oversight

Audit of Global Omnibus Budget Reconciliation Act of 1990 Claims for BlueCross and BlueShield Plans

Published by the Office of Personnel Management, Office of Inspector General on 2016-06-17.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

  U.S. OFFICE OF PERSONNEL MANAGEMENT
     OFFICE OF THE INSPECTOR GENERAL
              OFFICE OF AUDITS




                Final Audit Report
                       AUDIT OF
         GLOBAL OMNIBUS BUDGET RECONCILIATION
                 ACT OF 1990 CLAIMS FOR
            BLUECROSS AND BLUESHIELD PLANS
                                             Report Number 1A-99-00-15-047

                                                               June 17, 2016




                                                                 -- CAUTION –
This audit report has been distributed to Federal officials who are responsible for the administration of the audited program. This audit report may
contain proprietary data which is protected by Federal law (18 U.S.C. 1905). Therefore, while this audit report is available under the Freedom of
Information Act and made available to the public on the OIG webpage (http://www.opm.gov/our-inspector-general), caution needs to be exercised
before releasing the report to the general public as it may contain proprietary information that was redacted from the publicly distributed copy
             EXECUTIVE SUMMARY 

                     Audit of Global Omnibus Budget Reconciliation Act of 1990 Claims

Report No. 1A-99-00-15-047                                                                        June 17, 2016

Why Did We Conduct The Audit?             What Did We Find?

The objectives of our audit were to       Our audit identified several erroneous claim payments that we
determine whether the Blue Cross and
                                          believe are indicative of minor systemic control problems.
Blue Shield (BCBS) plans charged
costs to the Federal Employees Health
                                          Although the Association generally has adequate procedures in
Benefits Program (FEHBP) and              place to properly price and pay OBRA 90 claims, we identified
provided services to the FEHBP            two system enhancements that would result in a cost savings to the
members in accordance with the terms      FEHBP.
of the contract with the U.S. Office of
Personnel Management. Specifically,       However, we conclude that the overall processing of FEHBP
our objective was to determine
                                          OBRA 90 claims by the BCBS plans appear to be in compliance
whether the BCBS plans complied
with contract provisions relative to
                                          with the terms of its contract with the U.S Office of Personnel
claims paid in accordance with the        Management and industry standards.
Omnibus Budget Reconciliation Act
of 1990 (OBRA 90).                        The report questions $9,937,273 in health benefit charges.

What Did We Audit?

The Office of the Inspector General
has completed a limited scope
performance audit of the FEHBP
operations at all BCBS plans. The
audit covered claim payments from
January 1, 2012 through April 30,
2015, as reported in the Blue Cross
and Blue Shield Association’s
Government-wide Service Benefit
Plan Annual Accounting Statements.
Specifically, we identified claims
from this period that were subject or
possibly subject to the OBRA 90
pricing guidelines.




 _______________________
 Michael R. Esser
 Assistant Inspector General
 for Audits
                                                      i
              ABBREVIATIONS


Association   Blue Cross Blue Shield Association
BCBS          Blue Cross Blue Shield
CMS           Center for Medicare and Medicaid Services
DO            Director’s Office
FEHB          Federal Employees Health Benefits
FEHBP         Federal Employees Health Benefits Program
FEP           Federal Employee Program
FEP OC        Federal Employee Program Operations Center
OBRA 90       Omnibus Budget Reconciliation Act of 1990
OPM           U. S. Office of Personnel Management
Plan(s)       Blue Cross and Blue Shield Plan(s)




                           ii
IV. MAJOR CONTRIBUTORS TO THIS REPORT
          TABLE OF CONTENTS

                                                                                                                         Page 

          EXECUTIVE SUMMARY ......................................................................................... i 


          ABBREVIATIONS ..................................................................................................... ii 


  I.	     BACKGROUND ..........................................................................................................1 


  II.	    OBJECTIVES, SCOPE, AND METHODOLOGY ..................................................3 


  III.	   AUDIT FINDING AND RECOMMENDATIONS...................................................6 


          Global Omnibus Budget Reconciliation Act of 1990 ....................................................6 


  IV.	    MAJOR CONTRIBUTORS TO THIS REPORT ..................................................11 


          APPENDIX: Blue Cross Blue Shield Association’s August 24, 2015 response to the
                    Draft Audit Report, issued June 23, 2015.

