Open Recommendations

We recommend that CVS Health identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before or after our audit period and refund any resulting overpayments to the Federal Government.

We recommend that CVS Health continue its examination of its existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk for 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 the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Obtain a revised ARP EANS application from the 73 nonpublic schools thatused proportionality data (in whole or in part) to estimate its low-income student count and ensure that the schoolsinclude a revised low-income student count that is based on a proper data source. FDOE should use the revised countsto reassess the eligibility of the 73 schools and any EANS funds used to provide services to ineligible nonpublic schoolsmust be reverted to Florida’s Governor to be used for…

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Formally document its expenditure review and approval procedures to guideFDOE personnel through the expenditure review and approval processes. The procedures should be designed to ensurecompliance with applicable requirements, including those pertaining to EANS in both CRRSA and ARP EANS as well asthe regulations at 2 C.F.R. Part 200 (Uniform Guidance).

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Retroactively obtain prior written approval from the Department for the 5equipment expenditures or return the $187,660 expended for those equipment purchases and perform a review of theremaining equipment expenditures to determine whether there are additional purchases that require prior written approval.FDOE should also incorporate into its grants management policies and procedures a step to determine whether it isrequired to obtain prior approval from the Department for certain expenditures related to any Department grants, orwhether it can provide…

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Develop a process to track and periodically check on the use ofEANS-funded supply purchases with a unit cost under $5,000 to ensure that all supplies are accounted for and used forallowable purposes.

Develop procedures requiring acquisition team members, as defined in response to Recommendation 1, to complete a conflict of interest certification in which each team member is to assess and document that they do not have a potential or actual conflict of interest related to the specific acquisition prior to participating in any phase of the acquisition lifecycle (from planning to closeout). These procedures should require that evidence of acquisition team members’ conflict of interest certifications is maintained in accordance with requisite FDIC records retention schedule requirements.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Iowa torequire Des Moines to return to the U.S. Department of Education the $164,580 that Des Moines improperly charged tothe ARP ESSER grant for LEA advertising and public relations or reallocate the funds to other allowable costs. Identifyany additional improper charges to ESSER grants for LEA advertising and public relations, including those made duringperiods not covered by our review, and if applicable, return the funds to the U.S. Department of Education or reallocatethem to other allowable costs.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Iowa torequire Des Moines to provide documentation to support payment of the unsupported portion of the HVAC upgradesexpenditure, return to the U.S. Department of Education the $33,326 in ARP ESSER grant funds, or reallocate the fundsto other allowable costs.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Iowa torequire Des Moines to calculate the interest earned (actual or imputed) on any ESSER grant funds that were retained(withheld) and not immediately paid to vendors, and if applicable, ensure that the correct amount of interest is returned tothe Federal government in accordance with 2 C.F.R. section 200.305(b)(9).

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Iowa torequire Des Moines to ensure that LEA officials responsible for making or reviewing and approving purchases receivesufficient training on Federal rules and regulations related to grant administration and management, particularly thoseaddressing allowability, documentation requirements, and cash management.

We recommend that the Director of Acquisition and Contract Management develops standard operating procedures for issuing contract modifications.

We recommend that the Director of Acquisition and Contract Management provides training on the updated contracting procedures.

We recommend that the Director of Acquisition and Contract Management develops a contracting officer representative handbook that alights with the contracting officer representative designation memo and includes policies, standard operating procedures, and best practices to assist the contracting officer representative with contract oversight.

We recommend that the Director of Acquisition and Contract Management defines and communicates the roles, responsibilities, and standard operating procedures for the technical point of contact to ensure efficiency in executing the contract activities.

We recommend that the Director of Acquisition and Contract Management develops a centralized system for maintaining contract files to ensure that contracting officer representatives are compliant with the Federal Acquisition Regulation and record retention requirements.

We recommend that the Director of Acquisition and Contract Management ensures that contracting officers review the contracting officer representative files annually and develop a checklist for the review.

We recommend that the Director of Acquisition and Contract Management ensures that contract management personnel have access to Contractor Performance Assessment Reporting System and develops and implements standard operating procedures for performance assessments to be submitted into Contractor Performance Assessment Reporting System at the time the work under the contract or order is completed.

