Recommendations Tracker

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.

We recommend that FDA update its registered entities' security plans to include procedures for notifying FSAP if a select agent shipment is not received within 48 hours after the expected time of delivery.

We recommend that FDA update its registered entities' security plans to include procedures for notifying FSAP if a select agent shipment will not be completed within 30 calendar days after transfer authorization issuance.

We recommend that FDA ensure that its registered entities verify and maintain documentation to assure that employees who are required to have select agent training understand the training received.

We recommend that DCF refund $114,504 to the Federal Government.

We recommend that DCF revise current policy to ensure the recovery of overpayments.

We recommend that the State agency work with CMS to determine the unallowable portion of $258,640 (Federal share) for other claims for covered outpatient physician-administered drugs that were submitted without NDCs or had invalid NDCs and that may have been ineligible for Federal reimbursement and refund that amount.

We recommend that the State agency strengthen its internal controls to ensure that all physician-administered drugs eligible for rebates are invoiced.

We recommend that the State agency refund to the Federal Government $32,620 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement

We recommend that CMS implement billing requirements (including, for example, a bundled payment similar to that for IMRT planning services) and system edits to prevent additional payments for 3D-CRT planning services that are billed before (e.g., up to 14 days before) 3D-CRT planning CPT code 77295 is billed, which could have saved Medicare as much as $125,377,027 during CYs 2008 through 2017 and as much as $13,601,090 in CY 2018.

We recommend that the State agency work with community-based providers on how to identify and report all critical incidents.

We recommend that NIH revise its All of Us Cooperative Agreements and cooperative agreements with security and privacy requirements to include a detailed description of how NIH will monitor cybersecurity and ensure that future awardees adequately implement security controls to protect sensitive data.

FDA should further communicate to hospitals the importance of obtaining NPS compounded drugs from outsourcing facilities.

We recommend that CMS work with the Survey Agencies to improve training for staff of SNFs on how to identify and report incidents of potential abuse or neglect of Medicare beneficiaries.

We recommend that CMS require the Survey Agencies to record and track all incidents of potential abuse or neglect in SNFs and referrals made to local law enforcement and other agencies.

We recommend that CMS compile a complete list of diagnosis codes that indicate potential physical or sexual abuse and neglect.

We recommend that CMS inform States that the extracted Medicare claims data are available to help the States ensure compliance with their mandatory reporting laws.

We recommend that CMS instruct the MACs to recover the portion of the $56,668 in identified net overpayments that are within the 4-year reopening period.

We recommend that CMS work with the MACs to conduct data analysis allowing for targeted reviews of claims for polysomnography services.

Fill vacant positions now that the Unit is in a temporary workspace and continue to ensure that the Unit has a safe and adequate work environment

Establish an annual training plan covering all professional disciplines within the Unit