          REPORT FRAUD, WASTE, AND MISMANAGEMENT
IV. MAJOR CONTRIBUTORS
            I. BACKGROUND
                       TO THIS REPORT

This final audit report details the findings, conclusions, and recommendations resulting from our
limited scope audit of the Federal Employees Health Benefits Program (FEHBP) operations at all
Blue Cross and Blue Shield (BCBS) plans. The audit was performed by the U.S. Office of
Personnel Management’s (OPM) Office of the Inspector General (OIG), as authorized by the
Inspector General Act of 1978, as amended.

The FEHBP was established by the Federal Employees Health Benefits (FEHB) Act (Public Law
86-382), enacted on September 28, 1959. The FEHBP was created to provide health insurance
benefits for federal employees, annuitants, and dependents. OPM’s Healthcare and Insurance
Office has overall responsibility for administration of the FEHBP. The provisions of the FEHB
Act are implemented by OPM through regulations, which are codified in Title 5, Chapter 1, Part
890 of the Code of Federal Regulations. Health insurance coverage is made available through
contracts with various health insurance carriers.

The Blue Cross Blue Shield Association (Association), on behalf of participating BCBS plans,
has entered into a Government-wide Service Benefit Plan contract (CS 1039) with OPM to
provide a health benefit plan authorized by the FEHB Act. The Association delegates authority
to participating local BCBS plans throughout the United States to process the health benefit
claims of its federal subscribers. There are 64 local BCBS plans participating in the FEHBP.

The Association has established a Federal Employee Program (FEP1) Director’s Office (DO) in
Washington, D.C. to provide centralized management for the Service Benefit Plan. The FEP DO
coordinates the administration of the contract with the Association, member BCBS plans, and
OPM.

The Association has also established an FEP Operations Center (OC). The activities of the
FEP OC are performed by CareFirst BlueCross BlueShield, located in Washington, D.C. These
activities include acting as fiscal intermediary between the Association and member plans,
verifying subscriber eligibility, approving or disapproving the reimbursement of local plan
payments of FEHBP claims (using computerized system edits), maintaining a history file of all
FEHBP claims, and maintaining an accounting of all program funds.




1
  Throughout this report, when we refer to "FEP", we are referring to the Service Benefit Plan lines of business at
the Plan(s). When we refer to the "FEHBP", we are referring to the program that provides health benefits to federal
employees.

                                                         1                                Report No. 1A-99-00-15-047
Compliance with laws and regulations applicable to the FEHBP is the responsibility of the
Association and Plan management. Also, management of each BCBS plan is responsible for
establishing and maintaining a system of internal controls.

Findings from our previous global OBRA 90 audit of all BCBS plans (Report No. 1A-99-00-09-
046, dated July 19, 2010) for claims reimbursed from January 1, 2006 through May 31, 2009,
have been resolved.

Our sample selections, instructions, and preliminary audit results of the potential OBRA 90
errors were presented to the Association in a draft report, dated June 23, 2015. The
Association’s comments offered in response to the draft report were considered in preparing our
final report and are included as an Appendix to this report. Also, additional documentation
provided by the Association and BCBS plans on various dates through February 23, 2016 was
considered in preparing our final report.




                                               2                   Report No. 1A-99-00-15-047
IV. OBJECTIVES,
II.  MAJOR CONTRIBUTORS
                SCOPE, ANDTO THIS REPORT
                          METHODOLOGY

 Objectives
 The objectives of our audit were to determine whether the BCBS plans charged costs to the
 FEHBP and provided services to the FEHBP members in accordance with the terms of the
 contract. Specifically, our objective was to determine whether the plans complied with contract
 provisions relative to claims paid in accordance with Omnibus Budget Reconciliation Act of
 1990 (OBRA 90) pricing guidelines.

 Scope
 Generally, OBRA 90 limits the benefit payments for certain inpatient hospital services provided
 to annuitants age 65 or older who are not covered under Medicare Part A. The FEHBP fee-for-
 service plans are required to limit the claim payments to the amount equivalent to the Medicare
 Part A payment.

