Recommendations Tracker

CMS should assess the results of infection control surveys and revise the survey as appropriate.

CMS should clarify expectations for States to complete backlogs of standard surveys and high-priority complaint surveys.

IHS should provide additional guidance and training to facilities on patient protection policies, including the role of law enforcement and the reporting process related to patient abuse.

IHS should examine and revise, as needed, the reporting structure in the policies and the incident reporting system to ensure that staff and patients can report abuse anonymously.

We recommend that Hospice Compassus, Inc., of Tullahoma, Tennessee exercise reasonable diligence to identify, report, and return the estimated $3,464,856 for hospice services that did not comply with Medicare requirements 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 Hospice Compassus, Inc., of Tullahoma, Tennessee strengthen its procedures to ensure that hospice services comply with Medicare requirements.

We recommend that Providence Medical Center refund to the Medicare contractor the portion of the $325,241 in estimated overpayments for the audit period for claims that it incorrectly billed that are within the 4-year reopening period.

We recommend that Providence Medical Center strengthen controls to ensure full compliance with Medicare requirements.

We recommend that the Centers for Disease Control and Prevention implement requirements for CDC in-country offices to have SOPs for CoAg management.

IHS should assess the costs and benefits of updating its EHR system with tools to support more automated monitoring.

IHS should establish patient harm monitoring and reduction as a key priority of the Office of Quality.

IHS should implement quality improvement plans to improve patient safety across IHS, including plans that focus specifically on smaller hospitals and patient groups at higher risk of harm.

IHS should assess its labor and delivery practices and consider practice improvements based on the findings of this assessment.

IHS should encourage and support greater adoption of AIM's bundles of maternal-safety best practices.

We recommend that the New York State Department of Health refund $54,456,563 to the Federal Government.

We recommend that the New York State of Health reinforce with the local districts and personal care services providers Medicaid requirements related to personal care services to ensure local districts conduct all required assessments and examinations in a timely manner and that they maintain documentation related to the authorization and reauthorization of services; local districts are aware of requirements related to conducting independent medical review; personal care service providers conduct criminal history checks on all aides and verify that all aides meet training requirements prior to providing Medicaid services; and personal care services providers document time spent providing services.

We recommend that Total Patient Care Home Health, LLC strengthen its procedures to ensure that (1) the homebound statuses of Medicare beneficiaries are verified and continually monitored and the specific factors qualifying beneficiaries as homebound are documented and (2) beneficiaries are receiving only reasonable and necessary skilled services.

We recommend that the New York State Office of Mental Health refund the entire PATH grant amount, totaling $4,222,941, to the Federal Government.

We recommend that the New York State Office of Mental Health strengthen its policies and procedures to ensure that PATH program services are only provided to eligible consumers; PATH providers submit certifications before distributing PATH funds; PATH providers accurately report the number of consumers served; and it timely completes the financial closeout of its PATH program for the grant period to confirm its final FFR is accurate.

We recommend that the Nebraska Department of Health and Human Services, Division of Medicaid and Long-Term Care refund $22,484 (Federal share) in overpayments to the Federal Government.

We recommend that the Florida Agency for Health Care Administration refund $1,441,107 to the Federal Government.

We recommend that the Florida Agency for Health Care Administration improve its policies and procedures to ensure that it is adequately monitoring school-based service claims to ensure compliance with Federal and State requirements.

We recommend that Hospice Compassus, Inc., of Payson, Arizona exercise reasonable diligence to identify, report, and return the estimated $1,872,291 for hospice services that did not comply with Medicare requirements 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 Hospice Compassus, Inc., of Payson, Arizona strengthen its procedures to ensure that hospice services comply with Medicare requirements.

We recommend that The Palace, 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 Cahaba work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare PRB costs of $4,320,303 for CYs 2014 through 2016.

We recommend that Cahaba Safequard Administrators, LLC, work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare PRB costs of $675,457 for CYs 2014 through 2016.

We recommend that CMS instruct the Medicare contractors to recover, in accordance with Federal regulations, the portion of the $33,095,068 in identified Medicare potential overpayments from the 911 hospitals for the 3,233 incorrectly billed claims that are within the 4-year reopening period.

We recommend that CMS require hospitals to use condition codes 49 or 50 on claims for a device-replacement procedure that resulted from a recall or premature failure, regardless of whether the hospital received a reportable credit prior to billing for the device replacement procedure.

We recommend that CMS obtain device credit listings from manufacturers and determine whether providers reported the credits as required by Medicare regulations.

We recommend that CMS, as an alternative to our third, fourth, and fifth recommendations, consider eliminating the current Medicare requirements for reporting device credits by reducing IPPS and OPPS payments for cardiac device replacement procedures.

We recommend that the Health Resources and Services Administration improve its procedures for monitoring how health centers meet targets for future HRSA grant funding opportunities.

We recommend that the Health Resources and Services Administration require the 34 health centers in our sample identified as having improperly allocated AIMS grant costs to refund $1,722,271 to the Federal Government or work with the health centers to determine what portion of these costs is allocable to their AIMS grants, and work with other health centers in our sampling frame to determine what portion of an estimated $9,207,958 in improperly allocated grant costs is allocable.

We recommend that Edward W. Sparrow 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.