Recommendations Tracker

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 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.

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.

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.

We recommend that Cigna HealthSpring of Florida, Inc. refund to the Federal Government $39,612 of net overpayments.

We recommend that the National Institutes of Health improve its procedures to ensure that responsible parties of NIH-funded clinical trials comply with requirements to submit results to ClinicalTrials.gov in a timely manner.

We recommend that the National Institutes of Health work with the responsible parties to understand the challenges they face when submitting their results to ClinicalTrials.gov and implement procedures to address the challenges.

Refund to the Federal Government $14,281,626 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.

Work with CMS to determine the unallowable portion of $1,328,195 (Federal share) for other claims for multiple-source physician-administered drugs that may have been ineligible for Federal reimbursement, refund that amount, and consider invoicing drug manufacturers for rebates for these drugs if CMS determines that the drug claims are allowable.

Continue to review and strengthen its internal controls to ensure that all physician-administered drugs eligible for rebates are invoiced.

CMS should encourage Part D plans to increase access to and use of the authorized generic versions of Epclusa and Harvoni, within the authorities granted under statute.

We recommend that the Centers for Medicare & Medicaid Services instruct SSAs to follow up with the 28 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 Centers for Medicare & Medicaid Services provide training to SSAs on the updated phase three interpretive guidance as soon as feasible.

We recommend that the Centers for Medicare & Medicaid Services continue its efforts to recover any collectible portion of the $226 million in uncollected overpayments and inform us of any additional collections related to this amount.

We recommend that the Centers for Medicare & Medicaid Services determine what portion of the $152,510,191 (footnote 25) was collected and recorded in its accounting system based on policies established in response to our recommendation in the previous bullet.

We recommend that the Centers for Medicare & Medicaid Services ensure that employees follow established policies and procedures for verifying that collection information is accurately and consistently recorded.

We recommend that the Centers for Medicare & Medicaid Services revise 42 CFR section 405.980 and corresponding manual instructions related to the reopening period for claims to be consistent with statutory provisions contained in section 1870 of the Social Security Act, which allows Medicare contractors to determine whether overpayments were made and to begin to collect them for 5 years following the year payments were made.

We recommend that the Centers for Medicare & Medicaid Services develop a plan, with milestones, for reconciling cost reports applicable to nine audit reports discussed in Appendix B of this report.

We recommend that Lahey Clinic, Inc. refund to the MAC $6,015 in overpayments for critical care services.

We recommend that Lahey Clinic, Inc. strengthen its policies and procedures to ensure that critical care services billed to Medicare are adequately documented and correctly billed by: providing training to critical care physicians to ensure the services they identify for coding review meet Medicare requirements for critical care services; providing training to coders to ensure they assign the appropriate CPT code for critical care or another E/M service based on their review of the medical record documentation; and developing an internal quality control review process to determine the accuracy of coders who review services identified as critical care services.

We recommend that Cariten Health Plan, Inc. refund to the Federal Government the $9,212,531 of estimated net overpayments.

We recommend that Cariten Health Plan, Inc. 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.

We recommend that the Centers for Medicare & Medicaid Services work with State survey agencies to require mandatory participation in standardized life safety training for nursing home staff.

We recommend that the Centers for Medicare & Medicaid Services propose regulations requiring carbon monoxide detectors to be installed in accordance with NFPA 72 and 720 for all nursing homes that utilize fuel-burning appliances or have an attached garage.