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Reports
Audit of the Reliability of the DoD Coronavirus Disease–2019 Patient Health Data
Rec. 1: The DoD OIG recommended that the Director of the Defense Health Agency work with the Program Executive Officer of the Program Executive Office, Defense Healthcare Management Systems to document and implement the process for identifying and collecting patient health data of DoD patients in the Military Health System in current and future registries within their purview in a written document, such as a standard operating procedure. The procedure should identify, at a minimum, the internal controls throughout the process, the relevant data sources, data fields, and diagnostic codes used in the computer scripts, and should be reviewed and approved when updates occur.
Rec. 2: The DoD OIG recommended that the Senior Contracting Official of the U.S. Army Medical Research Acquisition Activity and the Chief of the Joint Trauma System work with the Joint Trauma System contracting officer's representative to revise the quality assurance surveillance plan. The plan should include an appropriate sampling methodology for selecting patient health records from the Coronavirus Disease-2019 Registry to verify that the contractor is achieving the contract-required accuracy rate for entering patient data, and submit the revised quality assurance surveillance plan to the contracting officer.
Rec. 2: The DoD OIG recommended that the Senior Contracting Official of the U.S. Army Medical Research Acquisition Activity and the Chief of the Joint Trauma System work with the Joint Trauma System contracting officer's representative to revise the quality assurance surveillance plan. The plan should include an appropriate sampling methodology for selecting patient health records from the Coronavirus Disease-2019 Registry to verify that the contractor is achieving the contract-required accuracy rate for entering patient data, and submit the revised quality assurance surveillance plan to the contracting officer.
Rec. 3: The DoD OIG recommended that the Chief of the Joint Trauma System conduct an analysis to determine whether the patient data entered into the Coronavirus Disease-2019 Registry met the 90 percent accuracy rate requirement for contract W81XWH-20-P-0197 and contract W81XWH-22-C-0151.
Rec. 3.a: If the contractor did not meet the 90 percent accuracy requirement, the DoD OIG recommended that the Chief of the Joint Trauma System work with the Senior Contracting Official of the U.S. Army Medical Research Acquisition Activity to update the contractor's rating in the contractor's performance assessment reports for contract W81XWH-22-C-0151 and contract W81XWH-20-P-0197, when feasible.
Rec. 3.b: If the contractor did not meet the 90 percent accuracy requirement, the DoD OIG recommended that the Chief of the Joint Trauma System work with the Senior Contracting Official of the U.S. Army Medical Research Acquisition Activity to recoup any of the $3.9 million in questioned costs paid for services that did not comply with the terms of contract W81XWH-20-P-0197, if feasible.
Rec. 3.c: If the contractor did not meet the 90 percent accuracy requirement, the DoD OIG recommended that the Chief of the Joint Trauma System work with the Senior Contracting Official of the U.S. Army Medical Research Acquisition Activity to recoup any of the $2.3 million in questioned costs paid for services that did not comply with the terms of contract W81XWH-22-C-0151.
Rec. 3.d: If the contractor did not meet the 90 percent accuracy requirement, the DoD OIG recommended that the Chief of the Joint Trauma System work with the Senior Contracting Official of the U.S. Army Medical Research Acquisition Activity to consider all available contract remedies for contract W81XWH-22-C-0151, including modifying and, if necessary, terminating and re-competing the contract, and take action to ensure that the Department receives full value for the funds it expends for contract W81XWH-22-C-0151.
Rec. 3.e: If the contractor did not meet the 90 percent accuracy requirement, the DoD OIG recommended that the Chief of the Joint Trauma System work with the Senior Contracting Official of the U.S. Army Medical Research Acquisition Activity to delegate an official to review the concerns identified in this report, including the actions of the contracting officials, and take administrative actions, as necessary. The review should include a determination on whether the contractor's performance assessment reports were accurate and make updates as necessary.
Rec. 4.a: The DoD OIG recommended that the Director of the Defense Health Agency work with the Chief of the Joint Trauma System establish and implement a process for selecting Coronavirus Disease-2019 events for entry into the Coronavirus Disease-2019 Registry to limit selection bias.
