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Offshore Outsourcing of Administrative Functions by State Medicaid Agencies

April 18, 2014 Comments off

Offshore Outsourcing of Administrative Functions by State Medicaid Agencies
Source: U.S. Department of Health and Human Services, Office of Inspector General

WHY WE DID THIS STUDY
Outsourcing occurs when State Medicaid agencies enter into agreements with contractors to perform administrative functions. Outsourcing can occur inside the United States (domestic outsourcing) or outside (offshore outsourcing) and can be direct (when a Medicaid agency contracts with an offshore contractor) or indirect (when a Medicaid agency’s contractor subcontracts to an offshore contractor). There are no Federal regulations that prohibit the offshore outsourcing of Medicaid administrative functions. However, the Health Insurance Portability and Accountability Act (HIPAA) requires covered entities to have business associate agreements (BAAs) to protect personal health information (PHI).

HOW WE DID THIS STUDY
We conducted a survey of 56 Medicaid agencies, including those of the District of Columbia and the U.S. territories. We asked Medicaid agencies (1) whether they had any policies, Executive Orders, State laws, or contract requirements (collectively, “requirements”) addressing the outsourcing of administrative functions offshore and (2) whether they directly or indirectly outsourced administrative functions offshore. For Medicaid agencies with outsourcing requirements, we asked whether these requirements address PHI and whether the Medicaid agencies monitor contractors’ compliance with the requirements. We reviewed the Medicaid agencies’ requirements and BAAs. For the Medicaid agencies that outsource offshore, we asked what types of administrative functions are outsourced offshore.

WHAT WE FOUND
Only 15 of 56 Medicaid agencies have some form of State-specific requirement that addresses the outsourcing of administrative functions offshore. The remaining 41 Medicaid agencies reported no offshore outsourcing requirements and do not outsource administrative functions offshore. Among the 15 Medicaid agencies with requirements, 4 Medicaid agencies prohibit the outsourcing of administrative functions offshore and 11 Medicaid agencies allow it. The 11 Medicaid agencies that allow offshore outsourcing of administrative functions each maintain BAAs with contractors, which is a requirement under HIPAA. Among other things, BAAs are intended to safeguard PHI. These 11 Medicaid agencies do not have additional State requirements that specifically address safeguarding PHI. Seven of the eleven Medicaid agencies reported outsourcing offshore through subcontractors, but none reported sending PHI offshore. If Medicaid agencies engage in offshore outsourcing of administrative functions that involve PHI, it could present potential vulnerabilities. For example, Medicaid agencies or domestic contractors that send PHI offshore may have limited means of enforcing provisions of BAAs that are intended to safeguard PHI. Although some countries may have privacy protections greater than those in the United States, other countries may have limited or no privacy protections.

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DoD OIG — Section 847 Ethics Requirements for Senior Defense Officials Seeking Employment with Defense Contractors

April 17, 2014 Comments off

Section 847 Ethics Requirements for Senior Defense Officials Seeking Employment with Defense Contractors
Source: U.S. Department of Defense, Office of Inspector General

Objective
Our objectives were to (1) address the central database and DoD IG oversight provisions of Public Law 110-181, “The National Defense Authorization Act for Fiscal Year 2008,” Section 847, “Requirements for Senior Department of Defense Officials Seeking Employment with Defense Contractors,” January 28, 2008; (hereinafter referred to as “section 847”) (2) address subsequent direction from the House Armed Services Committee (HASC); and (3) accordingly determine:

  • Whether written legal opinions required by section 847 were “being provided and retained in accordance with the requirements of this section.” (Public Law 110-181, section 847 [b][2]).
  • “The Department of Defense’s record of compliance with section 847 of Public Law 110-181.” (HASC Report on the National Defense Authorization Act For Fiscal Year 2013).
  • Quantitative data specified by the HASC, as follows:
    • “the total number of opinions issued,
    • the total number of opinions retained in accordance with section 847,
    • any instances in which a request for a written opinion pursuant to section 847 lacked a corresponding written opinion, or
    • in which the written opinion was not provided to the requesting official or former official of the Department of Defense by the appropriate ethics counselor within 30 days after the request for a written opinion.”