 The audit covered health benefit payments from January 1, 2012 through April 30, 2015, as
 reported in the Blue Cross and Blue Shield Association’s Government-wide Service Benefit Plan
 FEP Annual Accounting Statements. To test each BCBS plan’s compliance with the FEHBP
 health benefit provisions relative to claims that are subject to OBRA 90 pricing guidelines, we
 performed a computer search on our claims data warehouse to identify all BCBS claims that were
 subject or potentially subject to OBRA 90 pricing guidelines from January 1, 2012 through
 April 30, 2015. This universe is comprised of claims for two distinct categories. The first
 category, “OBRA 90,” consists of claims that were priced in accordance with OBRA 90 pricing
 guidelines. From this category, we judgmentally selected for review all claims with amounts paid
 of $20,000 or more. The second category, “Possible OBRA 90,” consists of claims that appear
 should have priced in accordance with OBRA 90 pricing guidelines, but the Plans’ local pricing
 was applied instead. From this category, we judgmentally selected for review all claims with
 amounts paid of $10,000 or more. See Exhibit I for a summary of our OBRA 90 claims universe
 and sample selections. We did not project the results of our review to the universe of potentially
 overpaid claims.

          Exhibit I – Summary of OBRA 90 Claims Universe and Sample Selections

                                   Universe Totals in Scope          Sample Selection Totals
       Claim Category
                                   Claims     Amount Paid           Claims     Amount Paid
 1. OBRA 90                                                          3,232        $120,254,172
 2. Possible OBRA 90                                                 2,359         $64,284,596
 Totals                                                              5,591        $184,538,768



                                                 3                   Report No. 1A-99-00-15-047
Methodology
The claims selected for review were submitted to each BCBS plan for their review and response.
We then conducted a limited review of the plans’ “paid correctly” responses and an expanded
review of the plans’ “paid incorrectly” responses. Specifically, we verified supporting
documentation and the accuracy and completeness of the plans’ responses, determined if the
claims were paid correctly, and/or calculated the appropriate questioned amounts for the claim
payment errors. Additionally, we verified on a limited test basis if the BCBS plans had initiated
recovery efforts, adjusted or voided the claims, and/or completed the recovery process by the
audit request due date (i.e., July 24, 2015) for the claim payment errors in our sample.

The determination of the questioned amount is based on the FEHBP contract, the 2012 through
2015 Service Benefit Plan brochures, the Association’s FEP Procedures Administrative Manual
and OBRA 90 pricing guidelines.

We conducted our limited scope performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform the audit to
obtain sufficient and appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.

We did not consider each BCBS plan’s internal control structure in planning and conducting our
auditing procedures. Our audit approach consisted mainly of substantive tests of transactions
and not tests of controls. Therefore, we do not express an opinion on each BCBS plan’s system
of internal controls taken as a whole.

We also conducted tests to determine whether the BCBS plans had complied with the contract
and the laws and regulations governing the FEHBP as they relate to claims paid in accordance
with OBRA 90 pricing guidelines. The results of our tests indicate that, with respect to the items
tested, the BCBS plans did not fully comply with the provisions of the contract relative to the
pricing and paying of OBRA 90 claims. Exceptions noted are explained in detail in the “Audit
Findings and Recommendations” section of this report. With respect to the items not tested,
nothing came to our attention that caused us to believe that the BCBS plans had not complied, in
all material respects, with these provisions.

In conducting our audit, we relied to varying degrees on computer-generated data provided by
the FEP DO, the FEP OC, and the BCBS plans. Through audits and a reconciliation process, we
have verified the reliability of the BCBS claims data in our data warehouse, which was used to
identify the universe of OBRA 90 or potential OBRA 90 claims. The BCBS claims data is


                                                4                   Report No. 1A-99-00-15-047
provided to us on a monthly basis by the FEP OC, and after a series of internal steps, uploaded
into our data warehouse. However, due to time constraints, we did not verify the reliability of
the data generated by the BCBS plans’ local claims systems. While utilizing the computer-
generated data during our audit testing, nothing came to our attention to cause us to doubt its
reliability. We believe that the data was sufficient to achieve our audit objectives.

Audit fieldwork was performed at our offices in Washington, D.C.; Cranberry Township,
Pennsylvania; and Jacksonville, Florida through February 2016.




                                                5                   Report No. 1A-99-00-15-047
 IV. AUDIT
III. MAJORFINDING
           CONTRIBUTORS  TO THIS REPORT
                  AND RECOMMENDATIONS
 Global Omnibus Budget Reconciliation Act of 1990 	                                   $9,937,273

 As mentioned in the scope section above, we selected for review high dollar claims that were
 subject to or potentially subject to the OBRA 90 pricing guidelines to determine whether the
 BCBS plans complied with contract provisions relative to OBRA 90 pricing guidelines. We
 consider these specific claim payments to be at high risk for overpayments based on previous
 audit experiences.