Rec. 4.b: The DoD OIG recommended that the Director of the Defense Health Agency work with the Chief of the Joint Trauma System to include a bias disclosure notice on all reports generated from the Coronavirus Disease-2019 Registry until the Coronavirus Disease-2019 Registry data represent the population of DoD patients who had a Coronavirus Disease-2019 event.
Rec. 5.a: The DoD OIG recommended that the Assistant Secretary of Defense (Health Affairs) establish and implement a policy for developing and populating patient registries that aligns with the Department of Health and Human Services best practices, "Agency for Healthcare Research and Quality, Registries for Evaluating Patient Outcomes: A User?s Guide," current edition.
Rec. 5.b: The DoD OIG recommended that the Assistant Secretary of Defense (Health Affairs) conduct a review of all patient registries in the Military Health System to verify the reliability of data in each registry and implement corrective actions, as necessary.
Remote Application and Desktop Virtualization Client
We recommend the Vice President and Chief Information and Digital Officer, Technology and Information, design and implement a documented configuration management process of TVA’s remote application and desktop virtualization client.
Audit of DoD Actions Taken to Protect DoD Information When Using Collaboration Tools During the Coronavirus Disease–2019 Pandemic
Recommendation is CUI
Recommendation is CUI
Recommendation is CUI
Recommendation is CUI
Recommendation is CUI
Recommendation is CUI
(U) Rec. B.1.a: The DoD OIG recommended that the Chief Information Officer for the Defense Finance and Accounting Service renegotiate changes with the Adobe Connect vendor to configure Adobe Connect to require privileged users to authenticate into the collaboration tool using multifactor authentication.
Recommendation is CUI
Recommendation is CUI
Recommendation is CUI
Recommendation is CUI
Rec. B.3.c: The DoD OIG recommended that the Chief Information Officer for the Defense Threat Reduction Agency configure Zoom for Government to lock user accounts after three unsuccessful logon attempts in a 15-minute period.
Recommendation is CUI
Alaska Experienced Challenges in Meeting Federal and State Foster Care Program Requirements During the COVID-19 Pandemic
We recommend that the Office of Children's Services ensure that staff are adequately trained on policies and procedures to ensure that required background checks are completed before placing children in foster homes under emergency conditions.
We recommend that the Office of Children's Services continue to identify ways to address the challenges related to meeting the requirements for conducting monthly caseworker visits and home inspections, including consulting with ACF.
We recommend that the Office of Children's Services complete home inspections in accordance with requirements for the two foster homes identified by our audit as lacking completed inspections and for the five foster homes requiring in-person inspections.
Seventeen of Thirty Selected Health Centers Did Not Use or May Not Have Used Their HRSA COVID-19 Supplemental Grant Funding in Accordance With Federal Requirements
We recommend that the Health Resources and Services Administration require the 10 health centers identified in our report as having charged unallowable COVID-19 supplemental grant funding costs to refund $787,152 (less any amounts health centers voluntarily refunded as a result of our audit) to the Federal Government.
We recommend that the Health Resources and Services Administration work with the 13 health centers identified in our report that may not have properly allocated COVID-19 supplemental grant funding costs to determine what portion of the $15,056,835 is allocable to their COVID-19 supplemental grant funding and require the health centers to refund the improperly allocated funds to the Federal Government.
We recommend that the Health Resources and Services Administration assist the 17 health centers identified in our report as having charged unallowable costs or potentially improperly allocated costs to implement HRSA's guidance for developing and maintaining financial management systems and internal controls that ensure that only allowable, allocable, and documented costs are charged to their HRSA supplemental grant funding.
Montana Generally Complied With Requirements for Telehealth Services During the COVID-19 Pandemic
We recommend that the Montana Department of Public Health and Human Services develop and implement edits in its claim payment system so that the State agency pays only telehealth claims whose HCPCS codes denote the associated services as eligible to be performed via telehealth.
FDIC Examinations of Government-Guaranteed Loans
Develop and implement guidance to examination staff on the credit, operational (including fraud), liquidity, and compliance risks related to Government-guaranteed loans to ensure staff adequately plans and conducts examinations to identify and address emerging risks.
Develop and implement a training plan to ensure examination staff are trained on the requirements and risks of Government-guaranteed loan programs.
Update, develop, and distribute to FDIC examination personnel a list of FDIC examiners who have significant experience examining banks that specialize in Government-guaranteed loan programs to regional offices.
