Recommendations Tracker

Refund to the Federal Government the portion of the estimated $42,336,162 for hospice services that did not comply with Medicare requirements and that are within the 4-year claims reopening period.

Strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services direct the MACs to recover from acute-care hospitals the portion of the $39,310,499 in identified improper payments for our audit period that are within the 4-year reopening period in accordance with CMS's policies and procedures.

We recommend that the Centers for Medicare & Medicaid Services, based upon 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 Centers for Medicare & Medicaid Services continue to review the CWF edits to determine whether any refinements are necessary to prevent improper payments to acute-care hospitals for outpatient services provided to beneficiaries who are inpatients of other facilities (i.e., LTCHs, IRFs, IPFs, and CAHs).

Reimburse New York's BHP Trust Fund $8,615 associated with the improper monthly payments identified in our sample.

Implement system changes to ensure that BHP enrollees with a pending coverage end-date are transferred from BHP to Medicaid upon the end of their 5-year bar.

Implement system changes to ensure that claims for BHP payments are not made on behalf of deceased individuals.

CMS should design an annual MLR reporting template for States to provide to their Medicaid managed care plans.

CMS should clarify that States should review their Medicaid managed care plans' MLR reports to verify the accuracy of reported data elements.

CLA recommends that the National Institutes of Health assess its grant award programs to determine which grants should require additional cybersecurity protections due to research potentially including sensitive and confidential data or NIH intellectual property or both.

CLA recommends that the National Institutes of Health strengthen the NIHGPS to establish clear and measurable standards for cybersecurity protections.

CLA recommends that the National Institutes of Health strengthen its post-award process to confirm that cybersecurity protections have been implemented to adequately safeguard sensitive and confidential data. ?

We recommend that the Centers for Medicare & Medicaid Services provide States with matched T-MSIS enrollment data that identify Medicaid beneficiaries who were concurrently enrolled in a Medicaid managed care program in two States.

We recommend that the Centers for Medicare & Medicaid Services direct the MACs to recover the $331,448 from the CAHs for 12,156 claims for which the health care practitioners had not reassigned their billing rights to the CAHs and $83,412 in cost-sharing overcharges to Medicare beneficiaries that are within the 4-year reopening period.

We recommend that the Centers for Medicare & Medicaid Services request that relevant providers 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 Centers for Medicare & Medicaid Services direct the MACs to educate CAHs on their obligation not to bill for professional services when health care practitioners do not reassign billing rights to the CAH.

FDA should assess and, as appropriate, revise FDA guidance for test Emergency Use Authorization (EUA) submissions.

FDA should expand the Center for Devices and Radiological Health's existing device-tracking platform to facilitate Emergency Use Authorization (EUA) submission and monitoring.

FDA should establish formal communication channels between FDA and the lab community, to be used in emergencies that require testing.

We recommend that IHS's NSSC strengthen internal controls by developing and implementing written policies and procedures for emergency situations when normal NSSC supply distribution processes are not possible or must be augmented.

We recommend that IHS's NSSC upgrade its inventory management system software to improve its ability to interface with IHS Areas, other customers, and third-party vendors.

We recommend that the Centers for Medicare & Medicaid Services instruct SSAs to follow up with the 23 nursing homes that we have identified with possible infection prevention and control and emergency preparedness deficiencies to verify that they have taken corrective actions.

We recommend that the Tennessee Department of Finance & Administration invoice for and collect manufacturers' rebates totaling $16,805,782 ($10,996,932 Federal share) for single-source and top-20 multiple-source physician-administered drugs and refund the Federal share of rebates collected.

We recommend that the Tennessee Department of Finance & Administration strengthen internal controls for non-crossover claims to ensure that all eligible physician-administered drugs are invoiced for rebate in a timely manner.

We recommend that Regence BlueCross BlueShield of Oregon refund to the Federal Government the $1,890,855 of estimated net overpayments.

We recommend that Regence BlueCross BlueShield of Oregon continue to examine 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.

ACF should develop and implement a plan that supports ORR and its contractors in securing qualified case managers during an influx to help ensure children's safe and timely release to sponsors.

ACF should create an emergency policy development protocol that provides for adequate input from staff with expertise in child welfare when ORR develops field guidance during an influx.

ACF should ensure that ORR's employees and employees of ORR contractors and recipients are informed about Federal whistleblower protections.

We recommend that the New York State Department of Health refund the estimated $84,329,893 to the Federal Government for payments that did not comply with Federal and State requirements.

We recommend that the New York State Department of Health improve its oversight of its NEMT program to ensure that the transportation manager strengthen its procedures to ensure that (1) prior authorization documentation, including medical practitioner's orders are properly completed and maintained; (2) transportation providers do not bill for transport on a date when a beneficiary does not receive a Medicaid-covered service; (3) transportation providers document that drivers and vehicles used to transport Medicaid beneficiaries meet applicable State requirements; (4) NEMT services are adequately documented; (5) transportation providers bill only for services that are actually provided; and (6) transportation providers bill for the level of service authorized.

The Indian Health Service should develop a strategy for expeditiously deploying a new information system when it is necessary to meet an urgent, mission-critical need. The strategy should define the minimum set of controls out of the total number of required controls that should be addressed and, if applicable tested, before the new system is authorized to operate until it is feasible to address all required controls. The authorization to operate should include an acceptance of risk for not implementing all required controls, specify a date by which the remaining required controls will be implemented and tested, and be replaced with a new authorization to operate once all the required controls have been addressed.

Develop and implement outreach efforts to ensure that the Unit regularly receives referrals of patient abuse and neglect.

Conduct and document supervisory reviews of case files in accordance with Unit policy.

We recommend that the Administration for Strategic Preparedness and Response establish written policies and procedures regarding the roles and responsibilities for organizational communication between ASPR and federally established emergency response team lead agencies.

We recommend that the Administration for Strategic Preparedness and Response: develop and implement policies and procedures to help ensure the accurate reporting of contract data in FPDS.

CMS should lower Medicare's payment rates for intermittent urinary catheters.

We recommend that the Municipality of Barceloneta complete its integration of the Head Start program's accounting system to the Municipality's electronic accounting system.

We recommend that the Municipality of Barceloneta reinforce existing policies and procedures to ensure that drawdowns for the Head Start program are based on a valid voucher.

We recommend that the Municipality of Barceloneta ensure that criminal background checks on employees and contractors that have direct contact with children are completed within required time frames.

CMS should strengthen monitoring and targeted oversight of telehealth services.

CMS should improve the transparency of "incident to" services when clinical staff primarily delivered a telehealth service.

CMS should follow up on the providers identified in this report.