Recommendations Tracker

Refund to the Federal Government the portion of the estimated $140,370,745 for hospice services that did not comply with Medicare requirements and that are within the 4-year claims reopening period.

Strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

CDC should expand its efforts both to improve racial and ethnic data associated with COVID-19 and to supplement them with additional data sources.

ACF should work with States to improve compliance with requirements to screen children who return to foster care after going missing to identify whether they are victims of sex trafficking.

ACF should conduct oversight activities to identify States that may not screen all children for sex trafficking when they return to foster care after going missing.

Remediate the vulnerabilities identified on internet-facing systems and implement procedures to ensure compliance with BOD 19-02 requirements.

Implement oversight to ensure corrective actions are performed in accordance with Federal requirements and in the timeframe set forth in CMS policy.

We recommend that the Food and Drug Administration identify and implement additional ways to improve the timeliness of its foreign for-cause drug inspection process.

We recommend that the Food and Drug Administration conduct an analysis of the workloads of individuals responsible for: (1) determining final classification, (2) issuing warning letters, and (3) holding regulatory meetings, and address any potential issues identified by this analysis.

We recommend that the Food and Drug Administration ensure that supervisors review investigators' qualifications and document that they meet applicable training requirements when the investigator training records do not exist.

We recommend that the New Hampshire Department of Health and Human Services refund $7,943,271 to the Federal Government.

We recommend that the New Hampshire Department of Health and Human Services improve communication with providers regarding the State requirements for OUD treatment and provide written confirmation to providers about whether offsite counseling may be included as a required counseling service.

We recommend that the Office of Refugee Resettlement develop a process to clearly communicate COVID-19 guidance and updates to the appropriate staff at the EISs so that staff have a full understanding of what is required of them to help protect against the spread of COVID-19.

We recommend that the Office of Refugee Resettlement improve and increase training provided to facilities regarding COVID-19 mitigation strategies.

Assess the adequacy of existing staffing levels, and if warranted, develop a plan to expand the size of the Unit

We recommend that CMS pursue legislative or regulatory changes to lower costs for both the Medicare program and beneficiaries, by equalizing payments as appropriate between provider based facilities and freestanding facilities for E&M services.

We recommend that the Maine Department of Health and Human Services continue to work with CMS to fully implement the prior recommendation to ensure that followup reports are submitted by community-based providers appropriately.

CMS should develop its own source of race and ethnicity data.

CMS should develop a process to ensure that the data are as standardized as possible.

NIH should ensure that grantees comply with Federal requirements to train investigators regarding disclosure of significant financial interests.

NIH should specifically require grantees to provide trainings and maintain a written policy regarding investigators' disclosure of other support.

NIH should conduct outreach to grantees with R13 conference grants to clarify requirements regarding the disclosure and review of investigators' significant financial interests and other support.

NIH should establish a method for grantees to share their best practices for identifying and reviewing investigators' foreign significant financial interests and other support.

We recommend that CAS update its Review Guide to conform with applicable Federal regulations and CAS internal policies and procedures.

We recommend that CAS include all federally required documents on checklists provided to the nonprofit organizations and on checklists used by CAS officials.

We recommend that CAS seek clarification on whether the policy of including executive compensation higher than the Level II statutory cap in its indirect cost pool calculation complies with Federal law and governmentwide policy.

We recommend that the Centers for Medicare & Medicaid Services instruct the DME MACs to recover $41,137 in overpayments for PMD repairs made to PMDs that belonged to 76 sampled beneficiaries.

We recommend that the Centers for Medicare & Medicaid Services instruct the DME MACs to based upon the results of this audit, notify appropriate suppliers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the suppliers 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 work with the DME MACs to do the following, which could have saved Medicare an estimated $7,948,182 during our audit period: implement a system edit that applies to all PMD repairs and identifies PMD repairs for review of supplier documentation to help ensure that PMD repairs are adequately documented and that the PMD repair charges are reasonable and necessary.

