Open Recommendations

5. We recommend that the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office direct the Commissioner for Trademarks to formalize a methodology for estimating and validating efficiency gains in the trademark production model.

6. We recommend the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office direct the Commissioner for Trademarks to develop and implement a Trademarks workforce action plan that includes strategies to address challenges in recruitment and retention, milestones, roles of key organization components, measures of success, and a process to continuously assess and revise the plan.

We recommend that the Massachusetts Department of Public Health follow up with the two ICF/IIDs to verify that they have taken corrective actions on the life safety and emergency preparedness deficiencies identified during the audit.

We recommend that the Massachusetts Department of Public Health work with CMS to develop standardized life safety training for ICF/IID staff.

We recommend that the California Department of Aging refund the estimated $1,087,459 of CARES Act funds that were not in compliance with Federal and State requirements.

We recommend that the California Department of Aging work with ACL to determine the allowability of the estimated $2,484,631 in local service provider expenses and refund any amount determined to be unallowable.

We recommend that the California Department of Aging clarify in the Standard Agreement that AAAs review local service provider expenses to ensure they are documented and supported.

We recommend that the California Department of Aging update procedures to include approving advanced payments as close as administratively feasible to when the AAAs will expend the funds.

Update and formalize the Agency's standard operating procedures for collecting, processing, and disseminating airline on-time performance data and make sure that these procedures are disseminated internally and available to all relevant staff.

Conduct an assessment of whether the BTS Data Administrator position and any other position should be designated as mission critical.

Develop succession plans for any mission-critical positions.

Develop and implement a process to verify that carriers are reporting on-time performance data for all flights.

Evaluate the Agency's technical directives to identify areas where it could provide clarifying or additional guidance to promote consistency in the data reported by carriers.

Work with FAA to understand no-matches in the National Airspace System (NAS) delay data between BTS' Airline Service Quality Performance (ASQP) and FAA's Aviation System Performance Metrics (ASPM) databases; and improve the consistency of air-carrier reported NAS delay data by providing additional carrier guidance as applicable.

Develop and implement a process to assess the consistency across air carriers' reporting of causes of delay data.

Castro recommends Treasury OIG follow-up with Baltimore County's management to confirm the transactions noted as unsupported expenditures of $620,189 within Aggregate Reporting less than $50,000 are recouped or replaced by other eligible expenditures, not previously charged to CRF, that were incurred during the period of performance. Based on Baltimore County's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation, Castro recommends that Treasury OIG determine the feasibility of conducting an audit for Aggregate Reporting less than $50,000.

Treasury OIG should confirm the transactions noted as unsupported expenditures within the Transfers greater than or equal to $50,000 and Aggregate Payments to Individuals are recouped or replaced by other eligible expenditures, not previously charged to CRF, that were incurred during the period of performance. Further, based on the State of North Carolina's responsiveness to Treasury OIG's requests and its ability to provide documentation, Treasury OIG should determine if a focused audit is feasible for Transfers greater than or equal to $50,000 and Aggregate Payments to Individuals. Additionally, Treasury OIG should 1) Determine the feasibility of performing additional follow-up with…

The Deputy Commissioner should establish a Service-wide process where representatives from key functional areas including CFAM, RAAS and Accounts Management officials are responsible for expeditiously reviewing and addressing emerging/ongoing fraud schemes where advanced analytics and matching to IRS sourced information proactively identifies a scam.

We recommend that USAID/Zimbabwe determine the allowability of $19,152 in ineligible questioned costs on pages 12 and 14 of the audit report and recover any amount that is unallowable.

We recommend that USAID/Zimbabwe verify that Hospice and Palliative Care Association of Zimbabwe corrects the two instances of material noncompliance detailed on pages 27 to 30 of the audit report.

We recommend that USAID/Zimbabwe verify that Hospice and Palliative Care Association of Zimbabwe provides Union Zimbabwe Trust with a copy of the audit report for their review to determine the allowability of $2,995 in ineligible and $3,100 in unsupported questioned costs identified on page 14 related to the subaward and recover the amounts determined to be unallowable.

We recommend that USAID/Rwanda verify that Young Women Christian Association of Rwanda corrects the one instance of material noncompliance detailed on page 25 of the audit report.

USAID/Philippines determine the allowability of $303,925 in questioned costs, ($1,467 of ineligible costs and $302,458 of unsupported) on pages 30 to 63 of the audit report and recover any amount that is unallowable.

USAID/Philippines verify that ADMU corrects the 8 material weaknesses in internal control detailed on pages 30 to 44 of the audit report.

USAID/Philippines verify that ADMU corrects the 5 instances of material noncompliance detailed on pages 32 to 33, and 36 to 44 of the audit report.