DoD did not retain all required section 847 records in its designated central repository, the After Government Employment Advice Repository (AGEAR).

This occurred because the Department did not:

  • implement the 2010 DoD Inspector General (IG) report recommendation to transfer historical records into AGEAR when the database became operational,
  • centrally supervise section 847 activities by its decentralized Components, and
  • comply with Deputy Secretary guidance making AGEAR use mandatory as of January 1, 2012.

As a result:

  • The AGEAR database was incomplete with limited or no use by specific DoD organizations with significant contracting activity.
  • Individual section 847 records were located in multiple or decentralized locations, and in a number of cases were inaccurate, incomplete, and not readily accessible for examination.

HHS OIG — Limited Compliance With Medicare’s Home Health Face to Face Documentation Requirements

April 15, 2014 Comments off

Limited Compliance With Medicare’s Home Health Face to Face Documentation Requirements
Source: U.S. Department of Health and Human Services, Office of Inspector General

WHY WE DID THIS STUDY
The Patient Protection and Affordable Care Act (ACA) requires that physicians (or certain practitioners working with them) who certify beneficiaries as eligible for Medicare home health services document-as a condition of payment for home health services-that face-to-face encounters with those beneficiaries occurred. This study (1) determined the extent to which physicians who certified home health care documented the face-to-face encounters, (2) described the nature of face-to-face documentation, and (3) assessed CMS’s oversight of the face-to-face requirement.

HOW WE DID THIS STUDY
We reviewed 644 face-to-face encounter documents to analyze the extent to which the documents confirmed encounters and contained the required elements. We interviewed the four Home Health and Hospice Medicare Administrative Contractors (HH MACs) to describe how they ensure that home health agencies met the face-to-face encounter requirements. We also reviewed guidance documents and policies from CMS or the HH MACs about monitoring the face-to-face requirement.

WHAT WE FOUND
For 32 percent of home health claims that required face-to-face encounters, the documentation did not meet Medicare requirements, resulting in $2 billion in payments that should not have been made. Furthermore, physicians inconsistently completed the narrative portion of the face to face documentation. Some face-to-face documents provide information that, although not required by Medicare, could be useful, such as a printed name for the physician and a list of the home health services needed. CMS oversight of the face-to-face requirement is minimal.

WHAT WE RECOMMEND
We recommend that CMS (1) consider requiring a standardized form to ensure that physicians include all elements required for the face-to-face documentation, (2) develop a specific strategy to communicate directly with physicians about the face-to-face requirement, and (3) develop other oversight mechanisms for the face-to-face requirement. CMS concurred with all of our recommendations.

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Department of State OIG — Management Alert: Contract File Management Deficiencies

April 11, 2014 Comments off

Management Alert: Contract File Management Deficiencies (PDF)
Source: U.S. Department of State, Office of Inspector General

The Office of Inspector General (OIG), in recent audits, investigations, and inspections, has identified significant vulnerabilities in the management of contract file documentation that could expose the Department to substantial financial losses. Specifically, over the past 6 years, OIG has identified Department of State (Department) contracts with a total value of more than $6 billion in which contract files were incomplete or could not be located at all. The failure to maintain contract files adequately creates significant financial risk and demonstrates a lack of internal control over the Department’s contract actions.

New From the GAO

April 10, 2014 Comments off

New GAO Reports and Testimony
Source: Government Accountability Office

Reports

1. KC-46 Tanker Aircraft: Program Generally on Track, but Upcoming Schedule Remains Challenging. GAO-14-190, April 10.
http://www.gao.gov/products/GAO-14-190
Highlights - http://www.gao.gov/assets/670/662449.pdf

2. Air Force: Actions Needed to Strengthen Management of Unmanned Aerial System Pilots. GAO-14-316, April 10.
http://www.gao.gov/products/GAO-14-316
Highlights - http://www.gao.gov/assets/670/662468.pdf