We recommend that the Director of Acquisition and Contract Management ensures contracts are closed out within the specified Federal Acquisition Regulation timeframes and backlogged contracts are properly closed.

We recommend that the Director of Acquisition and Contract Management works with the contracting officer representative to establish processes and standard operating procedures that ensure de-obligations are completed when the period of performance ends and the final invoice is paid.

1. We recommend that the Under Secretary of Commerce for Industry and Security, Bureau of Industry and Security take proactive actions, such developing a comprehensive mitigation plan or alternative actions, to minimize the risk of unauthorized release of U.S. -controlled advanced computing and semiconductor manufacturing technology and software source code to China.

Review and take corrective action for the 222 cases we identified where the Social Security Administration (SSA) may have incorrectly applied a waiting period and delayed Medicare coverage, if applicable.

Review and take appropriate corrective action on the remaining population of 2,269 beneficiaries with Amyotrophic Lateral Sclerosis, beneficiaries entitled to Childhood Disability Benefits, and beneficiaries re entitled within 5 years for whom SSA may have incorrectly applied waiting periods.

Create integrity checks within SSA systems that result in alerts or exceptions for scenarios where the 5-month waiting period was applied incorrectly.

The Director, Field Collection, SB/SE Division, should ensure that the taxpayers who were not given the opportunity for a CDP hearing are given their CDP rights, if appropriate; and obtain authorization to retain any improper levy proceeds or refund the proceeds to the taxpayer.

(U) Rec. 1: Report is Classified.

(U) Rec. 1: Report is Classified.

(U) Rec. 2: Report is Classified.

Update its DHS I&A Contract Management Guidebook and checklists to include specific contracting functions in support of OCPO and clearly delineate the contract administration responsibilities between DHS I&A and OCPO.

Develop a process to ensure that all closeout modifications are signed on the same date that the contract action is released in the contract writing system.

We recommend that USAID's Chief Information Officer request its
cognizant Management Council on Risk and Internal Control to report and track as a significant deficiency to the Agency the risk of not timely disabling network accounts for separated employees and contractors, as identified in Office of Inspector General Report No. A-000-21-004-C, Recommendation 2.

We recommend that USAID's Chief Human Capital Officer request its
cognizant Management Council on Risk and Internal Control to report and track as a significant deficiency to the Agency the risk of not maintaining records evidencing that staff have been offboarded in accordance with Agency policy, as identified in Office of Inspector General Report
No. A-000-21-004-C, Recommendation 3.

We recommend that USAID's Chief Information Officer develop and
implement procedures to document deviations from Agency policy on security control assessments, including acceptance of the risk of such deviations.

We recommend that USAID's Chief Information Officer establish and implement a process to track the progress of conducting annual reviews and related lessons learned from the implementation of its Information Security Continuous Monitoring Strategy.

(U) Rec. A.1: Report is Classified.

(U) Rec. A.2: Report is Classified.

(U) Rec. A.4: Report is Classified.

(U) Rec. B.1: Report is Classified.

(U) Rec. B.2: Report is Classified.

(U) Rec. C.1: Report is Classified.

(U) Rec. 1: Report is Classified.

(U) Rec. 2: Report is Classified.

(U) Rec. 3: Report is Classified.

CMS should implement additional safeguards to ensure that remote patient monitoring is used and billed appropriately in Medicare.

CMS should require that remote patient monitoring be ordered and that information about the ordering provider be included on claims and encounter data for remote patient monitoring.

CMS should develop methods to identify what health data are being monitored.

CMS should conduct provider education about billing of remote patient monitoring.

CMS should identify and monitor companies that bill for remote patient monitoring.

1. We recommend that the Department's Senior Agency Official for Geospatial Information coordinate with NOAA and Census to review our test results, determine which missing metadata content is most significant for current users of geospatial data, and develop a plan (with goals and timeframes) to ensure more consistent completion of those fields.

We recommend the Director of CISA develop and implement a risk-based national strategic plan that addresses current and evolving risks, to enhance the security and resilience of the Nation’s election infrastructure, including disinformation and the use of artificial intelligence.