Recommendations Tracker

We recommend that the State agency refund $411,932,576 to the Federal Government, consisting of $64,382,543, representing the Federal share of net Hospital self-reported LIP overpayments for the audit period and $347,550,033, representing the Federal share of LIP cost limits calculated by the Hospital that did not comply with Federal and State requirements as identified in this audit.

We recommend that the State agency establish procedures to ensure that it returns to the Federal Government the Federal share of overpayments reported by hospitals.

We recommended that the State agency review the cost-limit calculations to verify that hospitals have included these payments (i.e., Medicaid payments (other than DSH and LIP) that are not related to specific claims and the dual-eligible patient portion of payments for Medicare cost report settlements, direct graduate medical education, Medicare bad debts, and organ acquisition costs.

We recommended the State agency improve its oversight of the LIP program by establishing policies and procedures for providing additional training to its staff members on the RFMD and STCs for the waiver; providing training to participating hospital personnel on LIP program compliance and preparing the cost-limit calculations; and monitoring hospital LIP calculations to verify that they comply with the RFMD and STCs including reconciling hospital cost-limit calculations to the finalized Medicare cost reports; reviewing hospital low-income data to verify that it does not include data for undocumented aliens; reviewing hospital low-income data to verify that it does not include data for prisoners in other than an inpatient setting; testing or verifying the accuracy and completeness of the data being used by hospitals in their LIP cost-limit calculations; reviewing hospital cost-limit calculations to verify that the hospitals properly incorporate observation days and charges into the calc

We recommend that the State agency redetermine, as appropriate, the current Medicaid eligibility status of the sampled beneficiaries who did not meet Federal and State eligibility requirements, with specific attention to beneficiaries who did not meet income requirements; beneficiaries who were eligible under a mandatory Medicaid eligibility group; beneficiaries who did not meet citizenship requirements; and beneficiaries who were not eligible for the new adult group but for whom the State agency claimed enhanced Federal Medicaid reimbursement.

We recommend that the State agency implement in the CBMS system functions to ensure benefits of ineligible beneficiaries are terminated in a timely manner and income verifications are requested from beneficiaries when electronic verification does not occur within 4 months of application.

We recommend that the State agency implement a process whereby it resolves discrepancies more promptly by reducing the time between the identification of a discrepancy and the dispatch of a discrepancy letter to the beneficiary.

Ensure that it accurately reports all data on quality measures through the CMS web portal.

We recommended that Oceanside Medical Group refund to the Medicare program the portion of the estimated $2,694,446 overpayment for claims that are within the reopening period.

We recommended that Oceanside Medical Group exercise reasonable diligence to identify and return any additional similar overpayments outside of our audit period, in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.

Develop and implement a plan to increase Medicaid fraud referrals from the Utah Medicaid Inspector General and ACOs.

Develop and implement written procedures for storing, maintaining, and efficiently accessing case information.

We recommend that the Administration for Children and Families continue to monitor the States' actions and progress toward implementation of the new background check requirements.

CMS must do more to avoid paying twice for the same drugs. As we have previously recommended, CMS should work directly with hospices to ensure that they are providing drugs covered under the hospice benefit. In addition, we recommend that CMS should develop and execute a strategy to ensure that Part D does not pay for drugs that should be covered by the Part A hospice benefit, which would save at least an estimated $160.8 million a year in Part D total cost, with potentially much higher annual savings associated with the drugs that hospices said they were not responsible for providing. This should include working with Part D sponsors and seeking whatever authorities are necessary to develop proper controls.

We recommend that the Texas Health and Human Services Commission bill manufacturers for the $3,785,737 ($2,202,921 Federal share) in rebates for single-source and top-20 multiple-source physician-administered drugs, and refund the Federal share of rebates collected.

We recommend that the Texas Health and Human Services Commission work with CMS to determine whether the other physician-administered drugs, associated with 160,579 claim lines, were eligible for rebates and, if so, determine the rebates due and upon receipt of the rebates refund the Federal share of the rebates collected.

We recommend that the New York State Department of Health redetermine, as appropriate, the current Medicaid coverage group of the sampled beneficiaries for whom services were incorrectly reimbursed at an enhanced FMAP rate.

We recommend that the NYS Department of Health maintain the necessary documentation to determine whether it enrolled individuals who did not meet Federal and State Medicaid eligibility requirements in the new adult group.

We recommend that the New York State Department of Health follow up with the 20 nursing homes to ensure corrective actions have been taken regarding the life safety and emergency preparedness deficiencies identified in this report.

We recommend that the New York State Department of Health conduct more frequent surveys at nursing homes with a history of multiple high-risk deficiencies.

We recommend that the Illinois Department of Healthcare (State agency) and Family Services refund $3,174,262 to the Federal Government.

