Recommendations Tracker

To strengthen program safeguards for preventing and detecting improper payments for short inpatient stays and recovering overpayments for claims that do not comply with Medicare requirements, we recommend that the Centers for Medicare & Medicaid Services work with its contractors to develop a list of ICD-10 procedure codes associated with the HCPCS codes on the inpatient only procedures list.

To strengthen program safeguards for preventing and detecting improper payments for short inpatient stays and recovering overpayments for claims that do not comply with Medicare requirements, we recommend that the Centers for Medicare & Medicaid Services work with its contractors to update policies and procedures for postpayment reviews to focus on claims for short inpatient stays identified as at risk for noncompliance with the two-midnight rule and recovery of overpayments (e.g., through additional reviews by RACs or other contractors).

We recommend that the Food and Drug Administration develop and implement policies and procedures requiring periodic reporting (e.g.,monthly reporting) to senior leadership on the status of open whistleblower complaints.

We recommend that the Food and Drug Administration strengthen the QFC process to identify data entry inaccuracies.

We recommend that the Food and Drug Administration develop policies and procedures that FDA can use during future public health emergencies to identify how and when it is necessary to conduct mission-critical inspections and ensure that mission-critical inspections are conducted in a timely manner.

We recommend that the Food and Drug Administration amend the language on the CAERS adverse event report form to emphasize the importance of including the lot number to encourage the public to report this information.

We recommend that the Centers for Medicare & Medicaid Services identify providers who ordered OTS braces for enrollees with whom they had no treating relationships and use that information to determine whether to provide additional education to—or take administrative or legal action against—the ordering providers or associated suppliers.

We recommend that the Centers for Medicare and Medicaid Services review Medicare allowable amounts for OTS braces that are not currently in the DMEPOS Competitive Bidding Program to ensure that Medicare payments for OTS braces are reasonably comparable with payments made by non-Medicare payers, and determine whether to include any of those procedure codes for braces in future rounds of competitive bidding.

We recommend that the Centers for Medicare & Medicaid Services use predictive data analysis and information from other Federal agencies and from State agencies to identify emerging fraud schemes related to OTS braces, and use CMS's authority to prevent further losses to the Medicare program.

We recommend that the Centers for Disease Control and Prevention require the six recipients in our sample that may have improperly charged salary, related fringe benefit, and overhead costs to the REACH program award to refund $1,377,025 to the Federal Government or work with the recipients to determine what portion of these costs is allocable to their REACH program award and refund any unallocable portion of these costs to the Federal Government.

We recommend that the California Department of Health Care Services work with CMS to determine the amount of any improperly claimed Federal reimbursement for capitation payments made on behalf of noncitizens with UIS for an agreed-upon period not covered by our audit.

We recommend that HHS continue advocating for legislative changes and work with OMB and other stakeholders to develop and implement an approach to calculating and reporting on TANF IPs going forward. This process will aid in identifying root causes of TANF IPs and allow HHS to report CAPs in the AFR.

We recommend that HHS focus on the root causes of the IP percentage and evaluate critical and feasible action steps to assist states with their compliance efforts for these requirements. This would include working with the states to bring their respective systems into full compliance with the requirements to decrease the IP rate percentage below 10 percent. HHS should work with the states to follow up on repeat root causes of errors and enhance the CAPs for implementation. In addition, as HHS reviews only 17 states each year for the CHIP IP rate, HHS should continue to follow up with states during the interim period to verify that corrective actions identified after the Payment Error Rate Measurement (PERM) review are being implemented. HHS should also consider sharing corrective action best practices across states to help address these issues. Additionally, HHS should continue to focus on corrective actions around eligibility as there is an increased risk that the rates for Medicaid

We recommend that HHS continue to work with OMB and other relevant stakeholders to complete the IP measurement program for the State-based Exchanges to report a full and accurate IP estimate.

We recommend that HHS should include in its UIP estimation methodology an evaluation of patient eligibility and consider alternative methods to perform this evaluation if data limitations exist.

CMS should provide additional technical assistance to States to clarify what to include or exclude from the reported paid amounts to providers for Medicaid managed care drug claims.

