Recommendations Tracker

ASFR should take steps to ensure that HHS's suspension and debarment program has more consistent senior leadership and sufficient staffing.

ASFR should develop and disseminate guidance regarding how to prepare and submit complete referrals.

CMS should actively monitor the use and effectiveness of States' corrective action plans and other remedies, with a focus on making the remedies specific and outcome oriented.

CMS should engage with senior State officials earlier and more frequently to address State performance problems.

CMS should revise the State Operations Manual to reflect current CMS practices in overseeing State survey performance.

We recommend that Healthfirst Health Plan, Inc. refund to the Federal Government the $5,221,901 of estimated net overpayments.

We recommend that Healthfirst Health Plan, Inc. identify, for the potentially mis-keyed diagnosis codes described in this report, similar instances of noncompliance that occurred during our audit period but were not included in our non-statistical sample and refund any resulting overpayments to the Federal Government.

We recommended that Noridian Healthcare Solutions, LLC, work with CMS to ensure that its final settlement of contract costs reflects an increase in Medicare pension costs of $620,072 for CYs 2014 through 2016.

We recommended that Noridian Healthcare Solutions, LLC, increase the Medicare segment pension assets by $1,207,983 and recognize $31,451,287 as the Medicare segment pension assets as of December, 31, 2016.

We recommended that Noridian Healthcare Solutions, LLC, increase the Medicare segment PRB assets by $197,098 as of January 1, 2017.

We recommend that Noridian Healthcare Solutions, LLC, work with CMS to ensure that its final settlement of contract costs reflects an increase in Medicare PRB costs of $1,531,023 for CYs 2014 through 2016.

We recommend that the Louisiana Department of Education ensure that providers initiate and complete criminal background checks for all required individuals, including those given access to children on a contingency basis.

CMS should evaluate the potential impacts of updating the DRG window policy to include affiliated hospitals, and seek the necessary legislative authority to update the policy as appropriate.

We recommend that the Arkansas Department of Human Services ensure that community-based providers report all suspected adult or child abuse and neglect to the appropriate adult or child abuse hotline.

We recommend that the Arkansas Department of Human Services follow waiver guidance to conduct reviews of the deaths of beneficiaries receiving waiver services.

We recommend that the Arkansas Department of Human Services perform analytical procedures, such as data matches, on Medicaid claims data to identify potential critical incidents that have not been reported and investigate as needed.

Refund to the Medicare contractor $389,973 in estimated overpayments for the audit period for claims that it incorrectly billed that are within the 4-year claim reopening period.

Strengthen internal controls by: strengthening procedures to verify that all inpatient beneficiaries meet Medicare requirements for inpatient hospital services, strengthening processes to ensure that diagnosis codes and HCPCS codes are supported in the medical records, and providing additional training to coding staff on DRG and HCPCS code assignments.

We recommend that the Food and Drug Administration deobligate $88,152 in contract funding and close the six contracts that remained open but eligible for closeout as of June 15, 2021.

We recommend that the FDA add language to the contract awards to require that contractors specify when an invoice is the final contract invoice.

FDA require that CORs communicate a change in COR to the contracting officer before the COR leaves the position.

CMS should conduct additional outreach to beneficiaries to increase awareness about Medicare coverage for the treatment of opioid use disorder.

CMS should assist SAMHSA by providing data about the number of Medicare beneficiaries receiving buprenorphine in office-based settings and the geographic areas where Medicare beneficiaries remain underserved.

CMS should create an action plan and take steps to address disparities in the treatment of opioid use disorder.

We recommend that the Centers for Medicare & Medicaid Services expand the IRF transfer payment policy to apply to early discharges to home health care. If this expanded policy had been in place, Medicare could have saved $993,134,059 in 2017 and 2018.

We recommend that the Centers for Medicare & Medicaid Services direct the MACs to recover $9,528,296 in improper payments made to physicians for selected facet-joint denervation sessions.

We recommend that the Centers for Medicare & Medicaid Services assess the effectiveness of oversight mechanisms specific to preventing or detecting improper payments to physicians for more than two facet-joint denervation sessions related to the lumbar spine or cervical/thoracic spine per beneficiary during a rolling year and modify the oversight mechanisms based on that assessment.

We recommend that the Centers for Medicare & Medicaid Services direct the MACs to review claims for facet-joint denervation sessions after our audit period to identify instances in which Medicare paid physicians for denervation sessions that exceeded the number of allowable sessions in a 12-month period (in accordance with the applicable LCDs) and recover any improper payments identified.

We recommend that the Kentucky Cabinet for Health and Family Services refund to the Federal Government $1,894,643 (Federal share) in unallowable payments.

We recommend that the Kentucky Cabinet for Health and Family Services enhance or establish new controls to ensure that no beneficiary is issued multiple Medicaid ID numbers.

We recommend that the Centers for Medicare & Medicaid Services update its PDE guidance to address margin under sponsor delivery models in which a sponsor owns a pharmacy.

CMS should provide training for nursing homes on Federal requirements for facility-initiated discharge notices.

CMS should implement its deferred initiatives to address inappropriate facility-initiated discharges.

ACL should establish guidance for analysis and reporting of data collected by State Ombudsman programs from facility-initiated discharge notices.

ACL and CMS should ensure that all State Ombudsmen, State agencies, and CMS ROs have an ongoing venue to share information about facility-initiated discharges and potentially other systemic problems in nursing homes.

ACL and CMS should ensure that all State Ombudsmen, State agencies, and CMS ROs have an ongoing venue to share information about facility-initiated discharges and potentially other systemic problems in nursing homes.

We recommend that the Office of Intergovernmental and External Affairs develop and distribute to staff a quick reference document that includes key staff responsibilities for coordinating and vouchering both invitational and staff travel in accordance with the FTR and the HHS Travel Policy Manual and the resources available to staff for ensuring that travel card transactions are compliant with these Federal travel regulations; and a requirement that staff and supervisors read and sign the HHS Traveler Agreement.

We recommend that the Centers for Medicare & Medicaid Services take the following actions for supplier claims for DMEPOS items provided to hospice beneficiaries, which could have saved Medicare an estimated $116.9 million in improper payments and could have saved beneficiaries an estimated $29.8 million in deductibles and coinsurance that may have been incorrectly collected from them or from someone on their behalf during the audit period.

We recommend that the Centers for Medicare & Medicaid Services implement a postpayment edit process to detect claims submitted by suppliers processed before a beneficiary's notice of election of hospice care is processed in the CWF, and instruct the DME Medicare contractors to deny DMEPOS claims identified by the edit process if they do no have the GW modifier.

We recommend that the Centers for Medicare & Medicaid Services study the feasibility of including palliative items and services not related to a beneficiary's terminal illness and related conditions within the hospice per diem. Such a requirement would eliminate the need for Medicare to make additional payments for these services consistent with CMS's longstanding position that payments for services unrelated to a beneficiary's terminal illness and related conditions should be exceptional, unusual, and rare given the comprehensive nature of the services covered under the Medicare hospice benefit. In analyzing the feasibility of such a change, CMS could consider: (1) beneficiary access to care, (2) administrative costs, (3) appropriate adjustments to the per diem rates to reflect the higher costs associated with providing hospice services, and (4) possible improvement of coordination of care.