 Our review determined that the BCBS plans overpaid 686 of these claims by $10,792,073 and
 underpaid 143 of these claims by $854,800. In total, the BCBS plans incorrectly paid 829
 claims, resulting in net overcharges of $9,937,273 to the FEHBP. See Exhibit II for a summary
 of questioned costs.

                          Exhibit II – Summary of Questioned Costs

                           Overpaid Totals            Underpaid Totals      Net Questioned Totals
   Claim Category                  Amount                     Amount
                         Claims                      Claims                Claims    Amount Paid
                                    Paid                        Paid
 1. OBRA 90               429    $6,565,331           100    ($516,163)      529       $6,049,168
 2. Possible OBRA 90      257    $4,226,742            43    ($338,637)      300       $3,888,105
 Totals                   686    $10,792,073          143    ($854,800)      829       $9,937,273

 These 829 claim payment errors are comprised of the following:
 	 250 claims were questioned due to manual processing errors, such as applying incorrect
    Medicare DRG coding or allowances, applying incorrect patient transfer codes, and using
    incorrect billed amounts, resulting in net overcharges of $3,943,777 to the FEHBP.

 	 418 claims were priced with outdated Medicare effective rates, resulting in net overcharges
    of $2,911,375 to the FEBHP. At the time these claims were priced, the FEP Express system
    had not been updated with the most recent Center for Medicare and Medicaid Services
    (CMS) pricing rates. Although the FEP Express system is updated annually with the CMS
    effective rates, the system is not updated when CMS releases monthly or quarterly pricing
    changes, which in this case would have resulted in savings to the FEHBP.

    In general, OBRA 90 claim payments should be limited to the amount equivalent to the
    Medicare Part A allowances. CMS releases various pricing adjustments quarterly, and these
    adjustments decrease Medicare inpatient hospital payment allowances, which ultimately
    results in payment savings. The FEP OC updates the Medicare inpatient hospital payment

                                                6	                  Report No. 1A-99-00-15-047
    rates yearly in the FEP Express system. However, updating the FEP Express system with
    quarterly releases would result in an ongoing savings to the FEHBP year-after-year.

	 81 claims were questioned due to FEP Express system processing errors, resulting in net
   overcharges of $2,225,093 to the FEHBP. In most instances, the claims bypassed OBRA 90
   pricing edits in the FEP Express system due to the fact that
                                                                      Our review determined
   that if the FEP Express system had identified that an                                 was
   on file during the processing of these claims, the OBRA 90 allowance would have been
   properly applied.

	 22 claims were questioned due to provider billing errors, such as providing an incorrect
   Medicare provider number or incorrect claim information, resulting in net overcharges of
   $279,386 to the FEHBP.

	 18 claims were questioned due to the BCBS plans incorrectly pricing claims that were not
   subject to OBRA 90 pricing guidelines, resulting in net overcharges of $219,651 to the
   FEHBP. In these instances the local plans’ pricing allowances were applied; however, the
   incorrect pricing amount, discount, or pricing method was used during the processing of the
   claims.

	 24 claims were questioned due to the BCBS plans not applying or incorrectly applying
   Medicare B payments, resulting in net overcharges of $203,258 to the FEHBP.

	 16 claims were questioned due to local system processing errors, resulting in net overcharges
   of $154,733 to the FEHBP. In most instances, these errors were due to changes in the BCBS
   plans’ local system or because the plans’ local system did not properly accept the OBRA 90
   pricing from the FEP Express system.

Contract CS 1039, Part III, section 3.2 (b)(1) states, “The Carrier may charge a cost to the
contract for a contract term if the cost is actual, allowable, allocable, and reasonable. . . . [and] on
request, document and make available accounting support for the cost to justify that the cost is
actual, reasonable and necessary; and (ii) determine the cost in accordance with: (A) the terms
of this contract . . . .” Part II, section 2.3(g) states, “If the Carrier [or OPM] determines that a
Member’s claim has been paid in error for any reason . . . the Carrier shall make a prompt and
diligent effort to recover the erroneous payment . . . .”

Contract CS 1039, Part II, section 2.6 states, “(a) The Carrier shall coordinate the payment of
benefits under this contract with the payment of benefits under Medicare . . . (b) The Carrier



                                                   7	                   Report No. 1A-99-00-15-047
shall not pay benefits under this contract until it has determined whether it is the primary carrier .
. . .”