3. Presidential Helicopter Acquisition: Update on Program’s Progress toward Development Start. GAO-14-358R, April 10.
http://www.gao.gov/products/GAO-14-358R

4. Status of Efforts to Initiate an Amphibious Combat Vehicle Program. GAO-14-359R, April 10.
http://www.gao.gov/products/GAO-14-359R

Testimony

1. Inspectors General: Oversight of Small Federal Agencies and the Role of the Inspectors General, by Beryl H. Davis, director, financial management and assurance, before the Subcommittee on Financial and Contracting Oversight, Senate Committee on Homeland Security and Governmental Affairs. GAO-14-503T, April 10.
http://www.gao.gov/products/GAO-14-503T
Highlights - http://www.gao.gov/assets/670/662442.pdf

Inspector Report: DOE/IG-0904 Review of Controls Over the Department’s Classification of National Security Information

April 9, 2014 Comments off

Inspector Report: DOE/IG-0904 Review of Controls Over the Department’s Classification of National Security Information
Source: U.S. Department of Energy, Office of Inspector General

The Department of Energy handles and manages a broad spectrum of classified information, including National Security Information (NSI). The Office of Health, Safety and Security’s Office of Classification, manages the Department-wide classification program and establishes policies to conform with Federal classification requirements. Implementation of classification requirements is shared among various organizations within the Department. In addition, the Department’s Office of Intelligence and Counterintelligence is required to follow NSI policies and procedures instituted by the Office of the Director of National Intelligence. Similarly, the Department’s National Nuclear Security Administration (NNSA) separately develops and implements policies and procedures, in coordination with the Office of Classification, for the protection and security of classified information at NNSA sites.

Our inspection revealed that the Department had established and implemented critical elements of its classified NSI program. However, our review revealed that certain aspects of the NSI program could be improved. For instance, our inspection determined that a classification marking tool embedded in the classified email system at an NNSA site automatically marked emails as Secret//Restricted Data, regardless of content. The classification related issues we observed occurred, in part, because of ineffective oversight of classification activities and inadequate training and guidance.

In general, we found management’s comments and planned corrective actions to be generally responsive to our report findings and recommendations.

HHS OIG — Questionable Billing for Medicare Electrodiagnostic Tests

April 8, 2014 Comments off

Questionable Billing for Medicare Electrodiagnostic Tests
Source: U.S. Department of Health and Human Services, Office of Inspector General

WHY WE DID THIS STUDY
In 2011, Medicare paid approximately $486 million to 21,700 physicians who billed for electrodiagnostic tests for 877,000 beneficiaries. Electrodiagnostic tests are used to evaluate patients who may have nerve damage. Recent investigations have found that electrodiagnostic testing is an area vulnerable to fraud, waste, and abuse. For example, in 2011, following work by the Medicare Fraud Strike Force, a group of physicians was charged with fraudulently billing Medicare $113 million for false claims, including claims for electrodiagnostic tests. CMS issues comparative billing reports to providers for a variety of services, including electrodiagnostic testing. Such reports are intended to proactively educate providers and to help them identify and correct errors in their billing.

HOW WE DID THIS STUDY
We developed seven measures of questionable billing on the basis of past OIG work and input from CMS staff. We analyzed Medicare 2011 electrodiagnostic test claims to identify physicians who had unusually high billing for at least one of these measures. We also determined whether physicians with questionable billing for electrodiagnostic tests received comparative billing reports in 2011 for such tests. Finally, we identified the geographical areas with the highest amounts of questionable billing.

WHAT WE FOUND
In 2011, 4,901 physicians had questionable billing for Medicare electrodiagnostic tests totaling $139 million. Additionally, we found that approximately 20 percent of these physicians received comparative billing reports in 2011 on the basis of their 2010 billing for electrodiagnostic tests. Finally, physicians in the New York, Los Angeles, and Houston areas had the highest total questionable billing for Medicare electrodiagnostic tests in 2011.

WHAT WE RECOMMEND
We recommend that CMS (1) increase its monitoring of billing for electrodiagnostic tests, (2) provide additional guidance and education to physicians regarding electrodiagnostic tests, and (3) take appropriate action regarding physicians whom we identified as having inappropriate or questionable billing. CMS partially concurred with two of our recommendations and concurred with the third recommendation.

