Recommendations Tracker

We recommend that the Health Resources and Services Administration require the 34 health centers in our sample identified as having claimed unallowable AIMS grant costs to refund $773,114 to the Federal Government and work with the other health centers in our sampling frame to identify additional unallowable costs, which we estimate to be $5,217,709.

We recommend that the Health Resources and Services Administration improve its monitoring of grant expenditures, including requiring health centers to develop and maintain financial management systems that ensure only allowable, allocable, and documented costs are charged to their HRSA grants.

We recommend that Edward W. Sparrow Hospital strengthen controls to ensure full compliance with Medicare requirements; specifically, ensure that all inpatient beneficiaries meet Medicare requirements for inpatient hospital services and evaluation and management services are supported in the medical records.

We recommend that the Ohio Department of Medicaid ensure that procedures are in place for county caseworkers to timely review and terminate eligibility for beneficiaries who were identified as concurrently eligible in another State.

We recommend that the Ohio Department of Medicaid ensure that Ohio Benefits has the system functionality to properly categorize a beneficiary who was formerly in the foster care program; retrieve and use information from SSA to determine whether a beneficiary is disabled; disallow multiple cases for a beneficiary to be opened simultaneously; alert eligibility caseworkers when a beneficiary dies and discontinue Medicaid coverage for the beneficiary; and alert eligibility caseworkers when a beneficiary or beneficiary's child reaches the age affecting the beneficiary's coverage group.

We recommend that the Ohio Department of Medicaid develop a process for monitoring data entered into Ohio Benefits by periodically testing a State agency-defined percentage of entries for accuracy and implementing appropriate corrective actions, such as staff training, when data entry issues are discovered.

We recommend that CMS work with MACs to recover Medicare OPPS overpayments from hospitals for any additional claims that included medical device credits and that were outside our audit period.

We recommend that VNA of Central Jersey for the remaining portion of the estimated $2,015,925 overpayment for claims that are outside of the Medicare reopening period, exercise reasonable diligence to identify and return overpayments in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.

We recommend that VNA of Central Jersey strengthen its procedures to ensure that the homebound statuses of Medicare beneficiaries are verified and the specific factors qualifying beneficiaries as homebound are documented, beneficiaries are receiving only reasonable and necessary skilled and home health aide services, claims for Medicare reimbursement are only made for services that are provided, and appropriate billing codes are assigned when submitting claims for Medicare reimbursement.

We recommend that the Massachusetts Executive Office of Health and Human Services refund to the Federal Government refund $882,892 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.

We recommend that the Massachusetts Executive Office of Health and Human Services 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, 2017.

We recommend that the Minnesota Department of Human Services work with CMS to determine whether the non-top-20 multiple-source physician-administered drugs were eligible for rebates that we calculated to be at least $173,780 (Federal share) and, if so, upon receipt of the rebates, refund the Federal share of the rebates collected.

We recommend that the Minnesota Department of Human Services work with the contractor to confirm that DRAMS is properly identifying drug rebate eligibility to ensure that all rebate-eligible pharmacy and physician-administered drugs are identified and billed for rebates.

We recommend that St. Francis Hospital, based on the results of this audit, 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 Gem City for the remaining portion of the estimated $2,667,849 overpayment for claims that are outside of the reopening period, exercise reasonable diligence to identify and return overpayments in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.

We recommend that Gem City strengthen its procedures to ensure that the homebound statuses of Medicare beneficiaries are verified and continually monitored and the specific factors qualifying beneficiaries as homebound are documented and beneficiaries are receiving only reasonable and necessary skilled services.

We recommend that Cedars-Sinai Medical Center based upon the results of this audit, 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 Cedars-Sinai Medical Center update its patient checklist to include all of Noridian's specifications for billing bariatric surgeries.

For the 11 MAC jurisdictions with a coverage limitation for the number of facet-joint injection sessions during a rolling 12-month period, we recommend that the Centers for Medicare & Medicaid Services, instruct the MACs to, based upon the results of this audit, notify appropriate physicians (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the physicians 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.

For the 11 MAC jurisdictions with a coverage limitation for the number of facet-joint injection sessions during a rolling 12-month period, we recommend that the Centers for Medicare & Medicaid Services direct the MACs that oversee the 11 jurisdictions to review claims for facet-joint injections after our audit period to identify instances in which Medicare paid physicians for more than 5 injection sessions received by beneficiaries during a rolling 12-month period and recover any improper payments identified.

We recommend that the U.S. Department of Health and Human Services maintain an inventory of all geospatial data assets, per section 759(b) of the GDA.

We recommend that Clinical Practices of the University of Pennsylvania based upon the results of this audit, 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 Colorado Department of Health Care Policy and Financing identify and refund to the Federal Government any payments made on behalf of ineligible beneficiaries for whom services after our audit period were claimed and reimbursed past the termination dates of their eligibility.

We recommend that Alta Bates Summit Medical Center based on the results of this audit, 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 Youth For Tomorrow – New Life Center, Inc. strengthen existing procedures to ensure that family reunification packets are sent within required timeframes.

We recommend that Youth For Tomorrow – New Life Center, Inc. ensure that all employees follow policies and procedures requiring Federal and State background investigations to be completed before staff begin working with children, provide relevant training to appropriate staff, and document and maintain documentation of all results.

We recommend that Youth For Tomorrow – New Life Center, Inc. work with ORR to develop allowable methodologies to allocate salaries, develop a procedure or system to capture what programs each employee actually worked on, and determine what portion of the $1,500,218 in salaries charged based on budget estimates was accurately charged to the UAC program and refund to the Federal Government any unallowable portion.

We recommend that Youth For Tomorrow – New Life Center, Inc. develop policies and procedures for identifying allowable shared UAC program costs, including items that need advance approval, determine whether any of the $210,037 in potentially unallowable and $23,390 in potentially unallowable unapproved expenditures would be allowable under the newly approved allocation methodology or plan, and refund to the Federal Government any unallowable or unapproved portion.

We recommend that Youth For Tomorrow – New Life Center, Inc. develop policies and procedures for identifying direct UAC program costs not in compliance with Federal requirements and refund $6,515 in unallowable expenditures not related to the UAC program.

FDA should strengthen the REMS for opioid analgesics (the successor to ER/LA opioids) by requiring prescriber training.

FDA should seek additional authority to ensure that manufacturers are held accountable when appropriate.