We recommend that the Illinois Department of Healthcare and Family Services identify capitation payments made on behalf of deceased beneficiaries before and after our audit period, and repay the Federal share of amounts recovered.

We recommend that the Agency refund to the Medicare program the portion of the $1,262,887 in estimated overpayments received during CYs 2014 and 2015 for claims incorrectly billed that are within the reopening and recovery periods

We recommend that the Agency strengthen its controls to ensure full compliance with Medicare requirement for billing home health services.

We recommend that ACF revise its policies and procedures to improve the information that it has to oversee the Tribal grantees. Specifically, we recommend that ACF enhance its policies and procedures to ensure that it can determine whether Tribal grantees: ensure that obligated grant funds are used to provide energy assistance to eligible beneficiaries (rather than being held as credit balances at energy suppliers) and that these funds can be traced to the year of obligation; maintain adequate supporting documentation for LIHEAP obligations and track and verify that prepayments made to energy suppliers are then used to provide services to eligible households; and ensure that energy suppliers return to the Tribes all unused grant funds prior to the end of each FY, thereby enabling the Tribes to re-obligate those funds for allowable LIHEAP purposes within the grant period.

We recommend that ACF educate Tribal grantees on ways to use grant funds to provide the maximum available benefits to eligible households and for other purposes of the program, such as crisis situations, residential weatherization, and energy-related home repairs.

We recommend that ACF review all FFRs, Carryover Reports, and Household Reports to ensure that the reports are complete, are submitted in a timely manner, and are properly supported.

We recommend that the Food and Drug Administration finalize and implement formal policies and procedures for resolving program and IT audit recommendations, similar to the Framework that FDA has implemented for resolving Single Audit recommendations, which include issuing management decisions and submitting related OCDs to OIG within the required 6-month resolution period.

We recommend that the Food and Drug Administration reconcile each month the OIG stewardship reports (or the HHS electronic Single Audit recommendation listing for audits processed on or after October 1, 2018) with FDA's audit resolution records and follow up on any differences noted.

Update its policies and procedures manual to reflect current Unit practices for periodic supervisory case file review.

Ensure that the case management system includes documentation of supervisory oversight.

We recommend that the Connecticut Department of Social Services refund to the Federal Government $1,065,387 (Federal share) for claims for single source physician-administered drugs that were ineligible for Federal reimbursement.

We recommend that the Connecticut Department of Social Services work with CMS to determine the unallowable portion of $2,380,355 (Federal share) for other claims for outpatient physician-administered drugs that were submitted without NDCs or with invalid NDCs and that may have been ineligible for Federal reimbursement and refund that amount.

We recommend that the Connecticut Department of Social 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, 2016.

CMS should work to ensure that individual beneficiaries can be uniquely identified at a national level using T-MSIS.

CMS should clarify requirements for diagnosis codes.

We recommend that Southwest Key review facilities' video monitoring and identify potential areas for improvement and work with ORR, if needed, to obtain the necessary video monitoring equipment.

We recommend Southwest Key inspect facilities to ensure that all hazardous materials are maintained in a secure location, and educate staff on the importance of keeping hazardous materials secured.

We recommend that Southwest Key comply with ORR staffing ratios to ensure that children receive the necessary case manager and clinician services.

We recommend that Southwest Key ensure that all facilities with gas appliances have carbon monoxide detectors installed.

We recommend that Southwest Key strengthen procedures to ensure severe weather drills are conducted in Texas, develop and enact a plan to for conducting disaster drills at facilities in California and Arizona, and monitor these requirements on a regular basis to ensure compliance with State laws.

We recommend Southwest Key develop policies and procedures to ensure consistency in the data used to compile the Annual Performance Report, and strengthen quality control procedures to ensure that the data in the UAC Portal and the effort-to-outcomes system is accurate and matches.

We recommend Southwest Key ensure that all required SORC are conducted nationally through the DOJ NSOPW when screening sponsors, adult household members, and adult caregivers.

We recommend Southwest Key maintain documentation to support that discharge notifications were emailed to DHS and other stakeholders.

We recommend Southwest Key ensure that out-of-State CPS checks are completed for employees in Arizona who resided in State(s) outside of Arizona in the past 5 years, because these checks are not conducted by the State of Arizona and should not be covered under the waiver.

We recommend Southwest Key review current staff and complete CPS checks for those staff that lived outside of their current State of residence in the past 5 years, and develop policies and procedures to ensure CPS checks are conducted for potential employees in State(s) of residence for the past 5 years.

CMS should collaborate with partners to develop strategies for improving rates of followup care for children treated for ADHD.

CMS should analyze the effectiveness of strategies for improving rates of followup care for children treated for ADHD.

ACF should evaluate whether States are ensuring equal access for CCDF families, as required.

ACF should establish a forum for States to share strategies regarding how they set payment rates to ensure equal access for eligible families while balancing competing program priorities.