USPS OIG — Enhancing the Value of Mail Follow Up: Discussion Forum Recap

April 7, 2014 Comments off

Enhancing the Value of Mail Follow Up: Discussion Forum Recap
Source: U.S. Postal Service, Office of Inspector General

Hard copy communications, and mail specifically, are not not the relic some claim them to be. Mail can still create a powerful connection with people of all ages. This is especially true when it is well designed and digitally interactive. Although senders pay for mail to be sent, catching recipients’ eyes determines the value of the communication. Without consumer interest in mailpieces like direct mail, catalogs, or bill reminders, the mail value chain breaks down.

The U.S. Postal Service Office of Inspector General (OIG) hosted a discussion forum with marketing, communications, and mail industry experts to discuss ways mail could be made more valuable to the recipient. The forum consisted of three parts. First, the OIG discussed the findings from its whitepaper that spurred the forum, Enhancing Mail for Digital Natives. Then, research highlighting the utility of mail and emotional connection to hard copy communications was illustrated through a number of European studies. Finally, there was a panel discussion among industry leaders about how mail can be made more effective in today’s omnichannel marketing campaigns.

The OIG’s past work shows that Digital Natives, aged 16-25, appreciate mail when it is personalized and has a useful connection to the digital realm. Digital Natives are gaining market power, and will soon outnumber baby boomers. As their influence grows, marketers’ ability to meet their expectations will become increasingly important.

The European research presented showed that hard-copy advertising creates a stronger emotional response than digital advertising. Another European study showed that the total cost of sending hard copy bill reminders through the mail was less than those sent via e-mail.

The panel discussed mail’s role in omnichannel campaign strategies, how personalizing can affect the success of a campaign, and demonstrated new technology like near field communication and augmented reality, which create a seamless integration between physical mail and a digital experience. There is strong interest among printers, marketers, and advertisers to incorporate this technology into traditional direct mail. Companies should take advantage of dropping prices of physical-digital technology and personalizing capabilities to create mailpieces that recipients truly value.

USPS OIG — Readiness for Package Growth – Customer Service Operations: Management Advisory Report

April 4, 2014 Comments off

Readiness for Package Growth – Customer Service Operations: Management Advisory Report (PDF)
Source: U.S. Postal Service, Office of Inspector General

BACKGROUND:
Strong customer demand for goods purchased over the Internet has driven growth in the package market, despite an otherwise declining mail market. This growing segment provides the U.S. Postal Service an opportunity to expand services and increase revenue. From fiscal year (FY) 2010 to FY 2012, Postal Service package revenue increased by $1.4 billion, or 14 percent, and volume increased by 445 million pieces, or 14 percent. Package volume also increased by 13.7 percent in the first 3 quarters of FY 2013, compared with the same period last year.

The Postal Service’s retail component, Customer Service Operations, processes about 34 percent of its annual package volume during the holiday mailing season (November and December). About 75,000 Customer Service Operations’ employees work at post offices and destination delivery units. Employees accept packages at over 31,000 post offices for dispatch to mail processing facilities and receive them at over 24,000 destination delivery units to sort for final delivery.

This report is one in a series of U.S. Postal Service Office of Inspector General products that addresses the Postal Service’s readiness for growth in the package business. Our objective was to evaluate operational readiness for package growth in Customer Service Operations.

WHAT THE OIG FOUND:
Customer Service Operations has successfully managed periods of package growth, employee workhours, and scan rates at delivery units. However, opportunities exist to enhance readiness by improving acceptance scan rates, decreasing customer wait time in line during the holiday mailing season, enabling the Passive Adaptive Scanning System revenue-protection function, and reducing the number of non-barcoded packages to provide end-to-end tracking for customers. Overcoming these challenges could improve the Postal Service’s competitiveness in the package business.

