Recommendations Tracker

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.

We recommend that the State agency redetermine, as appropriate, the current Medicaid eligibility status of the sampled beneficiaries who did not meet Federal and State eligibility requirements.

We recommend that the State agency maintain the necessary documentation to determine whether it enrolled individuals who did not meet Federal and State Medicaid eligibility requirements, which could have resulted in up to $1,297,308,200 in potentially improper Federal Medicaid payments over the 6-month audit period.

We recommend that CDSS refund the overpayment of $350 to the Federal Government.

CMS should ensure that all States fully implement fingerprint based criminal background checks for high risk Medicaid providers.

CMS should compare high risk Medicaid providers' self reported ownership information to Medicare's provider ownership information to help States identify discrepancies.

We recommend that the State agency work with providers to improve their facilities, staffing, and training.

We recommend that the State agency ensure that providers correct the 63 instances of provider noncompliance identified in this report.

CMS should expand the deficiency data that accrediting organizations report to CMS and use these data to strengthen its oversight of hospices.

CMS should include on Hospice Compare the survey reports from State agencies.

CMS should educate hospices about common deficiencies and those that pose particular risks to beneficiaries.

CMS should strengthen requirements for hospices to report abuse, neglect, and other harm.

CMS should strengthen guidance for surveyors to report crimes to local law enforcement.

CMS should improve and make user-friendly the process for beneficiaries and caregivers to make complaints.

We recommend that the New York State Department of Health refund $466,614 to the Federal Government.

We recommend that the New York State Department of Health ensure providers properly train personnel to appropriately claim Medicaid reimbursement for NHTD waiver program services.

We recommend that the New York State Department of Health refund $65,468,943 to the Federal Government.