CMS should impose additional restrictions on the use of diagnoses reported only on in-home HRAs or chart reviews that are linked to in-home HRAs for risk-adjusted payments. While there are general requirements and oversight in place for the MA risk adjustment payment.

CMS should conduct audits to validate diagnoses reported only on in-home HRAs and HRA-linked chart reviews.

CMS should determine whether select HCCs that drove payments from in-home HRAs and HRA-linked chart reviews may be more susceptible to misuse among MA companies.

We recommend that BIE require Havasupai Elementary School to develop and implement a plan to monitor the resolution and correction of identified deficiencies in accordance with abatement plan timelines.

We recommend that BIE require Havasupai Elementary School to implement staff training on the emergency management program as required by Indian Affairs policy.

We recommend that BIE assist Havasupai Elementary School with reviewing and analyzing all work orders in the facility management system related to the school and update work order status as needed to ensure an accurate facility management database.

We recommend that BIE require Havasupai Elementary School to develop and implement a plan to repair the other safety and health concerns identified in this report related to the heating, ventilation, and air conditioning and roof conditions, as well as institute an injury reporting system.

We recommend that BIE require Havasupai Elementary School to complete a memorandum of understanding with local emergency organizations as required by Indian Affairs policy.

We recommend that BIE require Havasupai Elementary School to implement fire safety procedures, track all required fire equipment maintenance, and train all staff on the use of fire extinguishers and other related fire safety equipment as required by the National Fire Protection Association and Federal regulations.

We recommend that BIE require Havasupai Elementary School to develop and implement a security plan as required by DOI policy.

We recommend that BIE expand its annual safety and health inspection guidance to include security requirements and measures.

We recommend that BIE require Havasupai Elementary School to until a dedicated maintenance worker is hired, ensure designated staff are trained to update the work orders.

We recommend that USAID's Office of Acquisition and Assistance Cost, Audit and Support Division/Contract Audit Management Branch verify that Crown Agents USA, Inc., corrects the three material
weaknesses in internal control detailed on pages 9 to 13 of the audit report.

We recommend that the Millennium Challenge Corporation verify that MCA-Nepal corrects the two instances of material noncompliance detailed on pages 65 to 68 of the audit report.

We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to adjust or delete PDEs, as necessary, and determine the impact to the Federal Government related to the Medicare Part D total costs of $953,370 for drugs associated with our sample items for which payment was available under the Medicare Part A SNF benefit, which included $541,652 for drugs that were administered during Part D enrollees' Part A SNF stays.

We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to adjust or delete PDEs, as necessary, and determine the impact to the Federal Government related to the Medicare Part D total costs of $953,370 for drugs associated with our sample items for which payment was available under the Medicare Part A SNF benefit, which included $541,652 for drugs that were administered during Part D enrollees' Part A SNF stays.

We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to identify similar instances of noncompliance that occurred during our audit period and determine the impact to the Federal Government, which could have amounted up to an estimated $465,077,908 in Part D total cost, including $245,365,324 for drugs that were administered during enrollees' Part A SNF stays.

We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to identify similar instances of noncompliance that occurred before and after our audit period and determine the impact to the Federal Government related to Part D total costs for drugs for which payment was available under the Medicare Part A SNF benefit.

We recommend that the Centers for Medicare & Medicaid Services provide plan sponsors with timely and accurate information, such as dates of covered Part A SNF stays, to reduce instances of inappropriate Part D payment for drugs for which payment is available under the Part A SNF benefit.

We recommend that the Centers for Medicare & Medicaid Services instruct SNFs to cooperate with plan sponsors to identify and prevent improper Part D payments for drugs for which payment was available under the Part A SNF benefit.

We recommend that USAID/Zimbabwe verify that Centre for Sexual Health and HIV/AIDS Research Zimbabwe corrects the one instance of material noncompliance detailed on page 21 of the audit report.

We recommend that USAID/Tanzania verify that Evangelical Lutheran Church in Tanzania corrects the one instance of material noncompliance detailed on pages 39 to 40 of the audit report.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Diplomatic Security, reevaluate the Vehicle Allocation Methodology and update the criticality scoring system to eliminate the retention bias toward armored vehicles located in high-threat environments. This evaluation should consider the relative weight of each factor within the criticality score and consider requiring justifications for the retention of low-usage, high-criticality vehicles to achieve a balanced score.

OIG recommends that the Bureau of Diplomatic Security develop and implement guidance requiring overseas posts to periodically assess the volume of special protective equipment and hazardous materials. The guidance should take into consideration usage rates and the criticality of each asset in order to determine the appropriate quantities needed for post operations and provide instructions for adjusting asset holdings based on the outcomes of the assessment.

OIG recommends that the Bureau of Diplomatic Security update the Foreign Affairs Handbook to include a requirement that posts develop and maintain written disposition plans, including emergency destruction plans, for all special protective equipment, hazardous materials, and armored vehicles.