WHAT THE OIG RECOMMENDED:
We recommended the vice president, Delivery and Post Office Operations, reinforce that Customer Service Operations’ employees perform acceptance scans to support the 100 percent product visibility strategy. We also recommended the vice presidents, Engineering Systems and Product Information, enable the Passive Adaptive Scanning System revenue protection function and implement a comprehensive strategy to reduce non-barcoded packages. Finally, we recommended the vice president, Mail Entry and Payment Technology, define a solution for notification and collection of shortpaid postage for packages.

DoJ OIG — Review of the Organized Crime Drug Enforcement Task Forces Fusion Center

April 3, 2014 Comments off

Review of the Organized Crime Drug Enforcement Task Forces Fusion Center (PDF)
Source: U.S. Department of Justice, Office of Inspector General

INTRODUCTION
This review examined the operations of the Organized Crime Drug Enforcement Task Forces (OCDETF) Fusion Center (OFC) and assessed its process for sharing its analytical products. The OFC is a multiagency intelligence center that produces intelligence products in response to requests from federal investigators (requesters). The Drug Enforcement Administration’s (DEA) Special Operations Division (SOD) supports the OFC in developing these products.

ISSUES THAT AROSE DURING THE REVIEW
The Office of the Inspector General (OIG) learned during the course of the review that OFC management took actions that created difficulties for us in obtaining information from OFC employees and in ensuring that interview responses were candid and complete.

We had issues in obtaining documents directly from OFC personnel. Further, two Federal Bureau of Investigation (FBI) employees detailed to the OFC, who met with us to describe their concerns about the OFC’s operations, told us that thereafter they had been subjected to retaliation by the OFC Director. The OIG recently completed its review of these retaliation allegations and concluded there were reasonable grounds to believe that actions were taken against the FBI employees in reprisal for making protected disclosures. We have referred our findings to the appropriate authorities for adjudication and resolution under applicable law.

Given this troubling conduct, we cannot be sure we obtained complete information from or about the OFC or that other OFC employees may not have been deterred from coming forward and speaking candidly with us. The results of our review reflect the findings and conclusions that we were able to reach based on the information that was made available to us.

RESULTS IN BRIEF
Although we found that OFC products may provide information that is valued by the investigators and prosecutors who use them, the OIG review identified deficiencies in the OFC’s operations that could limit its contribution to the OCDETF Program’s effectiveness.

See:

SSA OIG — Audit Report: Improper Use of Children’s Social Security Numbers

April 3, 2014 Comments off

Audit Report: Improper Use of Children’s Social Security Numbers
Source: Social Security Administration, Office of Inspector General

As part of the Annual Wage Reporting process, the Social Security Administration (SSA) verifies the names and SSNs on Wage and Tax Statements (Form W-2) to ensure the reported name and SSN is accurate before SSA posts the information from the W-2 to the Master Earnings File. When SSA’s data indicate a wage earner is a child age 6 or younger, SSA places the earnings in the Earnings Suspense File (ESF), a repository for unmatched wage items, and assigns a Young Children’s Earnings (YCER) indicator. SSA mails notices to employers and employees to confirm the children legitimately earned the wages. However, SSA does not have a process for children between ages 7 and 13. SSA posts these children’s wages to their earnings records.

In addition, if the data include a date of death, SSA places in the ESF all the earnings reported after the year of death and assigns an Earnings After Death indicator. SSA sends notices to the employers and employees to confirm employment.

The purpose of this audit was to determine whether employees were improperly using children’s SSNs for work purposes.

EPA OIG — Improvements to EPA Policies and Guidance Could Enhance Protection of Human Study Subjects

April 3, 2014 Comments off

Improvements to EPA Policies and Guidance Could Enhance Protection of Human Study Subjects (PDF)
Source: U.S. Environmental Protection Agency, Office of Inspector General

The EPA obtained approval to conduct the five human research studies, including approval from a biomedical Institutional Review Board (IRB) and the EPA Human Studies Research Review Official (H SRRO). However, t he EPA’s policies and guidance do not address when HSRRO approv al is needed for significant study modifications. Developing guidance for when HSRRO must approve significant modifications would ensure their independent review.

