Open Recommendations

We recommend that Lake Hospital System refund to the Medicare contractor the portion of the $4,385,974 in estimated overpayments for the audit period for claims that it incorrectly billed that are within the 4-year reopening period.

We recommend that Lake Hospital System based on the results of this audit, exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule,  and identify any of those returned overpayments as having been made in accordance with this recommendation (This recommendation does not apply to any overpayments that are both within our sampling frame (i.e., the population from which we selected our statistical sample) and refunded based on the extrapolated overpayment amount.  Those overpayments are already covered in the previous recommendation.).

We recommend that Lake Hospital System strengthen controls to ensure full compliance with Medicare requirements.

The OIG recommended the acting under secretary for health collaborate, as necessary, with other offices within VA that have responsibilities regarding personal identity verification cards to ensure contracting officers obtain and maintain evidence of contractor-provided lists of all personal identity verification cards issued to contractor employees.

The OIG recommended the acting under secretary for health collaborate, as necessary, with other offices within VA that have responsibilities regarding personal identity verification cards to ensure contracting officers maintain evidence documenting personal identity verification cards were returned to the issuing or designated office when the cards were no longer required and prior to closing the contract.

The OIG recommended the acting under secretary for health collaborate, as necessary, with other offices within VA that have responsibilities regarding personal identity verification cards to evaluate the role of contracting officer’s representatives in the personal identity verification card process for contractor employees and assess whether updates to their letter of delegation and standard operating procedures are necessary.

The OIG recommended the acting under secretary for health collaborate, as necessary, with other offices within VA that have responsibilities regarding personal identity verification cards to establish procedures within the Procurement Audit Office for periodic reviews of contract files to determine compliance with the personal identity verification card requirements established in the Federal Acquisition Regulation and the Veterans Health Administration procurement manual. Further, require the results of these reviews to be reported to senior management to help determine whether corrective actions are required.

The OIG recommended the acting under secretary for health collaborate, as necessary, with other offices within VA that have responsibilities regarding personal identity verification cards to assess whether contracting officers should be required to include the contractor-provided list as an explicit requirement in all Veterans Health Administration contracts that require issuance of personal identity verification cards to contractor employees.

Obtain the proper approval and communicate the IT modernization strategy to all appropriate stakeholders, including HUD program offices.

Ensure that records explaining decisions regarding changes in ownership, changes in accreditation status, percentage of required letters of credit, or heightened cash monitoring placement that deviate from the regulations or Department policy are created and retained.

Design and implement policies and procedures for reviewing and approving schools’ applications for conversions from for-profit to nonprofit status.

Clarify the functional statements for the Office of the Under Secretary and FSA to clearly state whether and in what circumstances the Under Secretary may, consistent with the provisions of the HEA governing FSA as a performancebased organization, exercise the Secretary’s authority to direct the operations of FSA. Authority areas that should be clarified include but are not limited to determinations regarding changes in school ownership.

Ensure that FSA creates and retains records explaining decisions to deviate from prescribed policy for letter of credit requirements and temporary provisional program participation agreement extensions during a change in ownership and documenting how the interests of students and taxpayers are adequately protected.

Clarify the functional statements for the Office of the Under Secretary and FSA to clearly state whether and in what circumstances the Under Secretary may, consistent with the provisions of the HEA governing FSA as a performancebased organization, exercise the Secretary’s authority to direct the operations of FSA. Authority areas that should be clarified include but are not limited to dealing with potential school closures and the Department’s release of and approval for the use of surety funds.

OIG recommends that the Bureau of Administration review and update all foreign per diem locations designated in eAllowances as exchange rate adjusted in accordance with the guidance developed in response to Recommendation 3.

OIG recommends that the Bureau of Administration review its methodology for determining foreign per diem rates to identify opportunities to streamline the process. At a minimum, the Bureau of Administration should consider whether the use of independent economic data would be more efficient and cost-effective for establishing foreign per diem rates.

OIG recommends that the Bureau of Administration develop and implement a plan to revise the methodology for determining foreign per diem rates based on the results of Recommendation 11.

After implementing Recommendation 12, OIG recommends that the Bureau of Administration recalculate the foreign per diem rates for the locations based on the revised methodology.

OIG recommends that the Bureau of Administration complete its efforts to upgrade and update its eAllowances application. As part of this effort, the Bureau of Administration should ensure that posts are able to upload supporting documentation, such as reservation logs, into the application.

Rec. A.1.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Directors of the Defense Finance and Accounting Service and DoD Components to establish and implement business rules between all the systems that create, process, or store SF 1081 transactions and the Advancing Analytics tool to ensure that the DoD maintains a universe of SF 1081 transactions in a centralized database.

Rec. A.1.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/ Chief Financial Officer, DoD, work with the Directors of the Defense Finance and Accounting Service and DoD Components to establish memorandums of understanding with the system owners and the Advancing Analytics owners to define roles and responsibilities for managing the SF 1081 transactions.

Rec. A.1.d: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Directors of the Defense Finance and Accounting Service and DoD Components to develop metric reports that track the net and absolute dollar amount, and number of SF 1081 transactions by each system that creates, processes, and stores SF 1081 transactions.

Rec. A.1.f: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Directors of the Defense Finance and Accounting Service and DoD Components to ensure that all systems that create, process, or store SF 1081 transactions can differentiate between SF 1081 transactions and other types of transactions. In addition, the systems should have the capability to differentiate between SF 1081 transactions used to correct errors and those used to transfer funds.

Rec. B.1: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Director of the Defense Finance and Accounting Service to either update the Defense Joint Military Pay System to ensure that all disbursements cite the correct accounting information or develop alternative automated solutions.

Rec. B.2.c: The DoD OIG recommended that the Director of the Defense Finance and Accounting Service implement procedures to inform DoD Component management when the Component is charged for Defense Finance and Accounting Service errors.