Association Response:

In its response to the draft report the Association stated that $8,819,863 in overpayments were
made and states,
	 “For OBRA ’90 priced claims, when the claims were repriced using the FEPOC
     Mainframe OBRA’ 90 pricer, the repriced claims resulted in a savings to the FEP
     Program of $2,168,538
	 For OBRA ’90 priced claims, when the claims were re-priced using the FEPOC
     Mainframe OBRA ’90 pricer, overpayments totaling $3,711,726 were identified.
	 For Possible OBRA ‘90 claims, when the claims were reviewed by Plans and/or repriced
     with the Mainframe OBRA ’90 pricer, overpayments totaling $2,939,599 were identified.
     The overpayments were the result of manual processor errors, billing errors or other
     miscellaneous reasons.”

The Association also states, “Where possible, Plans have initiated recovery as required by CS
1039, Section 2.3 (g)(l). Any benefit payments the Plans are unable to recover and where due
diligence is demonstrated are allowable charges to the Program. In addition, as good faith
erroneous payments, lost investment income does not apply.”

Regarding corrective actions, the Association states, “BCBSA is evaluating the Plans responses
to determine any additional corrective actions that can be taken to enhance OBRA ’90
processing. We will provide those recommendations to the Contracting Office once
completed.”

OIG Comments:

Based on the Association’s response and documentation provided by the BCBS plans, we
determined that the BCBS plans acknowledge that $9,937,273 in claim net overpayments were
made since the start of our audit. Although the Association only acknowledges $8,819,863 in net
overcharges in its written response, the BCBS plans’ documentation supports concurrence with
$9,937,273. If claim overpayments were identified by the BCBS plans before our audit
notification date (i.e., June 2, 2015) and adjusted or voided by the draft report response due date
(i.e., July 24, 2015), we did not consider these as claim payment errors in this final audit report.

Acknowledged Claim Payment Overpayments 

The $9,937,273 of acknowledged claim overpayments is comprised of the following: 




                                                  8	                   Report No. 1A-99-00-15-047
 $9,018,626 represents claim net overpayments for which the BCBS plans have committed to
  pursue recovery2.
 $918,647 represents claim net overpayments for which the BCBS plans did not initiate
  recovery because a) they believe they were restricted by contract limitations or b) that
  recovery efforts had been exhausted. However, we continue to question these costs because
  the BCBS Plans are required by contract CS 1039 to attempt recovery regardless of provider
  contract limitations, or because they have not provided us with documentation supporting that
  all recovery efforts have been exhausted.

Recommendation 1

We recommend that the contracting officer disallow $10,792,073 for claim overpayments and
verify that the BCBS plans return all amounts recovered to the FEHBP.

Recommendation 2

We recommend that the contracting officer allow the BCBS plans to charge the FEHBP
$854,800 if additional payments are made to the providers to correct the underpayments.

Recommendation 3

We recommend that the contracting officer require the Association to enhance the FEP Express
system by adding an edit that automatically defers claims where
                                                          when being automatically priced as
OBRA 90. If determined cost effective, the contracting officer should ensure the Association
implements an automated process to utilize the Medicare provider number files issued by CMS.

Recommendation 4

Due to the ongoing savings identified year after year with the FEP OC using monthly and/or
quarterly CMS pricing releases, we recommend that the contracting officer require the
Association to perform a risk analysis to determine if it is cost effective to implement a process
to include CMS pricing updates in the FEP Express system at the time the updates are released.




2
  Although the Association acknowledges that there were $9,018,626 in claim payment errors, it contends that
$678,956 of this amount should not be labeled as “questioned” because the BCBS Plans initiated recovery efforts
before they received our claims sample. However, Contract CS 1039 states that claims should be reported as
questioned charges unless the plans initiated recovery prior to receiving notification of the audit. Recovery efforts
for all of these claim overpayments began after the notification letter was issued; therefore, we continue to label the
entire $9,018,626 as questioned costs.

                                                           9                        Report No. 1A-99-00-15-047
Recommendation 5

We recommend that the contracting officer require the Association to provide an analysis of
corrective actions, as stated in the response to our draft report, to the contracting office and
implement the necessary procedures or system enhancements based on this review.