The EPA obtained informed consent from the 81 human study subjects before exposing them to pollutants. While the consent forms met the requirements of 40 CFR Part 26, we found that exposure risks were not always consistently represented. Further, the EPA did not in clude information on long-term cancer risks in its diesel exhaust studies’ co nsent forms. An EPA manager considered these long-term risks minimal for short-term study exposures. We believe presenting consistent information about risks further ensures that study subjects can make the most informed choice about participating in a study.

The EPA addressed six adverse events during its studies, reported them to the IRB, and provided clinical follow-up after t he events. While the clinical follow-up appeared to be reasonable, the EPA’s polic ies, guidance and cons ent forms do not establish the EPA’s clinical follow-up re sponsibilities. Acco rding to EPA managers, the agency uses the latest University of North Carolina at Chapel Hill (UNC) IRB’s adverse event definitions and reporting ti meframes to respond to adverse events. However, the agency’s guidance provides different definitions and reporting timeframes and does not state that t he EPA has adopted the UNC-IRB definitions and timeframes. Using EPA’s guidance, the EPA reported two of the six adverse events later than required and did not report two other events to IRB.

Audit of VHA’s Supportive Services for Veteran Families Program

April 2, 2014 Comments off

Audit of VHA’s Supportive Services for Veteran Families Program (PDF)
Source: U.S. Department of Veterans Affairs, Office of Inspector General

At the request of the House Committee on Veterans’ Affairs, Subcommittee on Health, we conducted this audit to determine if the Veterans Health Administration’s (VHA) Supportive Services for Veteran Families (SSVF) program grantees appropriately expended program funds. In December 2010, VA established the SSVF program to rapidly re-house homeless veteran families and prevent homelessness for those at imminent risk due to a housing crisis. For fiscal years (FYs) 2012 and 2013, the VHA awarded about $60 million and $100 million in SSVF grants, respectively, and has increased awards to nearly $300 million for FY 2014. We found that VHA’s SSVF program has adequate financial controls in place that are working as intended to provide reasonable assurance that funds are appropriately expended by grantees. We determined program staff were reviewing grantee timecards, invoices for temporary financial assistance, subcontractor costs, and conducted annual inspections. However, SSVF program officials can improve controls to ensure only eligible veterans and their family members participate in the program. We found three of five grantees used outdated area median income (AMI) limits to determine eligibility for the program. In addition, four of five grantees did not verify veterans’ discharge status with the required “Certificate of Release or Discharge from Active Duty” (DD 214). This occurred because some grantees were not aware when new AMI limits were published. To avoid delaying program participation, grantees did not always follow up to ensure receipt of the required DD 214 when an interim eligibility document was used. As a result, VHA risks providing SSVF services to ineligible veterans or excluding eligible veterans from the program. We recommended the Under Secretary for Health ensure SSVF program management implements a mechanism to inform grantees when the most current AMI limits are published and ensure grantees comply with eligibility documentation requirements. The Under Secretary for Health concurred with our recommendations and provided an appropriate action plan. We consider the SSVF program actions sufficient and closed the recommendations as completed.

USPS OIG — Information Storage Security: Audit Report

April 2, 2014 Comments off

Information Storage Security: Audit Report (PDF)
Source: U.S. Postal Service, Office of Inspector General

The Data Management Services group did not manage the storage environment in accordance with Postal Service security requirements because its managers did not provide adequate oversight of the storage teams. They did not, for example, conduct periodic employee access reviews. The absence of proper security practices and training increases the likelihood of an adverse impact on Postal Service operations, such as an outage of a customerdependent system.

In addition, the Corporate Information Security Office did not provide guidance for storage environments as it has for operating systems, databases, and telecommunication security. Establishing minimum security expectations for storage environments can reduce the likelihood of critical system and application outages throughout Postal Service operations.