We recommend that the Centers for Medicare & Medicaid Services establish Medicare requirements that: (1) include the documentation standards established by guidance for PMD repairs; (2) specify that accumulated costs of repairs made to power wheelchairs during their 5 year RUL must not exceed a certain threshold; and (3) specify that suppliers must provide warranties for repairs made to PMDs, which could have saved Medicare an estimated $3,739,346 during our audit period.

We recommend that Peoples Health Network refund to the Federal Government the $3,312,219 in estimated overpayments.

We recommend that Peoples Health Network enhance 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 Vanderbilt University Medical Center refund to the Medicare contractor the portion of the $686,500 in estimated outpatient outlier net overpayments for incorrectly billed claims that are within the 4-year reopening period.

We recommend that Vanderbilt University Medical Center improve procedures and provide education to staff to ensure that claims billed to Medicare are accurate.

We recommend that the Texas Health and Human Services Commission report and return the Federal share for the 26 cases, totaling $19 million ($11.1 million Federal share).

We recommend that the Texas Health and Human Services Commission ensure that it reports all MFCU-determined Medicaid overpayments in accordance with Federal regulations and within regulatory timeframes.

We recommend that the Washington State Health Care Authority refund to the Federal Government $374,579 for managed-care health home service encounters that were no longer supported.

We recommend that the Washington State Health Care Authority determine the portion of the remaining $1,367,120 that should have been claimed for managed-care health home service expenditures based on the portion of the MCOs' capitation payment rate that was specifically attributable to health home services, and refund any unallowable amounts.

We recommend that the Washington State Health Care Authority review all managed-care health home encounters from July 1, 2013, through March 31, 2017, to identify whether the encounters used to support claims for enhanced Federal reimbursement have since been removed from the encounter data and refund to the Federal Government any amounts that are no longer supported.

We recommend that the Washington State Health Care Authority implement a procedure to identify whether encounters used to support journal vouchers have been removed from the encounter data and refund to the Federal Government any Federal reimbursement that was claimed and is no longer supported.

CMS should ensure that participating States submit accurate quarterly reports.

We recommend that HHS either (1) implement a risk assessment strategy that ensures that all programs with annual outlays greater than $10 million are risk assessed at least once every three years or (2) work with OMB to develop an approach and obtain concurrence to perform risk assessments at a level that meets the intent of PIIA. As HHS has 236 programs that exceed the $10 million threshold in FY 2021, HHS should consider what additional resources are needed to perform these risk assessments for an organization as large and complex as HHS or what enhancements can be made to the current process to reduce the time and effort to risk assess each program.

We recommend that HHS continue to work with OMB and other relevant stakeholders, to complete the improper payment measurement program for the Federally facilitated Exchange in FY 2022. We also recommend that HHS continue to make progress in the development of an improper payment measurement methodology for the State-based Exchange to report an accurate improper payment estimate.

We recommend that HHS focus on the root causes of the improper payment percentage and evaluate critical and feasible action steps to assist states with their compliance efforts for these new requirements. This would include working with the states to bring their respective systems into full compliance with the requirements to decrease the improper payment rate percentage below 10 percent. HHS should work with the states to follow up on repeat root causes for errors and enhance the CAPs for implementation. In addition, as HHS reviews only 17 states each year for the Medicaid and CHIP improper payment rate, HHS should continue to follow up with states during the interim period to verify that corrective actions identified after the improper PERM review are being implemented. HHS should also consider sharing corrective action best practices across states to help address these issues.

We recommend that HHS improve its recovery audit efforts as required under PIIA Section 2(i), to identify and recoup overpayments for Medicare Part C and Medicare Part D unless not deemed cost effective. HHS should also continue to explore alternative vehicles to conduct recovery audits that will fit into the larger Medicare Part C and Medicare Part D programs in FY 2022 in the event that the RADV and PPI-MEDIC programs cannot effectively serve as HHS's sole recovery audit strategies.