Develop and implement a process to obtain improved data regarding Government-guaranteed lending activities of FDIC-supervised financial
institutions.
Update the [redacted] MOU to include the sharing of loan portfolio information such as historical loan performance, status of guaranty, and loan-level risk characteristics.
Establish arrangements with other Federal agencies that administer Government-guaranteed loan programs to facilitate information sharing and
proactive identification of risk.
Develop and implement processes and procedures for the routine sharing, receipt, and storage of confidential information with Federal agencies that administer Government-guaranteed loan programs.
Develop and implement guidance to provide instruction to FDIC bank examination staff requiring communication and information sharing with Federal agencies that administer Government-guaranteed loan programs to ensure FDIC staff and the Federal agencies are aware of any emerging risks.
Determine whether other Federal agencies that administer Government-guaranteed loan programs have a list of FDIC-supervised banks with high risk factors associated with such programs and develop protocols to share information with relevant FDIC personnel, including examiners.
Develop and implement guidance to ensure relevant risk information exchanged with Federal Government agencies that administer Government-guaranteed loan programs is shared internally within the FDIC on an ongoing basis with the appropriate FDIC employees.
Develop and implement updated FDIC examination guidance to establish an appropriate timeframe for uploading complete supervisory business records to RADD.
Develop and implement guidance to examination staff to ensure the staff consistently evaluate Government-guaranteed loans in their review of loan classification, assessment of off-balance sheet risk, concentration risk, and ongoing monitoring.
Update and implement the Examination Profile Script to include additional questions on financial institution participation in Government-guaranteed loan programs in order to identify and address emerging risk.
Develop and implement additional items to the Safety and Soundness Request List to identify Government-guaranteed loans, the performance of those loans, and status of the guaranty.
Issue and implement guidance to require that examination staff conduct a fraud risk assessment on future Government-guaranteed loan programs involving FDIC-insured and FDIC-supervised financial institutions to inform policy decisions.
Ensure guidance on future Government-guaranteed loan programs includes all risks associated with such programs and has instructions to allow for consistency in supervisory activities.
Issue and implement guidance for examiners clarifying the FDIC supervisory expectations for reviewing bank PPP activities, including the level of PPP loan volume triggering a heightened review, how examiners should assess the PPP activities of banks that have existing BSA/AML weaknesses, and protocols for examination staff to communicate observed weaknesses.
Revise and implement FDIC guidance and practices for assessing concentrations and loan classification to ensure uniform application with the other Federal bank regulators of supervisory approaches to banks
Coordinate with the other Federal bank regulators to ensure uniform application of supervisory approaches to banks regarding concentrations and loan classification.
Medicare Improperly Paid Providers for Some Psychotherapy Services, Including Those Provided via Telehealth, During the First Year of the COVID-19 Public Health Emergency
We recommend that the Centers for Medicare & Medicaid Services work with the MACs to recover $35,560 in improper payments made to providers for the 128 sampled enrollee days that did not meet Medicare requirements.
We recommend that the Centers for Medicare & Medicaid Services work with the MACs to based upon the results of this audit, notify appropriate providers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the providers can 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.
Now that CMS has reinstituted most program integrity measures, we also recommend that CMS take the following steps, which if in effect during the audit period could have saved Medicare an estimated $579,667,510 during that period: Conduct medical reviews of psychotherapy services, including services provided via telehealth, to verify that the services are documented and billed in accordance with Medicare requirements.
Now that CMS has reinstituted most program integrity measures, we also recommend that CMS take the following steps, which if in effect during the audit period could have saved Medicare an estimated $579,667,510 during that period: Implement system edits for psychotherapy services, including services provided via telehealth, to prevent payments for services that were billed incorrectly.
Now that CMS has reinstituted most program integrity measures, we also recommend that CMS take the following steps, which if in effect during the audit period could have saved Medicare an estimated $579,667,510 during that period: Strengthen educational efforts to make providers aware of educational materials on how to meet Medicare requirements and guidance for psychotherapy services, including services provided via telehealth.
Now that CMS has reinstituted most program integrity measures, we also recommend that CMS work with the MACs to take the following steps, which if in effect during the audit period could have saved Medicare an estimated $579,667,510 during that period: Review MAC jurisdictions' LCD requirements for psychotherapy services to identify which provisions effectively promote program integrity, and consider additional steps that CMS could undertake to ensure appropriate coverage and payment for psychotherapy services across all jurisdictions.
