Recommendations Tracker

We recommend that the Centers for Disease Control and Prevention develop an action plan to enforce site visit requirements by CDC's planned date of July 1, 2023.

We recommend that the Centers for Disease Control and Prevention update its Provider Education, Assessment, and Reporting online system to include interactive reminders or alerts related to overdue site visits and followup actions.

We recommend that the Centers for Medicare & Medicaid Services instruct the MACs to, based on the results of this audit, notify appropriate providers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the providers can 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.

We recommend that the Georgia Department of Community Health work with CMS to develop a risk-based approach to identify nursing homes where surveys should be conducted more frequently than once every 15 months, such as those with a history of multiple high-risk deficiencies or frequent management turnover.

We recommend that the Georgia Department of Community Health work with CMS to develop standardized life safety training for nursing home staff.

CMS should use data sources, in addition to OASIS assessments, to improve the accuracy of the quality measure related to falls with major injury.

CMS should explore whether improvements to the quality measure related to falls can also be used to improve the accuracy of other home health measures.

Build upon its efforts to increase referrals of patient abuse or neglect.

Take steps to ensure that periodic supervisory reviews are conducted on a consistent basis and that case files i.nclude documentation of supervisory approvals.

OCSS should bolster State agency resilience during emergencies.

We recommend that the Centers for Medicare & Medicaid Services instruct MACs, based upon the results of this audit, to notify appropriate providers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the providers can exercise reasonable diligence to identify, report, and return any overpayments, up to $17,817,121, in accordance with the 60-day rule and identify any of those returned overpayments as having been made in accordance with this recommendation.

We recommend that the Centers for Medicare & Medicaid Services revise its billing guidance to specify that OTPs should not bill add-on HCPCS codes for take-home supplies of medication for the same episode of care that was already covered by a weekly bundle that included medication, and instruct MACs to implement edits in their claims processing systems to identify improperly billed claims for take?home medication.

We recommend that the Centers for Medicare & Medicaid Services work with MACs to provide education on proper billing of intake activities to the 8 OTPs that billed 14 or more intake activity claims per enrollee during our audit period.

We recommend that the Centers for Medicare & Medicaid Services update applicable Medicare requirements to clarify which types of professional and public education overhead costs are unallowable (e.g., clarify whether the costs of meals provided to non-OPO employees for professional education and the costs of tickets to entertainment events purchased for the purpose of public education are unallowable), which could have saved Medicare an estimated $664,295 for professional and public education overhead costs during our audit period.

We recommend that the Texas Department of Health and Human Services Commission ensure DIR costs are allocated to Medicaid based on an approved methodology in the CAP.

We recommend that the Texas Department of Health and Human Services Commission strengthen policies and procedures to track its private MMIS contractor costs to APDs and ensure that the Federal match is claimed at the approved rate and ensure that it doesn't claim costs when it is reimbursed for those costs by other agencies.

We recommend that Presbyterian Health Plan, Inc., 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 the New York State Department of Health work with the New York State Office of Mental Health to improve its monitoring activities by increasing the number of case files reviewed when conducting provider site visits to ensure that service plans and subsequent service plan reviews are timely signed and maintained, community rehabilitation claims meet Medicaid reimbursement standards, and services are appropriately authorized; and providing formal guidance or training to providers to clarify requirements related to service plans and subsequent service plan reviews being timely signed and maintained, community rehabilitation claims meeting Medicaid reimbursement standards, and services being appropriately authorized.

We recommend that the Centers for Medicare & Medicaid Services work with the DME MACs to do the following, which if in effect during our audit period could have saved Medicare as much as $30,051,107 for wheelchair repairs: review accumulated costs for wheelchair repairs that exceed the federally recommended cost limit, and for those wheelchairs that the DME MACs determine will not remain serviceable for their entire 5-year RUL, enforce Federal requirements by requiring the suppliers that transferred ownership of the wheelchairs purchased on a rental basis to enrollees to furnish replacement wheelchairs to those enrollees at no cost to the enrollees or to Medicare.

We recommend that the Centers for Medicare & Medicaid Services work with the DME MACs to do the following, which if in effect during our audit period could have saved Medicare as much as $30,051,107 for wheelchair repairs: take appropriate action for suppliers that consistently bill for repairs made to wheelchairs during their 5-year RUL that exceed the federally recommended cost limit or the cost limit used as the basis for determining when wheelchairs furnished by suppliers will not remain serviceable for their entire 5-year RUL (e.g., by educating suppliers on proper billing and recovering improper payments).

We recommend that the Indian Health Service identify and correct any other Purpose Statute violations relating to funds not used on COVID-19 testing and other testing-related activities from the Families First Act and Paycheck Protection Act funds allocated to the IHS Direct programs within the GPAO, and, if IHS is unable to correct those violations, report any Antideficiency Act violations.

We recommend that the Indian Health Service identify and recover amounts not used for COVID-19 testing or other testing-related activities that we did not sample from remaining Tribal and UIO programs within the GPAO.

We recommend that the Indian Health Service develop and provide adequate guidance to programs within the GPAO on the proper use of Paycheck Protection Act funds in accordance with Federal requirements.

We recommend that the Indian Health Service provide adequate guidance to the programs on how to track and account for funds allocated and used under the Paycheck Protection Act.

We recommend that the Virginia Medicaid Department of Medical Assistance Services identify and recover unallowable capitaiton payments, which we estimate to be at least $21,849,401, made to MCOs during our audit period on behalf of deceased enrollees.

We recommend that the Virginia Medicaid Department of Medical Assistance Services continue to pursue development and implementation of an automated matching and eligibility update process.