NIH should develop additional ways of supporting researchers in meeting inclusion enrollment targets.

We recommend that the Colorado Department of Health Care Policy and Financing determine the value of overpayments identified after our audit period that have been recovered and collected but not reported, report them on the Form CMS-64, and refund the Federal share of the recovered overpayments.

We recommend that the Colorado Department of Health Care Policy and Financing strengthen policies and procedures to ensure that overpayments are reported correctly and in a timely manner on the Form CMS-64 in accordance with Federal requirements.

We recommend that New York Medical College refund $73,515 in unallowable salary costs, cost transfers, and travel costs.

We recommend that New York Medical College strengthen its internal controls by developing a policy or procedure that requires compensation costs to be reasonable, conform to established College policy, and be consistently applied regardless of the source of the funds and that reasonably reflects the percentage of time actually devoted to its NIH-funded projects.

We recommend that New York Medical College strengthen its internal controls completing the timely certification of employee time and effort reports to provide reasonable assurance that the charges are accurate, allowable, and properly allocated.

We recommend that New York Medical College strengthen its internal controls by developing a cost transfer policy that includes the documentation requirements contained in NIH GPS 7.5.

We recommend that New York Medical College strengthen its internal controls by monitoring key individuals' completion of annual FCOI disclosure forms and completion of required FCOI training.

We recommend that the Centers for Medicare & Medicaid Services issue finalized guidance regarding multiple-source physician-administered drugs, to clarify and reinforce the requirement that rebates should be collected for all required physician-administered drugs.

We recommend that the New Mexico Human Services Department recoup the $29,442,388 in NFLOC capitated payments from its MCOs and refund the $20,536,132 Federal share to the Federal Government.

We recommend that the California Department of Health Care Services provide caseworkers additional training to reduce errors related to: (1) calculating and verifying income, (2) entering income information into the county case management system, and (3) using electronic data sources when verifying enrollees' reported income.

We recommend that the California Department of Health Care Services identify and correct the system issues that prevented the State agency from renewing enrollees' eligibility on an ex parte basis when those enrollees should have been determined eligible and from sending a notice of termination to enrollees.

We recommend that the Office of Intergovernmental and External Affairs remind cardholders and AOs of the documentation and reconciliation requirements outlined in Federal and HHS requirements and provide them with a copy of the Program Guide as part of the annual refresher training process.

We recommend that the Office of Intergovernmental and External Affairs provide to all cardholders and AOs training that encompasses the requirements related to the purchase of sensitive items, including properly completing the HHS-755 and tracking purchases in the PMIS.

We recommend that the Office of Intergovernmental and External Affairs work with the HHS A/OPC to create and maintain a centralized database as required by the Program Guide that captures the training certificates of all cardholders and AOs, including certificates for the annual refresher training.

We recommend that West Virginia's Bureau of Behavioral Health conduct a periodic review of supporting documentation (e.g., invoices, payroll registers, and time-and-effort reports) for any subrecipient expenditures submitted to BBH.

We recommend that West Virginia's Bureau of Behavioral Health provide training to program managers to ensure that advanced payments are being approved as close as administratively feasible to actual disbursements by the subrecipient.

We recommend that the Ohio Department of Medicaid provide periodic training to caseworkers about verifying and documenting enrollees' income during the renewal process.

We recommend that the Centers for Medicare & Medicaid Services improve its procedures, which may require seeking legislative authority, for setting and adjusting rates for new CDLTs during a PHE by providing the MACs with the flexibility needed to set and adjust payment rates that would cover the laboratory costs of providing services when responding to a PHE.

We recommend that the Missouri Department of Health and Senior Services consider implementing additional monitoring activities whenever the State receives large supplemental funding disbursements.

We recommend that the Administration for Strategic Preparedness and Response review the FY 2018 and 2019 JFA allocation methodologies along with the methodologies used during subsequent FYs to determine whether the costs were allocated to each office based on appropriate methodologies, and correct any improper allocations to avoid potential Antideficiency Act violations.

We recommend that the Administration for Strategic Preparedness and Response review the 10 remaining sampled employees that we could not interview to determine whether any salaries were improperly charged to BARDA appropriations and identify potential Antideficiency Act violations.