Open Recommendations

We recommend that Triple-S Advantage, Inc. continue to examine its existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk of being miscoded comply with Federal requirements (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

We recommend that Bridge Home Health refund the $6,046 in overpayments to the Medicare program.

We recommend that Bridge Home Health identify similar instances of noncompliance that occurred before, during, and after the audit period and determine the impact and return any overpayments to the Federal Government.

We recommend that Bridge Home Health strengthen its review of medical record documentation to ensure compleance with Medicare billing requirements.

Meet with Commission members and stakeholders to determine whether incorporating evidence-building into its next strategic planning process would assist the Commission in identifying key areas for improvement and improve outcomes to ensure a comprehensive and evidence-based approach for measuring the progress toward goals and objectives in the AbilityOne program. This determination should include, but not be limited to, meetings, information sessions, determinations of key learning areas, and how the information will be used in its next strategic planning process.

Meet with Commission members and stakeholders to determine whether incorporating internal program evaluations into its next strategic planning process would assist the Commission in better informing stakeholders about the program's impact and contributions. This determination should include, but not be limited to, meetings, information sessions, determinations of potential program evaluations, and how information from those potential evaluations will be used in its next strategic planning process.

Enhance its ability to track and monitor progress and the successful implementation of agency goals by establishing and incorporating quantitative measures into its 2026-2030 strategic plan.

Treasury Office of Inspector General (OIG) should follow-up with Massachusetts management to confirm if the $21,342 noted as unsupported expenditures within the Contracts greater than or equal to $50,000 payment type can be supported. If support is not provided, Treasury OIG should recoup the funds or request Massachusetts' management to provide support for replacement expenses, not previous charged, that were eligible during the CRF period of performance. Further, based on Massachusetts management's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace unsupported transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility…

Treasury OIG should request Massachusetts perform an assessment to determine whether there was any additional advertising and marketing costs charged to CRF within its Contracts greater than or equal to $50,000 payment type and identify those for reversal and repayment to Treasury, as applicable. If support is not provided, Treasury OIG should recoup the funds or request Massachusetts' management to provide support for replacement expenses, not previously charged, that were eligible during the CRF period of performance for the $1,500,000 of ineligible costs charged to the Contracts greater than or equal to $50,000 payment type. Based on Massachusetts management's responsiveness…

Treasury OIG should request Massachusetts management to provide support for replacement expenses, not previously charged, that were eligible during the CRF period of performance for the $25,527 of ineligible costs charged to the Contracts greater than or equal to $50,000 payment type. If support is not provided, Treasury OIG should recoup the funds. Based on Massachusetts management's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace ineligible transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for the Contracts greater than or equal to $50,000 payment types.

Treasury OIG should follow-up with Massachusetts management to confirm if the $107,824 noted as unsupported expenditures within the Transfers greater than or equal to $50,000 payment type can be supported. If support is not provided, Treasury OIG should recoup the funds or request Massachusetts' management to provide support for replacement expenses, not previous charged, that were eligible during the CRF period of performance. Further, based on Massachusetts management's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace unsupported transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit…

Treasury OIG should request Massachusetts to provide support for replacement expenses, not previously charged, that were eligible during the CRF period of performance for the $59,225 of ineligible costs charged to the Transfers greater than or equal to $50,000 payment type. If support is not provided, Treasury OIG should recoup the funds. Based on Massachusetts management's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace ineligible transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for the Transfers greater than or equal to $50,000 payment types.

Treasury OIG should request Massachusetts to provide support for replacement expenses, not previously charged, that were eligible during the CRF period of performance for the $114,940 of ineligible costs charge to the Direct Payments greater than or equal to $50,000 payment type. If support is not provided, Treasury OIG should recoup the funds. Based on Massachusetts' responsiveness to Treasury OIG's requests and Massachusetts' ability to provide sufficient documentation and/or replace ineligible transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for the Direct Payments greater than or equal to $50,000 payment type.

Treasury OIG should request Massachusetts management perform an assessment over whether there were any additional indirect costs or negotiated rates claimed within its Direct Payments greater than or equal to $50,000 and Grants greater than or equal to $50,000 payment types, and to identify those costs for repayment to Treasury, as applicable.

