Recommendations Tracker

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.

We recommend that HHS develop department-wide objectives and a strategic framework for responding to international public health emergencies.

We recommend that HHS develop large-scale international response plans that include working with OPM to develop guidelines that would allow HHS to request and receive direct hiring authority during an international health response; working with DoS to develop a process to streamline overseas deployment of HHS staff during an international health crisis; updating the training and preparation needed for certain HHS staff to be readily deployable for international emergencies—both DoS-required clearances and training on infectious diseases; updating the training course developed during this crisis to train Commissioned Corps staff in the handling of infectious diseases to prepare staff for future response efforts; working with OMB to determine the viability of a contingency fund for international response efforts when congressionally requested funds are not immediately available; and establishing communication protocols for responding to an international crisis that identify key communica

We recommend that HHS work with other U.S. Government agencies to develop a flexible framework focusing on each agency's mission and define each agency's roles and responsibilities for responding to a multi-agency international public health emergency.

We recommend that Administration for Community Living determine whether it can allocate its funds differently to enable onsite compliance reviews.

We recommend that the Administration for Community Living perform the required onsite compliance reviews of independent living programs.

To avoid payments after a beneficiary's death, we recommend that the Georgia Department of Community Health use additional sources of date of death to help reduce the risk of making payments after a beneficiary's death.

To avoid payments after a beneficiary's death, we recommend that the Georgia Department of Community Health continue to identify payments made after a beneficiary's death to prevent additional payments similar to the $2,168,278 identified in this report.

We recommend that the Pennsylvania Department of Human Services work with the MCOs to determine the portion of the $43,524,609 that was unallowable for claims containing PPCs and its impact on current- and future-year capitation payment rates.

We recommend that the Pennsylvania Department of Human Services enforce the provisions in its managed-care agreements that allow sanctions or penalties to be imposed for noncompliance with or failure to meet performance and program standards indicated in the contract and subsequent related agreements.

We recommend that the Pennsylvania Department of Human Services require the MCOs to review all claims for inpatient hospital services that were paid after our audit period to determine whether any payments for services related to treating PPCs were unallowable and adjust future capitation payment rates for any unallowable payments identified.

We recommend that the Pennsylvania Department of Human Services take steps to ensure that the MCOs comply with Federal and State requirements and its managed-care contracts relating to the nonpayment of PPCs.

We recommend that GHI increase the GHI Cash Balance Plan Medicare segment pension assets by $366,763 and recognize $939,629 as the Cash Balance Plan Medicare segment pension assets as of January 1, 2011.

We recommend that GHI increase the EHS Retirement Plan Medicare segment pension assets by $432,584 and recognize $5,633,345 as the EHS Retirement Plan Medicare segment pension assets as of January 1, 2015.

We recommend that GHI decrease the Local 153 Medicare segment pension assets by $2,421,309 and recognize $31,821,914 as the Local 153 Medicare segment pension assets as of January 1, 2015.

Review Unit caseload management practices and develop an action plan to lower staff members' caseloads and maximize effectiveness.

IHS should as a management priority, develop and implement a staffing program for recruiting, retaining, and transitioning staff and leadership to remote hospitals.

IHS should continue to take steps to ensure early intervention when IHS identifies problems at hospitals.

CMS should review the impact of programmatic changes on ACOs' ability to promote value-based care.

CMS should adopt outcome-based measures and better align measures across programs.

CMS should identify and share information about strategies that integrate physical and behavioral health services and address social determinants of health.

CMS should prioritize ACO referrals of potential fraud, waste, and abuse.

We recommend that SAMHSA finalize and follow its policies and procedures related to the audit resolution process to ensure that all management decisions are issued within the required 6-month resolution period.

We recommend that SAMHSA 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 SAMHSA's audit resolution records and follow up on any differences noted.

We recommend that IHS revise the IHM to include the type of action a provider should take and what documentation to include in the patient's EHR when a UDS is unfavorable.

We recommend that IHS increase oversight of IT systems by IHS management, including consideration of centralizing its key IT systems (including RPMS), services, and cybersecurity functions (e.g., patch management, unsupported network equipment and contingency planning) by conducting a cost-benefit analysis and risk assessment of adopting the Cloud First Policy and other means of centralization (e.g., headquarters, area offices). Specifically, determine if a cloud solutions or other modernization approaches are most effective and cost efficient in addressing persistent cybersecurity vulnerabilities and increasing network resiliency.

We recommend that IHS implement a strategic and phased approach to centralization of IT systems, services and cybersecurity functions.

We recommend that IHS work with hospitals to develop policies and procedures to review the EHRs of patients with opioid prescriptions from non-IHS providers and document the results of the review in the EHR, particularly for those patients who had previously violated their COT agreements.

We recommend that IHS work with hospitals to ensure all opioids are in a locked cabinet, safe, drawer, or other appropriate secure container at all times.

We recommend that IHS work with hospitals to analyze opioid data to make decisions and oversee providers to minimize prescribing practices that exceed daily MME guidelines established by IHS, co-prescribe opioids and benzodiazepines, and use opioids for acute pain.

We recommend that IHS work with area offices to renegotiate the MOU with Oklahoma and other States that have restrictive MOU language to allow for PDMP self-audits and collection by clinical directors.

We recommend that IHS should assign a centralized team (e.g., headquarters, area office) to: Ensure patches are deployed timely to all IHS end points in accordance with NIST guidance and IHS policies and procedures.

We recommend that IHS should assign a centralized team (e.g., headquarters, area office) to: Securely configure and monitor wireless access points at all IHS hospitals.

We recommend that IHS should ensure that all devices on IHS's network are scanned for vulnerabilities, scan reports reviewed by appropriate computer personnel, track vulnerability remediation, and ensure that vulnerabilities are remediated in a timely way.

We recommend that IHS should ensure that all hospitals: Store backup tapes off-site in accordance with Federal guidelines.