CMS System for Sharing Information About Terminated Providers Needs Improvement

March 28, 2014 Comments off

CMS System for Sharing Information About Terminated Providers Needs Improvement
Source: U.S. Department of Health and Human Services, Office of Inspector General

WHY WE DID THIS STUDY
The Patient Protection and Affordable Care Act (ACA) requires the Centers for Medicare & Medicaid Services (CMS) to establish a process for sharing information about terminated providers. To meet this requirement, CMS established a Web-based portal, the Medicaid and Children’s Health Insurance Program State Information Sharing System (MCSIS). Sharing terminated provider data among States prevents terminated providers in one State from enrolling in another State. CMS and State agencies can submit information about providers that meet CMS’s criteria for having been terminated “for cause” from Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP). State Medicaid agencies can use these data to identify these providers and subsequently terminate them from their Medicaid programs as required under another section of the ACA. In November 2013, subsequent to the timeframe we examined for this study, CMS revised its process for sharing information about terminated providers. The findings and recommendations in this report remain relevant to the new process.

HOW WE DID THIS STUDY
We examined all provider records contained in MCSIS as of June 1, 2013. We (1) determined the extent to which MCSIS contained records submitted by CMS and State Medicaid agencies; (2) identified records that did not meet CMS criteria for reporting providers terminated “for cause” from Medicare, Medicaid, or CHIP; and (3) assessed whether records had complete identifying information about providers, including National Provider Identifiers (NPIs), provider types, and provider addresses.

WHAT WE FOUND
As of June 1, 2013, MCSIS contained records on terminated providers submitted by CMS and 33 State Medicaid agencies and did not contain records from the remaining State Medicaid agencies. Contrary to CMS guidance, about one-third of the 6,439 records in MCSIS did not relate to providers terminated “for cause.” Over half of MCSIS records did not contain NPIs, a critical data element for accurately identifying providers. Additionally, one-third of MCSIS records did not identify the provider types and one quarter had no provider addresses.

WHAT WE RECOMMEND
Our findings suggest that CMS’s process for sharing information on terminated providers needs improvement to make it more useful to State Medicaid agencies in identifying providers that must be terminated pursuant to Federal law because they were terminated “for cause” by Medicare, Medicaid, or CHIP. Therefore, we recommend that CMS (1) require each State Medicaid agency to report all terminated providers, (2) ensure that the shared information contains only records that meet CMS’s criteria for inclusion, and (3) take action to improve the completeness of records shared through the process. CMS concurred with all recommendations.

USPS OIG — Controls over Nonprofit Mailing Authorization Management — Management Advisory Report

March 28, 2014 Comments off

Controls over Nonprofit Mailing Authorization Management — Management Advisory Report (PDF)
Source: U.S Postal Service, Office of Inspector General

The Postal Service consistently applied its policies and procedures when approving and denying nonprofit mailer applications in compliance with applicable laws and regulations. Pricing and Classification Service Center staff reviewed applications and supporting documents to ensure each applicant provided sufficient evidence that it met one of the categories to qualify it for Nonprofit rate eligibility.

We reviewed 170 approved and 198 denied nonprofit mail applications from FYs 2010 through 2013 and found applications were approved when they met all of the Postal Service criteria, such as documenting proof of nonprofit status. Applications were denied when they failed to meet one or more of the criteria, such as the requirement to respond to requests for additional information. The Pricing and Classification Service Center used the same evaluation process to approve and deny applications.

Audit of the Federal Bureau of Investigation’s Management of Terrorist Watchlist Nominations (Redacted Version)

March 26, 2014 Comments off

Audit of the Federal Bureau of Investigation’s Management of Terrorist Watchlist Nominations (Redacted Version) (PDF)
Source: U.S. Department of Justice, Office of Inspector General

Despite using three separate systems to track non-investigative subject watchlist nominations, we found that the FBI had not maintained the necessry records to readily provide an accurate accounting of the actions that were taken regarding to the watchlisting status of non-investigative subjects. We found that the processes used by the FBI were redundant and resulted in incomplete, inconsistent, and erroneous data.