Treasury OIG should request Massachusetts management to provide support for replacement expenses, not previously charged, that were eligible during the CRF period of performance for the $70,625,069 of ineligible costs charge to the Aggregate Payments to Individuals payment type. If support is not provided, Treasury OIG should recoup the funds. Additionally, Treasury OIG should request that Massachusetts management perform an assessment to determine if there were any additional one-time bonus payments not related to hazardous duty included within its Aggregate Payments to Individuals claims and identify those for repayment to Treasury, as applicable. Further, based on Massachusetts management's responsiveness to…

Treasury OIG should request that Massachusetts management perform an assessment to determine if there were any additional one-time bonus payments not related to hazardous duty included within its Aggregate Payments to Individuals claims and identify those for repayment to Treasury, as applicable. Treasury OIG should request Massachusetts management to provide support for replacement expenses, not previously charged, that were eligible during the CRF period of performance for the $991 of ineligible costs charge to the Aggregate Payments to Individuals payment type. If support is not provided, Treasury OIG should recoup the funds. Based on Massachusetts management's responsiveness to Treasury OIG's…

Treasury OIG should request Massachusetts management to provide support for replacement expenses, not previously charged, that were eligible during the CRF period of performance for the $91,646,107 of fringe benefits and bonus payments ineligible costs charge to the Aggregate Payments to Individuals payment type. If support is not provided, Treasury OIG should recoup the funds. Additionally, Treasury OIG should request that Massachusetts management perform an assessment to determine if there were any additional one-time bonus payments not related to hazardous duty included within its Aggregate Payments to Individuals claims and identify those for repayment to Treasury, as applicable. Further, based…

Treasury Office of Inspector General (OIG) follow-up with Washington's management to confirm if the $14,085,335 noted as unsupported expenditures within the Grants greater than or equal to $50,000, Transfers greater than or equal to $50,000, Direct Payments greater than or equal to $50,000, and Aggregate Payments to Individuals payment types can be supported. If support is not provided, Treasury OIG should recoup the funds or request Washington management to provide support for replacement expenses, not previously charged, that were eligible during the CRF period of performance. In addition, Castro recommends that Treasury OIG request Washington management to provide support for…

Treasury OIG should follow-up with Selawik's management to confirm the transactions noted as unsupported or ineligible expenditures within the Direct Payments greater than or equal to $50,000, Aggregate Reporting less than $50,000, and Aggregate Payments to Individuals payment types are recouped or replaced by other eligible expenditures not previously charged to CRF, that were incurred during the period of performance. Based on Selawik's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation, Treasury OIG should determine the feasibility of conducting an audit for the Direct Payments greater than or equal to $50,000, Aggregate Reporting less than $50,000…

Treasury OIG should confirm if the transactions noted as unsupported expenditures within Grants greater than or equal to $50,000, Transfers greater than or equal to $50,000, Aggregate Reporting less than $50,000, and Aggregate Payments to Individuals payment can be supported. If support is not provided, Treasury OIG should recoup the funds or request that Nebraska provide support for replacement expenses, not previously charged, that were eligible during the CRF period of performance. Further, based on Nebraska's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace unsupported transactions charged to the CRF with valid expenditures, we…

We recommend the Vice President, Major Projects, develop procedures to ensure an assessment of risk is completed and Project Approval Board and/or Project Review Board approval is obtained prior to purchasing or providing pre payments for long-lead procurements.

We recommend the Vice President, Major Projects, verify emerging risks are included in the Project Risk and Contingency Tool prior to requesting any additional project funding approvals from the Project Approval Board and/or Project Review Board.

We recommend the Vice President, Major Projects, develop procedures to ensure that emerging risks are included in the Risk and Readiness Review prior the presentation to the Project Approval Board and Project Review Board.

Review the non-life-threatening health and safety and other deficiencies observed by the audit team and ensure that property owners and agents make the necessary corrections to the deficiencies as appropriate.

Determine the appropriate timeframe for when initial MORs should be completed for all properties that convert under RAD and issue updated guidance that includes a system to track the timeliness of initial MORs.

Status

HUD has not provided a draft plan for corrective action yet.

Analysis

Complete the initial MORs for RAD properties that have not had an initial MOR.

Status

HUD has not provided a draft plan for corrective action yet.

Analysis

Completing initial MORs would assist HUD in holding property owners accountable for maintaining the conditions of their properties and sufficient reserve for replacement accounts balances, which could impact property owners' ability to make needed capital repairs.

