Recommendations Tracker

We recommend that the State agency work with CMS to determine and refund the unallowable portion of Federal reimbursement for physician-administered drugs that were not invoiced for rebates after December 31, 2013.

CMS should improve its Drug Data Reporting for Medicaid system to minimize inconsistent data submissions and track potential classification errors for followup.

We recommend that ACF include in the letters sent to AIAN Head Start grantees specific dates for correcting deficiencies.

We recommend that ACF review its staffing levels and determine whether resources are aligned efficiently, and adjust as needed, to ensure that the audit resolution process is conducted in accordance with Federal requirements.

We recommend that the State agency consider adding a requirement in future contracts that the group homes conduct repairs and general upkeep within a specified timeframe.

We recommend that the State agency work with the State licensing agency to implement adequate monitoring controls to ensure that all group home employees who have the potential for unsupervised contact with children receive all of the required background record checks within a specific and reasonable timeframe.

We recommend that the State agency strengthen internal controls to ensure the invoice recalculation step is performed when needed so that all managed-care pharmacy drugs eligible for rebate are invoiced.

We recommend that His House increase oversight of its reviewing process for UAC case files to ensure that all required documentation is maintained in the file.

We recommend that His House update or develop policies and procedures pertaining to achieving the segregation of duties such as ensuring limited access to employee data maintained in its HR and payroll systems and improved managerial oversight.

We recommend that His House implement a financial management system that requires adequate identification of the source and application of Federal funds and effective accountability of property and other assets.

Implement controls to ensure in-kind contributions are properly supported and allowable, and develop policies and procedures for documenting and valuing the non-Federal share and in-kind contributions.

Follow its policies and procedures to obtain competitive bids for procurement transactions.

We recommend that Pine Bluff strengthen monitoring procedures to ensure that costs claimed benefit the program during the grant period (related to unnecessary equipment purchases)

Implement policies and procedures to ensure that only Head Start employees are compensated with Head Start funds.

Develop and implement adequate policies and procedures to ensure that funds charged to the Head Start program benefit the program (related to storage costs).

We recommend that Pine Bluff work with OHS to determine what portion of the $57,987 allocated to the Head Start program should be allocated to its other programs.

We recommend that Pine Bluff adhere to its policies and procedures to ensure that timesheets are always signed by the employee's supervisor and approved by the executive director, and ensure that employees with payroll responsibilities do not process their own timesheets.

We recommend that Pine Bluff adhere to its policies and procedures and periodically review its rental arrangements.

We recommend that Pine Bluff ensure that all costs charged to the Head Start program are properly supported with adequate documentation (related to GL transactions).

We recommend that the State agency strengthen its controls and oversight activities to ensure that providers maintain required attendance documentation to support the childcare payment amounts that they claim for reimbursement by the State agency.

We recommend IHS deem a risk of the lack of continuity of operations to be unacceptable and take immediate action to assess all IHS facilities and ensure each facility has a tested and viable continuity of operations program to respond to and recover from a range of disasters.

We recommend that IHS develop and implement logical access-control procedures to ensure compliance with the principle of least privilege and conduct periodic privilege-based access reviews to remove unnecessary access to RPMS.

We recommend that IHS identify all hospitals with unsupported networking equipment and implement a system development life cycle plan to ensure hardware and software replacement before EOL.

We recommend that IHS ensure that all vulnerabilities identified during vulnerability scanning are remediated in accordance with Federal requirements.

Our reviews of claims covering CYs 2010 through 2014 showed that providers incorrectly billed diagnosis code 260 for Kwashiorkor for inpatients who did not have the disease. On October 31, 2009, AHA published its Third Quarter 2009 Coding Clinic. In response to a question about claims containing two malnutrition codes, AHA stated that diagnosis code 260 is for Kwashiorkor only. This discrepancy in the coding classification was corrected with the issuance of the ICD-10 codes on October 1, 2015. While our reviews have successfully returned $5,684,016 of the $6,030,135 to the Medicare Trust Funds to date, we estimate that Medicare could have saved approximately $102 million from CY 2006 through CY 2014 if the coding discrepancy had been immediately corrected. Therefore we recommend that CMS formalize procedures for notifying providers of the correct way to bill diagnosis codes when there is a discrepancy in the coding classification between the alpha index and the tabular list.

We recommend that the State agency work with CMS to determine the allowable amount of the remaining $306,233,377 set-aside because the rates included unallowable costs that could not be quantified.

We recommend that CMS ensure that suppliers have the applicable licenses for the specific competitions in which they are submitting a bid by continuing to work with State licensing boards, as recommended in our previous report.

We recommend that Texas Medicaid review capitation payments before and after our audit period for additional unallowable payments for these deceased beneficiaries.

We recommend that Texas Medicaid strengthen its policies and procedures for identifying deceased beneficiaries and denying Medicaid benefits and ending eligibility to prevent future unallowable payments.

We recommended that the State agency ensure that future changes to Medicaid payment methodologies comply with the Medicaid State plan.

We recommend that the Hospital exercise reasonable diligence to identify and return any additional similar overpayments received outside of our audit period, in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.