Open Recommendations

OIG recommends that the Bureau of Administration develop and implement guidance directing all price negotiation memoranda-approving officials certify that price negotiation memoranda address all required elements in compliance with Federal Acquisition Regulation Subpart 15.406-3 before approving them.

OIG recommends that the Bureau of Administration issue a directive to the Office of Acquisitions Management to update its Memorandum 15-09, Contract File Documentation, regarding price negotiation memoranda. The updated memorandum should include instructions for Contracting Officers to verify that all price negotiation memoranda packages are properly approved and placed in the contract file.

OIG recommends that the Bureau of Administration develop and implement additional internal control procedures for monitoring compliance with Federal Acquisition Regulation requirements and Department policy regarding determining and documenting fair and reasonable price determinations and maintaining complete contract files.

We recommend that the Tennessee State Medicaid Agency refund to the Federal Government $397,341,616 in overpayments representing the Federal share of CPEs that the State agency claimed in excess of the allowable amount.

We recommend that the Tennessee State Medicaid Agency provide support for or refund to the Federal Government $370,119,499 for the net costs of caring for uninsured IMD patients for which the State agency did not provide detailed supporting documentation.

We recommend that the Tennessee State Medicaid Agency establish additional policies and procedures to ensure compliance with the STCs including policies and procedures for adjusting the CPE estimates to actual costs on the CMS-64s upon determining that hospitals have been overpaid or underpaid.

We recommend that the Tennessee State Medicaid Agency establish additional policies and procedures to ensure compliance with the STCs including policies and procedures for collecting and maintaining patient-level detail data for the uninsured population for the IMDs.

We recommend that the Tennessee State Medicaid Agency establish additional policies and procedures to ensure compliance with the STCs including policies and procedures for ensuring that the State agency identifies and excludes from its actual CPE calculations the net costs of caring for IMD patients between the ages of 21 and 64.

We recommend that the Tennessee State Medicaid Agency establish additional policies and procedures to ensure compliance with the STCs including policies and procedures for reviewing the actual CPE calculations of its contractor.

OMB should engage with Congress to consider legislating amendments to extend independent oversight of USAspending.gov data submissions, including developing new requirements in consultation with CIGIE and the PRAC for the review of agency award descriptions.

OMB should conduct a feasibility study, in coordination with relevant federal and non-federal stakeholders, as to how to better track and report subrecipient funding.

OMB should engage with Congress to consider legislating amendments to extend independent oversight of USAspending.gov data submissions, including developing new requirements in consultation with the CIGIE and the PRAC for the review of subrecipient reporting.

CMS should monitor national EPSDT performance data for blood lead screening tests and target efforts toward low-performing States to develop action plans for increasing tests, according toMedicaid's schedule

CMS should ensure consistency across CMS guidance related to actionable blood lead reference values and blood lead screening test definitions.

CMS should coordinate with partners to develop and disseminate to State Medicaid agencies educational materials that reaffirmrequirements and schedules for blood lead screening tests

We recommend ICE’s Records Officer, in conjunction with the Executive Assistant Director for Enforcement and RemovalOperations, update all policies, guidance, and contracts for detention facilities to ensure compliance with the National Archives and Records Administration’s record retention schedules.

Complete a program-specific fraud risk assessment and risk profile for the CDBG and ESG programs, with emphasis on CARES Act funding, and replicate this process to create program-specific fraud assessments and risk profiles for other CPD programs.

Consider OIG's fraud risk inventory to improve CPD's own fraud risk assessments and develop a program-specific fraud risk map and compendium.

Implement efforts to increase the awareness of fraud at all levels (headquarters, field offices, grantees, subrecipients, etc.), including but not limited to regularly publishing articles on known fraud schemes and identified instances of fraud in periodic newsletters or on CPD's intranet website, providing recurring fraud risk trainings to HUD employees and grantees and working with OIG to develop materials to support fraud awareness.

Develop and implement a fraud risk checklist or other instrument as part of CPD's monitoring oversight requirements, to be completed as part of each remote and onsite monitoring review.

Develop and implement a fraud analytics strategy using available data, including but not limited to data and information collected during the grantee risk assessment and monitoring processes, to begin conducting data analyses to identify potential fraud risks for further review.