Develop and implement a plan to determine how to implement the risk-based approach to review the RAD properties that have not had subsequent MORs in more than 3 years and to require periodic MORs going forward.

Status

HUD has not provided a draft plan for corrective action yet.

Analysis

Developing a plan to implement the risk-based approach would establish the criteria for identifying properties that are at a higher risk of noncompliance.

Provide training to field staff members to ensure that they have the skills necessary to complete MORs of converted properties.

Review the reserve for replacement account balances for the 13 properties (11 underfunded and 2 overfunded) to determine whether the balances are maintained in accordance with the applicable HUD requirements and executed HUD business documents and require owners to fully fund any underfunded reserves and determine whether any overfunded accounts should have the deposits suspended for a specified period.

Review the HUD business documents, such as the RAD conversion commitment, HAP contract, and regulatory agreement, for the four properties that did not contain consistent reserve for replacement information and update the documents to be consistent as appropriate.

Issue guidance to RAD property owners clarifying that the owner is responsible to follow both the HUD business documents and the property's business documents and that the most restrictive document indicates the amount and timing of the annual deposits into the reserve for replacement account.

Develop and implement a process to ensure that the reserve for replacement requirements in HUD's business documents are consistent for all converted properties.

Develop and implement a plan to review the reserve for replacement accounts for all converted properties from the date on which the account was established to the date of the review. Based on the reviews completed, HUD should take appropriate actions to ensure that reserve for replacement accounts are appropriately funded or determine whether overfunded accounts should have the deposits suspended for a specified period.

Implement adequate procedures and controls to ensure that servicing lenders comply with HUD time requirements in scheduling initial inspections of FHA-insured RAD PBV properties.

Determine an appropriate timeframe in which non-FHA-insured PBRA properties converted under RAD should be initially inspected, work with REAC to ensure that inspections are ordered and completed within that timeframe, and update HUD's publicly available and internal guidance to ensure consistent messaging in accordance with HUD's determination.

Status

HUD has not provided a draft plan for corrective action yet.

Analysis

The Under Secretary for Health ensures that required suicide risk and intervention training includes suicide risk identification screening and evaluation requirements, procedures, and instruction.

The Under Secretary for Health considers establishing benchmarks for suicide risk screening and evaluation that reflect the clinical importance of suicide risk identification requirements and takes action as warranted.

The Under Secretary for Health ensures monitoring of adherence to suicide risk identification screening and evaluation setting-specific requirements.

The Under Secretary for Health ensures actions taken to address barriers to completing suicide risk screening and evaluation are effective to increase adherence to annual and setting-specific requirements in all clinical settings.

The Under Secretary for Health ensures non-mental health clinical specialty leaders are aware of and adherent to the suicide risk identification screening and evaluation requirements.

We recommend the Director of the Office of Workers’ Compensation Programs develop policies and procedures for the monthly quality control review, provide training to the control operators, and monitor that the reviews are performed in accordance with such policies and procedures.

We recommend the Deputy Chief Financial Officer develop policies and procedures to ensure all non-GAAP policies are identified and reported to the Division of Financial Reporting timely.

We recommend the Director of the Division of Federal Employees’, Longshore and Harbor Workers’ Compensation design and implement monitoring procedures to periodically review control activities for effectiveness and develop action steps as appropriate based on such results.

We recommend the Assistant Secretary for ETA design and implement monitoring controls to ensure Federal Project Officer responses are obtained and reviewed for all delinquent cost reports.

We recommend the Assistant Secretary for ETA design and implement monitoring controls to enforce current policies and procedures for Federal Project Officers to timely review cost reports.

We recommend the Acting Chief Information Officer perform an analysis of the other operating system servers within the U.S. Department of Labor environment to determine if other servers were incorrectly configured.

We recommend the Acting Chief Information Officer implement the proper configurations for the impacted operating system servers.

We recommend the Acting Chief Information Officer configure the systems to adhere to the password requirements from the U.S. Department of Labor Cybersecurity Policy Portfolio.

We recommend the Acting Chief Information Officer implement monitoring controls to periodically assess security configurations in the systems to determine adherence to the U.S. Department of Labor Cybersecurity Policy Portfolio.

We recommend the Assistance Secretary for Administrations and Management and the Acting Chief Information Officer perform risk assessments in order to design and implement procedures for effective internal communication over access provisioning controls.