Recommendations Tracker

We recommend that the Centers for Medicare & Medicaid Services review the findings in this report and, if it determines that a separate payment methodology for capital costs at new hospitals is no longer warranted, change its regulations to require new hospitals to have their Medicare capital costs paid through the IPPS with an option for payment adjustments or supplemental payments if necessary.

We recommend that the Oklahoma Health Care Authority consider whether more of an emphasis on counseling could improve OUD outcomes and, if so, take steps to increase the appropriate use of counseling with OUD drugs in outpatient OUD treatment.

We recommend that the Missouri Department of Social Services refund $3,411,531 to the Federal Government.

We recommend that Palmetto work with CMS to ensure that its final settlement of contract costs reflects an increase in Medicare pension costs of $998,912 for CYs 2012-2016.

We recommend that CDS work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare PRB costs for $73,594 for CYs 2012-2016.

We recommend that CDS work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare EP costs of $8581 for CYs 2015 and 2016.

We recommend that Palmetto work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare PRB costs of $2,848,586 for CYs 2012-2016.

We recommend that Palmetto work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare SERP III costs of $25,162 for CYs 2015 and 2016.

We recommend that Palmetto work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare Excess Plan costs of $406,791 for CYs 2015 and 2016.

We recommend that the Centers for Medicare & Medicaid Services direct the Medicare contractors to recover the $1,918,278 for claims that are within the reopening period, and instruct providers to refund up to $540,680, which beneficiaries were required to pay; these amounts consist of $1,427,930 in overpayments to providers that billed noncomplex or complex CCM services more than once for the same beneficiaries for the same service periods and up to $406,080 in cost-sharing overcharges to these beneficiaries; $438,262 in overpayments to providers that billed for both noncomplex or complex CCM services and overlapping care management services rendered to the same beneficiaries for the same service periods and up to $121,166 in cost-sharing overcharges to these beneficiaries; and $52,086 in overpayments to providers that billed for incremental complex CCM services associated with overpayments for complex CCM services that we identified and up to $13,434 in cost-sharing overcharges to th

We recommend that the Centers for Medicare & Medicaid Services direct the Medicare contractors to implement claim system edits to prevent and detect overpayments for noncomplex and complex CCM services.

We recommend that CDS LLC work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare pension costs of $8989 for CYs 2012 through 2016.

We recommend that the Arkansas Department of Human Services refund the $4,361,850 Federal share to the Federal Government.

We recommend that the Texas Health and Human Services Commission refund $856,456 to the Federal Government.

We recommend that the Texas Health and Human Services Commission identify any other beneficiaries who are assigned more than one identification number and refund any unallowable CHIP payments associated with those beneficiaries.

We recommend that the New York State Department of Health refund to the Federal Government or provide documentation of such refund, totaling $97,998,292. Specifically refund to the Federal Government $77,152,491 related to random moments that could not be supported as Medicaid-eligible health services; refund to the Federal Government $1,238,102 for intergovernmental agreement payments that the State agency did not support that it did not double-claim; and refund to the Federal Government or provide documentation of the refund to CMS of $19,607,699 for excess costs claimed on the Form CMS-64 for 1 year.

We recommend that the New York State Department of Health refund $308,972,870 to the Federal Government or provide documentation that it can reasonably support, under the circumstances, its allocation of health services costs to Medicaid without using unverifiable IEP ratios.

We recommend that the New York State Department of Health revise its certified public expenditures SSHSP to (1) include September days worked in its random moment time study and (2) develop an accurate, supportable method to identify Medicaid costs instead of unverifiable IEP ratios.

We recommend that Palmetto GBA, LLC, discontinue using its internal policies of waiving certain overpayment collections related to lookback years and start collecting all hospice cap overpayments and paying refunds in accordance with CMS requirements.

We recommend that Palmetto GBA, LLC, collect $545,639 in lookback overpayments and return $17,513 in lookback refunds resulting from 2017 hospice cap calculations for lookback years.

Kaiser Permanente validate the point-of-sale fee amounts that its PBM disclosed for CYs 2014 and 2015 and refile the CY 2014 and 2015 DIR reports if appropriate.

We recommend that Partners In Care, Inc. refund to the Federal Government the portion of the estimated $11,278,891 for hospice services that did not comply with Medicare requirements and that are within the 4-year reopening period.

We recommend that Partners In Care, Inc. strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services, as part of its ERM program, implement a process to assess all of its programs for national security risks in accordance with OMB Circular No. A-123's requirement to include new or emerging risks in the risk profile.

We recommend that Mission Hospice & Home Care, Inc. refund to the Federal Government the portion of the estimated $10,564,396 for hospice services that did not comply with Medicare requirements and that are within the 4-year reopening period.

We recommend that Mission Hospice & Home Care, Inc.: strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend that Puerto Rico Department of Health revise its EOP, including adding or updating procedures, to comply with HPP-PHEP Cooperative Agreement requirements related to: (1) conducting annual public health and medical preparedness exercises or drills that include at-risk populations in all of its planning and activities; (2) identifying resources for at-risk populations; (3) anticipating storage needs for a surge of human remains; (4) implementing and identifying emergency procurement procedures; (5) clearly defining HCC Specialists' responsibilities; (6) obtaining public comment and input on its EOP; (7) utilizing EMAC or other public health mutual aid agreements to support coordinated activities when responding to public health emergencies; and (8) ensuring that all HCC members can share information regarding resources and resource needs to address an emergency.

We recommend that Puerto Rico Department of Health consider coordinating with appropriate organizations to develop guidance on accurate cause-of-death certifications focusing on whether underlying causes of death were disaster-related.