Audit of DoD Actions Taken to Implement Cybersecurity Protections Over Remote Access Software in the Coronavirus Disease–2019 Telework Environment
Rec. A.1: The DoD OIG recommended that the Director of the U.S. Southern Command - Joint Interagency Task Force South Command, Control, Communications, Computers, Cyber and Intelligence direct its network administrators to scan the VMware Horizon main virtual desktop for malware in accordance with the McAfee Endpoint Security Technical Implementation Guide, develop compensating controls, or formally accept the risk of not scanning the main virtual desktop.
Rec. A.2.a: The DoD OIG recommended that the Chief Information Officer of the Department of the Air Force revise its policy to align with the Windows 10 Security Technical Implementation Guide requirement for disabling inactive user accounts after no more than 35 days.
Rec. A.2.b: The DoD OIG recommended that the Chief Information Officer of the Department of the Air Force direct network and system administrators to disable inactive user accounts after no more than 35 days of inactivity in accordance with the Windows 10 Security Technical Implementation Guide, develop compensating controls, or formally accept the risk of not disabling the inactive user accounts.
Rec. A.3: The DoD OIG recommended that the Chief Information Officer of the Naval Surface Warfare Center - Panama City Division direct network and system administrators to disable inactive user accounts after no more than 35 days of inactivity in accordance with the Windows 10 Security Technical Implementation Guide, develop compensating controls, or formally accept the risk of not disabling the inactive user accounts.
Rec. A.4.a: The DoD OIG recommended that the Chief Information Officer of the Defense Intelligence Agency revise its policy to align with the Windows 10 Security Technical Implementation Guide requirement for disabling inactive users after no more than 35 days.
Rec. A.4.b: The DoD OIG recommended that the Chief Information Officer of the Defense Intelligence Agency direct network and system administrators to disable inactive user accounts after no more than 35 days of inactivity in accordance with the Windows 10 Security Technical Implementation Guide, develop compensating controls, or formally accept the risk of not disabling the inactive user accounts.
Rec. A.5.a: The DoD OIG recommended that the Director of the Marine Corps Information Command, Control, Communications, and Computers revise the organization's policy to align with the Windows 10 Security Technical Implementation Guide requirement for disabling inactive users after no more than 35 days.
Rec. A.5.b: The DoD OIG recommended that the Director of the Marine Corps Information Command, Control, Communications, and Computers direct network and system administrators to disable inactive user accounts after no more than 35 days of inactivity in accordance with the Windows 10 Security Technical Implementation Guide, develop compensating controls, or formally accept the risk of not disabling the inactive user accounts.
Rec. A.6: The DoD OIG recommended that the Director of the Defense Information Systems Agency Joint Service Provider direct network and system administrators to disable inactive user accounts after no more than 35 days of inactivity in accordance with the Windows 10 Security Technical Implementation Guide, develop compensating controls, or formally accept the risk of not disabling the inactive user accounts.
Rec. B.1: The DoD OIG recommended that the Director of the Defense Information Systems Agency Joint Service Provider direct network and system administrators to revise the vulnerability management program to include mitigation timeframes for all vulnerabilities and develop plans of actions and milestones for all vulnerabilities that cannot be mitigated in a timely manner.
The Bureau of Indian Affairs Great Plains Region Did Not Oversee CARES Act Funds Appropriately
We recommend that the BIA Great Plains Region develop and implement a process to acquire the delinquent CARES Act Federal Financial Reports and Annual Narrative Reports identified in the Attachment of this management advisory.
We recommend that the BIA Great Plains Region develop a process to identify and address any other delinquent CARES Act Federal Financial Reports and Annual Narrative Reports.
We recommend that the BIA Great Plains Region develop and implement written policies and procedures that describe the roles and responsibilities of BIA officials and the review processes for Federal Financial Reports and Annual Narrative Reports to ensure submitted reports are complete, accurate, and address areas of concern.
We recommend that the BIA Great Plains Region in accordance with developed and implemented written policies and procedures, provide and track annual training for BIA officials responsible for reviewing Federal Financial Reports and Annual Narrative Reports.