Recommendations Tracker

We recommend that the Centers for Medicare & Medicaid Services provide States with matched T-MSIS enrollment data that identify Medicaid beneficiaries who were concurrently enrolled in a Medicaid managed care program in two States.

We recommend that the Centers for Medicare & Medicaid Services direct the MACs to recover the $331,448 from the CAHs for 12,156 claims for which the health care practitioners had not reassigned their billing rights to the CAHs and $83,412 in cost-sharing overcharges to Medicare beneficiaries that are within the 4-year reopening period.

We recommend that the Centers for Medicare & Medicaid Services request that relevant providers 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 direct the MACs to educate CAHs on their obligation not to bill for professional services when health care practitioners do not reassign billing rights to the CAH.

FDA should assess and, as appropriate, revise FDA guidance for test Emergency Use Authorization (EUA) submissions.

FDA should expand the Center for Devices and Radiological Health's existing device-tracking platform to facilitate Emergency Use Authorization (EUA) submission and monitoring.

FDA should establish formal communication channels between FDA and the lab community, to be used in emergencies that require testing.

We recommend that IHS's NSSC strengthen internal controls by developing and implementing written policies and procedures for emergency situations when normal NSSC supply distribution processes are not possible or must be augmented.

We recommend that IHS's NSSC upgrade its inventory management system software to improve its ability to interface with IHS Areas, other customers, and third-party vendors.

We recommend that the Centers for Medicare & Medicaid Services instruct SSAs to follow up with the 23 nursing homes that we have identified with possible infection prevention and control and emergency preparedness deficiencies to verify that they have taken corrective actions.

We recommend that the Tennessee Department of Finance & Administration invoice for and collect manufacturers' rebates totaling $16,805,782 ($10,996,932 Federal share) for single-source and top-20 multiple-source physician-administered drugs and refund the Federal share of rebates collected.

We recommend that the Tennessee Department of Finance & Administration strengthen internal controls for non-crossover claims to ensure that all eligible physician-administered drugs are invoiced for rebate in a timely manner.

We recommend that Regence BlueCross BlueShield of Oregon refund to the Federal Government the $1,890,855 of estimated net overpayments.

We recommend that Regence BlueCross BlueShield of Oregon continue to examine its existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk for being miscoded comply with Federal requirements (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

ACF should develop and implement a plan that supports ORR and its contractors in securing qualified case managers during an influx to help ensure children's safe and timely release to sponsors.

ACF should create an emergency policy development protocol that provides for adequate input from staff with expertise in child welfare when ORR develops field guidance during an influx.

ACF should ensure that ORR's employees and employees of ORR contractors and recipients are informed about Federal whistleblower protections.

We recommend that the New York State Department of Health refund the estimated $84,329,893 to the Federal Government for payments that did not comply with Federal and State requirements.

We recommend that the New York State Department of Health improve its oversight of its NEMT program to ensure that the transportation manager strengthen its procedures to ensure that (1) prior authorization documentation, including medical practitioner's orders are properly completed and maintained; (2) transportation providers do not bill for transport on a date when a beneficiary does not receive a Medicaid-covered service; (3) transportation providers document that drivers and vehicles used to transport Medicaid beneficiaries meet applicable State requirements; (4) NEMT services are adequately documented; (5) transportation providers bill only for services that are actually provided; and (6) transportation providers bill for the level of service authorized.

The Indian Health Service should develop a strategy for expeditiously deploying a new information system when it is necessary to meet an urgent, mission-critical need. The strategy should define the minimum set of controls out of the total number of required controls that should be addressed and, if applicable tested, before the new system is authorized to operate until it is feasible to address all required controls. The authorization to operate should include an acceptance of risk for not implementing all required controls, specify a date by which the remaining required controls will be implemented and tested, and be replaced with a new authorization to operate once all the required controls have been addressed.

Develop and implement outreach efforts to ensure that the Unit regularly receives referrals of patient abuse and neglect.

Conduct and document supervisory reviews of case files in accordance with Unit policy.

We recommend that the Administration for Strategic Preparedness and Response establish written policies and procedures regarding the roles and responsibilities for organizational communication between ASPR and federally established emergency response team lead agencies.

We recommend that the Administration for Strategic Preparedness and Response: develop and implement policies and procedures to help ensure the accurate reporting of contract data in FPDS.

CMS should lower Medicare's payment rates for intermittent urinary catheters.

We recommend that the Municipality of Barceloneta complete its integration of the Head Start program's accounting system to the Municipality's electronic accounting system.

We recommend that the Municipality of Barceloneta reinforce existing policies and procedures to ensure that drawdowns for the Head Start program are based on a valid voucher.

We recommend that the Municipality of Barceloneta ensure that criminal background checks on employees and contractors that have direct contact with children are completed within required time frames.

CMS should strengthen monitoring and targeted oversight of telehealth services.

CMS should improve the transparency of "incident to" services when clinical staff primarily delivered a telehealth service.

CMS should follow up on the providers identified in this report.

We recommend that HRSA develop additional oversight controls and procedures (e.g., deliverable schedules, compliance assessments, and monitoring) to ensure that the OPTN contractor complies with all Federal cybersecurity requirements and implements security controls over the OPTN in an effective and timely manner.

We recommend that WellCare of Florida, Inc. refund to the Federal Government the $3,518,465 of estimated net overpayments.

We recommend that WellCare of Florida, Inc. continue its examination of existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk for being miscoded comply with Federal requirements (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

CMS should take appropriate steps to enable a successful transition from current pandemic-related flexibilities to well-considered longterm policies for the use of telehealth for beneficiaries in urban areas and from the beneficiary's home.

CMS should require a modifier to identify all audio-only telehealth services provided in Medicare.

We recommend that the Montana Department of Public Health and Human Services refund to the Federal Government $5,065,966 (Federal share) in overpayments.

We recommend that the Montana Department of Public Health and Human Services require TCM providers to comply with established policies and procedures in order to ensure that case managers who render TCM services to recipients have the experience required by the State plan supplement; TCM providers maintain documentation to support the TCM services rendered; TCM providers maintain documentation to support that case managers are qualified to perform TCM services; the State agency does not pay TCM providers or claim Federal Medicaid reimbursement for services that are not allowable TCM services; and recipients receiving TCM services are eligible to receive those services.

We recommend that the Nevada Department of Health and Human Services ensure that child care providers notify DPBH when a new household member is added or a new employee is hired so that the State may conduct the required criminal background checks.

We recommend that the Nevada Department of Health and Human Services ensure that all required criminal background checks are conducted for all employees who are under the age of 18.

We recommend that the Nevada Department of Health and Human Services add a written requirement and policy to conduct the in-State sex offender registry check, as required by Federal regulations, for all child care staff members.