Open Recommendations

1. We recommend that Alta Bates Summit Medical Center refund to the Medicare contractor $16,346,371 ($16,395,489 less $49,118 that the Hospital has already repaid) in estimated overpayments for the audit period for claims that it incorrectly billed.

2. We recommend that Alta Bates Summit Medical Center based on the results of this audit, 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.

3. We recommend that Alta Bates Summit Medical Center strengthen controls to ensure that: (1) all IRF beneficiaries meet Medicare criteria for acute inpatient rehabilitation and all required documentation is included in the medical records, (2) procedure and diagnosis codes are supported in the medical records and staff are properly trained, (3) all inpatient beneficiaries meet Medicare requirements for inpatient hospital services, (4) the use of bypass modifiers is supported in the medical records, and (5) staff are properly trained.

We recommend that the Assistant Secretary for Elementary and Secondary Education ensure that OESE strengthens its policy for creating and retaining records so those records demonstrate adequate and proper documentation of OESE’s functions, policies, decisions, procedures, and essential transactions relevant to the review and approval of the McKinney-Vento Act section of State plans.

We recommend that the Assistant Secretary for Elementary and Secondary Education ensure that OESE makes publicly available all submissions and resubmissions of States’ plans, including individual and consolidated plans, to promote full transparency.

We recommend that the Assistant Secretary for Elementary and Secondary Education ensure that OESE adheres to its policy and considers all conflict of interest information collected from peer reviewers before assigning them State plans to review.

Ensure that all case file documents are accurately timestamped to the date they are actually completed and that all staff are trained on how to properly maintain accurate and up-to-date case files

Strengthen existing procedures to ensure that family reunification packets are sent within required timeframes

Develop policies and procedures for promptly notifying DHS of the imminent release of a child to a sponsor and document and maintain all correspondence

Ensure that all employees follow policies and procedures requiring Federal and State background investigations to be completed before staff begin working with children, provide relevant training to appropriate staff, and document and maintain documentation of all results.

Implement procedures and controls for collecting and reconciling information contained in its performance reports by developing protocols for collecting required data, handling system failures, and resolving discrepancies to ensure that all performance reports are accurate, verifiable, and reviewed before release to ORR.

Work with ORR to develop allowable methodologies to allocate salaries, develop a procedure or system to capture what programs each employee actually worked on, and determine what portion of the $1,500,218 in salaries charged based on budget estimates was accurately charged to the UAC program and refund to the Federal Government any unallowable portion

Work with ORR to determine an allocation methodology or plan to claim shared direct expenditures in proportion to benefits received, develop a policy to reflect this methodology or plan, determine whether any of the $1,352,027 in direct expenditures and up to $235,253 in related indirect expenditures allocated using the unreasonable allocation ratio was allowable, and refund to the Federal Government any unallowable portion

Develop policies and procedures for identifying allowable shared UAC program costs, including items that need advance approval, determine whether any of the $210,037 in potentially unallowable and $23,390 in potentially unallowable unapproved expenditures would be allowable under the newly approved allocation methodology or plan, and refund to the Federal Government any unallowable or unapproved portion

Develop policies and procedures for identifying shared UAC program costs not in compliance with Federal requirements and refund $10,336 in unallowable employee appreciation expenditures

Develop policies and procedures for identifying direct UAC program costs not in compliance with Federal requirements and refund $6,515 in unallowable expenditures not related to the UAC program

Develop policies and procedures for claiming indirect expenditures based on the approved indirect cost rate.

Assess, confirm, and recover the previously issued improper WHIP payments of $4,268,395 to program participants.

Complete and publish a document describing lessons learned after the BRT completes its work related to this breach.

Determine, document, and implement a structure for the Clearinghouse.

Implement the recommendations from the Human Resources study.

FDA should use the new TIRF REMS patient registry to monitor for known areas of risk, such as inappropriate conversions and off-label prescribing.

FDA should strengthen the REMS for opioid analgesics (the successor to ER/LA opioids) by requiring prescriber training.

FDA should enhance its REMS assessment review process.

FDA should seek additional authority to ensure that manufacturers are held accountable when appropriate.