Postal Service Knowledge Management Process: Audit Report

March 20, 2014 Comments off

Postal Service Knowledge Management Process: Audit Report
Source: U.S. Postal Service, Office of Inspector General

BACKGROUND:
As a result of downsizing in response to declining mail volume and the retirement eligibility of about 31 percent of its workforce (152,000 employees), the U.S. Postal Service is at risk of losing the extensive knowledge required to manage its vast operations. The Postal Service had annual revenue of about $67.3 billion, delivered over 158 billion mailpieces, and managed over 31,700 retail locations in fiscal year (FY) 2013. It also operates one of the largest information technology infrastructures in the world, with an inventory of 795 computer applications. It spent at least $59 million on 49 contracts for studies or consulting services during FYs 2011 through 2013.

Our objective was to assess the Postal Service’s knowledge management practices, systems, roles, and responsibilities. Accordingly, we compared Postal Service knowledge management processes with eight organizations to identify best practices the Postal Service might adopt to optimize its resources and efforts.

WHAT THE OIG FOUND:
The Postal Service does not have a comprehensive knowledge management policy or process or a chief knowledge officer to ensure that knowledge sharing is systematic and collaborative. Although not well-defined, there are knowledge management elements within several Postal Service systems to capture some tacit and explicit knowledge. In addition, we could not find any of the 49 studies or consultant reports in the Postal Service Headquarters library where they could be shared among all postal departments, as required by policy.

A comprehensive Postal Service knowledge management process would enable management to leverage information from throughout the organization for strategic decision- making and new initiatives. In the near term, knowledge management activities would also mitigate the possible loss of extensive tacit knowledge due to anticipated Postal Service downsizing and the retirement eligibility of about 31 percent of its workforce.

WHAT THE OIG RECOMMENDED:
We recommended the vice president, Employee Resource Management, develop a comprehensive Postal Service knowledge management strategy. We also recommended the Postal Service join the Federal Knowledge Management Working Group, which has experts to assist, inform, and support development and implementation of a comprehensive knowledge management strategy.

USPS OIG — Officers’ Travel and Representation Expenses for Fiscal Year 2013: Audit Report

March 20, 2014 Comments off

Officers’ Travel and Representation Expenses for Fiscal Year 2013: Audit Report
Source: U.S. Postal Service, Office of Inspector General

Officers’ travel and representation expenses totaling about $771,000 were properly supported; however, the officers did not always comply with Handbook F-15, Travel and Relocation, which requires that all employees, including officers, adhere to the General Services Administration’s published lodging rates or justify why they chose lodging rates that exceeded the published rates. The Officers’ Travel and Representation Expense Guidelines does not reference this portion of Handbook F-15 or otherwise make it clear that officers should adhere to the General Services Administration’s rates. Rather, officers are directed to “shop around for the best possible rate.”

We identified 13 of 60 travel reimbursements filed by 11 officers where lodging costs were between 108 and 239 percent of the published General Services Administration’s lodging rate for the area, totaling about $1,200 in extra costs.

HHS OIG — Compendium of Priority Recommendations

March 19, 2014 Comments off

Compendium of Priority Recommendations
Source: U.S. Department of Health and Human Services, Office of Inspector General

The Compendium of Priority Recommendations presents opportunities to achieve cost savings, improve program management, and ensure quality of care and safety of beneficiaries. The 25 broad “Priority Recommendations” we identified for the March 2104 edition derive from more specific recommendations that OIG has made in audit and evaluation reports. Those more specific recommendations, or action steps, are included in the summary of each broad recommendation, and the underlying reports are referenced. The 25 recommendations are generally grouped according to the underlying HHS program or operation; thus, they are not internally ranked and so do not reflect relative priority among the 25.

OIG’s audits and evaluations do not routinely project the annual cost savings that could be realized at program level from implementing the recommendations. However, reports are indicative of the extent to which policies and methodologies may be less than effective and in need of corrective action. Actual savings to be achieved depend on the scope of the legislative, regulatory, or administrative implementing actions.

In years prior to 2007, information about recommendations was provided in OIG’s “Red Book” (unimplemented monetary recommendations) and “Orange Book” (unimplemented nonmonetary recommendations). The “Red Book” focused on significant Office of Inspector General (OIG) recommendations to save costs and the “Orange Book” focused on recommendations to improve HHS programs.

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