Recommendations Tracker

We recommend that the State agency refund $10,930,063 to the Federal Government, consisting of $1,496,725 (Federal share) of capitation payments made on behalf of deceased beneficiaries who had a date of death recorded in the KEES, $8,264,519 (Federal share) of capitation payments made on behalf of deceased beneficiaries who did not have a date of death recorded in the KEES but who did have a date of death recorded in the DMF, and $1,168,819 (Federal share) in overreported Medicaid expenditures that were related to prior-period adjustments.

We recommend that the State agency identify and recover unallowable capitation payments made to MCOs during our audit period on behalf of deceased beneficiaries who did not have a date of death recorded in the KEES but who did have a date of death recorded in the DMF, which we estimate to be at least $14,648,662.

We recommend that the State agency strengthen internal controls, to include strengthening policies and procedures and enhancing training on the research and application of date-of-death information and other eligibility data, to ensure that the State agency's KEES is accurately updated based on information provided by Federal data sources, that the KEES generates tasks to update eligibility status of deceased beneficiaries, and that all eligibility update tasks are completed in a timely manner by State agency staff.

We recommend that the Centers for Medicare & Medicaid Services assess the costs and benefits of implementing the following recommendations and if CMS determines that the benefits outweigh the costs, take action to develop a process to identify nursing homes that do not report required data for all of the data elements related to COVID-19 cases and deaths among residents and staff and PPE and supplies and request that they submit the required data.

We recommend that the Centers for Medicare & Medicaid Services assess the costs and benefits of implementing the following recommendations and if CMS determines that the benefits outweigh the costs, take action to revise its quality assurance checks for ratios 2 and 4, which use the numbers of confirmed cases and admissions among residents and confirmed cases among staff in the denominator, by adding the number of suspected COVID-19 cases to the denominator in both ratios and adjust the ratios' thresholds to reflect the change.

We recommend that the Centers for Medicare & Medicaid Services assess the costs and benefits of implementing the following recommendations and if CMS determines that the benefits outweigh the costs, take action to contact nursing homes that failed quality assurance checks to verify the accuracy of reported data or to correct inaccurate data.

We recommend that the National Institutes of Health direct the National Human Genome Research Institute to improve its policies and procedures to ensure Grants Specialists monitor whether required audit reports are submitted for foreign applicants.

We recommend that the National Institutes of Health direct the National Human Genome Research Institute to update policies and procedures for Grants Specialists to require that they review available IRS Form 990s regarding grant applicants' risk factors before awarding grant funds.

We recommend that the Centers for Medicare & Medicaid Services work with the Medicare administrative contractors to educate providers about the documentation requirements for phlebotomy travel allowances.

We recommend that the Centers for Medicare & Medicaid Services issue regulations related to phlebotomy travel allowances clarifying: whether specimen collections refer only to specimens that were drawn by a technician or whether it includes all specimens that were drawn by another individual and were merely picked up by a technician; whether a specimen includes blood, urine, and micros; whether to prorate based on the number of patients or on the number of specimens; how to calculate mileage when a location is included without any specimens collected; and how to calculate mileage when personal miles are included (i.e., when to start or stop counting mileage) in their proration calculations.

We recommend that CGS work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare Excess Plan costs of $29,022 for CYs 2015 and 2016.

We recommend that CGS Administrators, LLC, work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare PRB costs of $2,239,967 for CYs 2012 through 2016.

We recommend that CDC develop and implement a written policy requiring periodic internal review of PEPFAR award files for compliance with HHS and CDC policies.

We recommend that CDC establish a policy requiring periodic reviews of, and updates to, the NOA link to ensure functionality, accuracy, and relevance of the content.

We recommend that Catholic Home Care refund to the Medicare program the portion of the estimated $4,232,959 overpayment for claims incorrectly billed that are within the 4-year reopening period.

We recommend that Catholic Home Care strengthen its procedures to ensure that beneficiaries are receiving only reasonable and necessary skilled and dependent services

We recommend that Jewish Hospital refund to the Medicare contractor $13,486,524 in estimated overpayments for the audit period for claims that it incorrectly billed that are within the 4-year claim reopening period.

We recommend that Jewish Hospital strengthen internal controls by: strengthening procedures to verify that all IRF beneficiaries meet Medicare criteria for acute inpatient rehabilitation, developing processes to ensure that procedure and diagnosis codes are supported in the medical records, providing additional training to inpatient and outpatient coding staff on the use of bypass modifiers, and developing procedures to verify that the use of bypass modifiers is supported in the medical records.

We recommend that CGS Administrators, LLC, work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare pension costs of $293,893 for CYs 2012 through 2016.

We recommend that CGS Administrators, LLC, work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare SERP III costs of $6,705 for CYs 2015 and 2016.

Repay Federal matching funds spent on the case that was ineligible for Federal funding.

Examine the Unit's intake process for complaints of patient abuse or neglect and identify improvements.

Develop and implement a plan to increase fraud referrals from the Medicaid agency and other sources.

Implement processes to ensure that it reports convictions and adverse actions to Federal partners within the appropriate timeframes.

Repay Federal matching funds spent on cases that were ineligible for Federal funding.

Work with the Mississippi Division of Medicaid to ensure the return of the Federal Government's share of all recoveries.

Develop written policies and procedures and take other steps to ensure that periodic supervisory reviews are conducted and documented in the case files.

We recommend that the Centers for Medicare & Medicaid Services review the findings in this report and, if it determines that a separate payment methodology for capital costs at new hospitals is no longer warranted, change its regulations to require new hospitals to have their Medicare capital costs paid through the IPPS with an option for payment adjustments or supplemental payments if necessary.

We recommend that the Oklahoma Health Care Authority consider whether more of an emphasis on counseling could improve OUD outcomes and, if so, take steps to increase the appropriate use of counseling with OUD drugs in outpatient OUD treatment.

We recommend that the Missouri Department of Social Services refund $3,411,531 to the Federal Government.

We recommend that Palmetto work with CMS to ensure that its final settlement of contract costs reflects an increase in Medicare pension costs of $998,912 for CYs 2012-2016.

We recommend that CDS work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare PRB costs for $73,594 for CYs 2012-2016.

We recommend that CDS work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare EP costs of $8581 for CYs 2015 and 2016.

We recommend that Palmetto work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare PRB costs of $2,848,586 for CYs 2012-2016.