Recommendations Tracker

We recommend that the Food and Drug Administration consistently implement its existing policies and procedures and use existing checklists to ensure that contractor performance assessments are completed and uploaded to the Contractor Performance Assessment Reporting System timely.

We recommend that the Food and Drug Administration evaluate internal procedures and documents for key contracting decisions and activities to verify that all supporting contract documents are based on current HHS and FDA policies and procedures.

We recommend that the Food and Drug Administration should consistently implement its existing policies and procedures and use existing checklists to ensure that the appropriate contracting documents and supporting documents are uploaded to the Purchase Request Information System (PRISM).

CMS should improve how surveys identify infection control risks to nursing home residents and strengthen guidance on assessing the scope and severity of those risks.

We recommend that National Government Services, Inc. increase Medicare's share of the UGS Medicare segment excess pension liabilities as of December 31, 2018, by $69,360 and recognize $510,580 as Medicare's share of the pension liabilities as a result of the benefit curtailment.

We recommend that National Government Services, Inc. decrease Medicare's share of the Plan A Medicare segment excess pension liabilities as of December 31, 2018, by $47,508 and recognize $657,263 as Medicare's share of the pension liabilities as a result of the benefit curtailment.

We recommend that National Government Services, Inc. decrease Medicare's share of the Plan B Medicare segment excess pension assets as of December 31, 2018, by $435,942 and recognize $374,464 as Medicare's share of the pension assets as a result of the benefit curtailment.

We recommend that Cigna-HealthSpring of Tennessee, Inc. identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before and after our audit period and refund any resulting overpayments to the Federal Government.

Develop and implement procurement policies and procedures to avoid acquiring unnecessary items and to perform analyses to determine the most reasonable approach for future vehicle purchases.

We recommend that the State agency enhance the monitoring of provider compliance by conducting periodic reviews of telehealth payments for compliance with requirements.

Review all pediatric skilled nursing service requests for which overnight care was completely denied and determine whether the overnight care requests meet the medical necessity requirement regardless of whether the caregiver provided work or school verification documentation.

We recommend that the Pennsylvania Department of Human Services, Office of Medical Assistance Program, revise the initial denial notice template referenced under Exhibit N in the HealthChoices Agreement to include information regarding the beneficiary's right to request a State fair hearing after exhausting the MCO's appeals process.

We recommend that CMS re-educate providers on the requirement for all home health claims to be submitted with the FIPS code for the county where the service was provided.

CMS should issue guidance to reiterate State obligations under the EPSDT benefit to ensure access to services to correct or ameliorate confirmed blood lead levels identified during screenings.

FDA should complete its rulemaking on non-face-to-face sales of tobacco products, as required by the Tobacco Control Act.

FDA should publish information and performance data on its oversight of online tobacco retailers.

We recommend that the Centers for Medicare & Medicaid Services instruct the MACs to, based on the results of this audit, notify appropriate providers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the providers 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.

We recommend that the Centers for Medicare & Medicaid Services update its Medicare requirements and corresponding educational material to improve providers' understanding of the Medicare Part B billing requirements for co-surgery procedures, including: updating the Medicare Claims Processing Manual, chapter 12, section 40.8, to ensure billing providers understand that two physicians performing procedures as co-surgeons (including bilateral procedures) must append the co-surgery modifier regardless of whether they are in the same specialty or in different specialties, and providing additional education material to providers clarifying that spinal instrumentation procedure codes must be billed with a co-surgery modifier under Medicare Part B when performed as a co-surgery.