Recommendations Tracker

We recommend IHS deem a risk of the lack of continuity of operations to be unacceptable and take immediate action to assess all IHS facilities and ensure each facility has a tested and viable continuity of operations program to respond to and recover from a range of disasters.

We recommend that IHS develop and implement logical access-control procedures to ensure compliance with the principle of least privilege and conduct periodic privilege-based access reviews to remove unnecessary access to RPMS.

We recommend that IHS identify all hospitals with unsupported networking equipment and implement a system development life cycle plan to ensure hardware and software replacement before EOL.

We recommend that IHS ensure that all vulnerabilities identified during vulnerability scanning are remediated in accordance with Federal requirements.

Our reviews of claims covering CYs 2010 through 2014 showed that providers incorrectly billed diagnosis code 260 for Kwashiorkor for inpatients who did not have the disease. On October 31, 2009, AHA published its Third Quarter 2009 Coding Clinic. In response to a question about claims containing two malnutrition codes, AHA stated that diagnosis code 260 is for Kwashiorkor only. This discrepancy in the coding classification was corrected with the issuance of the ICD-10 codes on October 1, 2015. While our reviews have successfully returned $5,684,016 of the $6,030,135 to the Medicare Trust Funds to date, we estimate that Medicare could have saved approximately $102 million from CY 2006 through CY 2014 if the coding discrepancy had been immediately corrected. Therefore we recommend that CMS formalize procedures for notifying providers of the correct way to bill diagnosis codes when there is a discrepancy in the coding classification between the alpha index and the tabular list.

We recommend that the State agency work with CMS to determine the allowable amount of the remaining $306,233,377 set-aside because the rates included unallowable costs that could not be quantified.

We recommend that CMS ensure that suppliers have the applicable licenses for the specific competitions in which they are submitting a bid by continuing to work with State licensing boards, as recommended in our previous report.

We recommend that Texas Medicaid review capitation payments before and after our audit period for additional unallowable payments for these deceased beneficiaries.

We recommend that Texas Medicaid strengthen its policies and procedures for identifying deceased beneficiaries and denying Medicaid benefits and ending eligibility to prevent future unallowable payments.

We recommended that the State agency ensure that future changes to Medicaid payment methodologies comply with the Medicaid State plan.

We recommend that the Hospital exercise reasonable diligence to identify and return any additional similar overpayments received 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.

We recommend that the State agency refund to the Federal Government $917,519 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.

We recommend that the State agency work with CMS to determine whether the remaining $128,057 (Federal share) of other physician-administered drug claims could have been invoiced to the manufacturers to receive rebates and, if so, upon receipt of the rebates, refund the Federal share of the manufacturers' rebates for those claims.

We recommend that the State agency 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, 2014.

We recommend that the State agency work with counties to ensure the health and safety of vulnerable adults by considering staffing standards and caseload thresholds for county agencies.

We recommend that the State agency ensure that State guidance accurately reflects administrative requirements related to hazardous materials to ensure the health and safety of vulnerable adults.

We recommend that FCSO increase the Other segment allocable pension costs used to calculate its indirect cost rates for CYs 2008 through 2010 by $1,205,848.

We recommend that FCSO establish policies and procedures to ensure compliance with Federal regulations and the pension segmentation language of the Medicare contracts.

We recommend that Southeast Arkansas Community Action Corporation complete bank reconciliations in a timely manner, and properly segregate duties associated with bank reconciliations.

We recommend that Southeast Arkansas Community Action Corporation follow its existing purchasing policy to submit a purchase requisition 1 week in advance, as well as expand its purchasing policies to include (1) an individual assigned to review credit card purchases on a monthly basis and (2) a policy establishing consequences for employees who make unauthorized purchases.

We recommend that Southeast Arkansas Community Action Corporation work with the Office Head Start to ensure that shared costs claimed during our audit period are allocated correctly, document its methodology for allocating shared costs, develop a written policy that explains how to perform cost allocations, and require a second level of  review for cost allocations to ensure the application of correct data to properly allocate costs.

We recommend that Southeast Arkansas Community Action Corporation elect members to the board of directors who have legal and financial expertise or retain the services of a consultant with relevant expertise.

We recommend that CMS implement system enhancements to identify, adjust, and recoup improper capitation payments in the future.