                                                 10                   Report No. 1A-99-00-15-047
IV. MAJOR CONTRIBUTORS TO THIS REPORT

Information Systems Audits Group

           , Lead Auditor

             , Lead Auditor

                            , Auditor


           , Senior Team Leader

             , Group Chief




                                        11   Report No. 1A-99-00-15-047
                                         APPENDIX 



                                                                                  Federal Employee Program
                                                                                  1310 G Street, N.W.
                                                                                  Washington, D.C. 20005
                                                                                  202.942.1000
                                                                                  Fax 202.942.1125
August 24, 2015


Group Chief
Experience-Rated Audits Group
Office of the Inspector General
U.S. Office of Personnel Management
1900 E Street, N.W., Room 6400
Washington, D.C. 20415

Reference:            OPM DRAFT AUDIT REPORT
                      Global OBRA ‘90 & Possible OBRA ‘90
                      Audit Report 1A-99-00-15-047

Dear           :

This is in response to the above referenced U.S. Office of Personnel Management (OPM) Draft
Audit Report concerning the Global OBRA ‘90 and Possible OBRA ‘90 Claim Payments Audit
of the FEP Blue Cross Blue Shield Plans. Our comments concerning the recommendations in the
report are as follows:

Recommendation 1

We recommend that the contracting officer disallow the claims overcharges (to be determined
and included in the final report) and have the BCBS Plans return all amounts recovered to the
FEHBP.

BCBSA Response

After reviewing 3,232 claims totaling $120,254,172 that were subject to OBRA ’90 pricing
guidelines and 1,624 claims totaling $49,707,302 that were possibly subject to OBRA ’90
pricing, BCBS Plans determined the following:

	 For OBRA ’90 priced claims, when the claims were repriced using the FEPOC Mainframe
   OBRA’ 90 pricer, the repriced claims resulted in a savings to the FEP Program of $2,168,538




                                                                   Report No. 1A-99-00-15-047
   For OBRA ’90 priced claims, when the claims were re-priced using the FEPOC Mainframe
    OBRA ’90 pricer, overpayments totaling $3,711,726 were identified.
   For Possible OBRA ‘90 claims, when the claims were reviewed by Plans and/or repriced
    with the Mainframe OBRA ’90 pricer, overpayments totaling $2,939,599 were identified.
    The overpayments were the result of manual processor errors, billing errors or other
    miscellaneous reasons.

Where possible, Plans have initiated recovery as required by CS 1039, Section 2.3 (g)(l). Any
benefit payments the Plans are unable to recover and where due diligence is demonstrated are
allowable charges to the Program. In addition, as good faith erroneous payments, lost
investment income does not apply.

Recommendation 2

Although the Association has developed a corrective action plan to reduce OBRA 90 findings,
we recommend that the contracting officer instruct the Association to ensure that the BCBS plans
are following the corrective action plan. If the Association identifies additional correction
actions based on our audit review, provide the additional corrective actions as part of the
Association’s response to the draft report.

BCBSA Response

BCBSA is evaluating the Plans responses to determine any additional corrective actions that can
be taken to enhance OBRA ’90 processing. We will provide those recommendations to the
Contracting Office once completed.

We appreciate the opportunity to provide our response to the finding and request that our
comments be included in their entirety as part of the Final Audit Report.

Sincerely,




Managing Director, Program Assurance
Federal Employee Program




                                                                    Report No. 1A-99-00-15-047
                                                                                                                         



                                       Report Fraud, Waste, and 

                                           Mismanagement 

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                                               Government concerns everyone: Office of
                                                   the Inspector General staff, agency
                                                employees, and the general public. We
                                              actively solicit allegations of any inefficient
                                                    and wasteful practices, fraud, and
                                               mismanagement related to OPM programs
                                              and operations. You can report allegations
                                                          to us in several ways:


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                                                   1900 E Street, NW
                                                   Room 6400
                                                   Washington, DC 20415-1100
                     
                                                                                                                         
                                                                                                                         




                                                             -- CAUTION --
This audit report has been distributed to Federal officials who are responsible for the administration of the audited program. This audit report may
contain proprietary data which is protected by Federal law (18 U.S.C. 1905). Therefore, while this audit report is available under the Freedom of
Information Act and made available to the public on the OIG webpage (http://www.opm.gov/our-inspector-general), caution needs to be exercised
before releasing the report to the general public as it may contain proprietary information that was redacted from the publicly distributed copy.