallowable payments made to managed care entities during our audit period on behalf of deceased beneficiaries, which we estimate to be at least $39,873,514

Ensure that the Senior Federal Law Enforcement Official cadre participates in National Level Exercises, when applicable, and ESF-13 Table Top Exercises.

Develop and implement guidance on how to evaluate air carrier safety risk assessments to ensure the carrier has performed a comprehensive analysis, identified root causes, and established appropriate corrective actions.

We recommend that Opportunities for Williamson and Burnet Counties implement procedures designed to ensure that Federal funds are drawn down only in the amounts needed to meet the immediate cash requirements of its CSBG and LIHEAP-related activities.

We recommend that Opportunities for Williamson and Burnet Counties work with CAS to either be released from the existing indirect cost rate or negotiate a current indirect cost rate for claiming future indirect costs.

We recommend that Opportunities for Williamson and Burnet Counties train employees to follow existing policies and procedures for approval of expenses.

We recommend that Opportunities for Williamson and Burnet Counties instruct and train its finance employees to use the grant year program code built into the accounting software to identify revenues and expenses by specific grant year for all Head Start, CSBG, and LIHEAP general ledger transactions.

We recommend that Opportunities for Williamson and Burnet Counties refund $3,207 in unallowable costs.

We recommend that Opportunities for Williamson and Burnet Counties develop and implement a reasonable basis to allocate meal costs, kitchen salaries, and central office expenses between the Head Start and Senior Nutrition programs in accordance with the benefits received.

Although the Federal marketplace properly determined most individuals’ eligibility for insurance affordability programs, to address the specific deficiencies that we identified, we recommend that the Centers for Medicare & Medicaid Services take steps to ensure that the Federal marketplace corrects an error in its eligibility and enrollment system so that information on whether an individual met the 5 year bar does not automatically carry over from a previous coverage year.

Although the Federal marketplace properly determined most individuals’ eligibility for insurance affordability programs, to address the specific deficiencies that we identified, we recommend that the Centers for Medicare & Medicaid Services take steps to ensure that the Federal marketplace establishes guidance to exclude income from other gains on a Federal tax return submitted by an individual when resolving an income inconsistency.

Although the Federal marketplace properly determined most individuals’ eligibility for insurance affordability programs, to address the specific deficiencies that we identified, we recommend that the Centers for Medicare & Medicaid Services take steps to ensure that the Federal marketplace revises its written guidance so that it does not extend an individual’s inconsistency period when the marketplace receives returned mail.

To improve procedures related to verifying whether individuals complied with the requirement to file a Federal tax return and reconcile APTC payments, we recommend that the Centers for Medicare & Medicaid Services ensure that the Federal marketplace’s eligibility and enrollment system performs subsequent FTR verifications for an individual who received an FTR indicator for a tax-filing extension.

To improve procedures related to verifying whether individuals complied with the requirement to file a Federal tax return and reconcile APTC payments, we recommend that the Centers for Medicare & Medicaid Services require an individual to submit supporting documentation (e.g., a Federal tax return with IRS Form 8962) when he or she attests to having filed a tax return to reconcile a previous year’s APTC payments.

Although the Federal marketplace properly determined most individuals’ eligibility for insurance affordability programs, to address the specific deficiencies that we identified, we recommend that the Centers for Medicare & Medicaid Services take steps to ensure that the Federal marketplace corrects an error in its eligibility and enrollment system so that the system does not incorrectly show that an individual is no longer enrolled in a QHP.

Although the Federal marketplace properly determined most individuals’ eligibility for insurance affordability programs, to address the specific deficiencies that we identified, we recommend that the Centers for Medicare & Medicaid Services redetermine, if necessary, the eligibility of the eight sampled individuals for whom eligibility for insurance affordability programs was not or may not have been determined in accordance with Federal requirements.

Although the Federal marketplace properly determined most individuals’ eligibility for insurance affordability programs, to address the specific deficiencies that we identified, we recommend that the Centers for Medicare & Medicaid Services take steps to ensure that the Federal marketplace implements a change in its eligibility and enrollment system so that the system maintains data showing that verifications of minimum essential coverage through non-ESI were performed, even if responses were not received from some of the electronic data sources.

Although the Federal marketplace properly determined most individuals’ eligibility for insurance affordability programs, to address the specific deficiencies that we identified, we recommend that the Centers for Medicare & Medicaid Services take steps to ensure that the Federal marketplace corrects an error in its eligibility and enrollment system so that the marketplace generates an inconsistency when an individual’s attested information related to eligibility for minimum essential coverage through ESI is not completed.

The Assistant Secretary for Management should ensure that the Office of the Deputy Assistant Secretary for Human Resources and Chief Human Capital Officer (DASHR/CHCO) and the Office of Executive Resources (OER) calculate the overpayment amounts for the two Departmental Office (DO) Senior Executive Service (SES) members whose pay was set higher than allowed by regulation.

We recommend that the New York State Department of Health refund $39,329,059 to the Federal Government.