oversight

Audit of Hawaii Medical Service Association Honolulu, Hawaii

Published by the Office of Personnel Management, Office of Inspector General on 2018-06-11.

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

862)),CE OF PERSONNEL MANAGEMENT
   OFFICE OF THE INSPECTOR GENERAL
            OFFICE OF AUDITS




   Final Audit Report

               AUDIT OF
   HAWAII MEDICAL SERVICE ASSOCIATION
           HONOLULU, HAWAII

          Report Number 1D-87-00-17-038
                  June 11, 2018
               EXECUTIVE SUMMARY
                                Audit of Hawaii Medical Service Association

Report No. 1D-87-00-17-038                                                                            June 11, 2018



 Why did we conduct the audit?             What did we find?
 We conducted this limited scope audit     We questioned $1,208,306 in cash management activities and lost
 to obtain reasonable assurance that       investment income (LII). We also identified a procedural finding
 Hawaii Medical Service Association        regarding the Plan’s Fraud and Abuse Program. The Plan agreed with
 (Plan) is complying with the provisions   all of the questioned amounts and the procedural finding for the
 of the Federal Employees Health           Fraud and Abuse Program.
 Benefits Act and regulations that are
                                           Our audit results are summarized as follows:
 included, by reference, in the Federal
 Employees Health Benefits Program         •   Miscellaneous Health Benefit Payments and Credits – The audit
 (FEHBP) contract. The objectives of           disclosed no significant findings pertaining to miscellaneous
 our audit were to determine if the Plan       health benefit payments and credits, except for the finding
 charged costs to the FEHBP and                pertaining to the Plan’s improper management of FEHBP funds
 provided services to FEHBP members            noted in the “Cash Management” section. Overall, we
 in accordance with the contract.              concluded that the Plan returned health benefit refunds and
                                               recoveries, including pharmacy drug rebates, to the FEHBP and
 What did we audit?                            properly charged miscellaneous payments to the FEHBP.
 Our audit covered miscellaneous health    •   Administrative Expenses – The audit disclosed no findings
 benefit payments and credits, such as         pertaining to administrative expenses. Overall, we concluded that
 refunds and pharmacy drug rebates,            the Plan’s administrative expenses charged to the FEHBP were
 from 2012 through February 2017, and          actual, allowable, necessary, and reasonable expenses incurred in
 administrative expenses from 2012             accordance with the contract and applicable laws and regulations.
 through 2016. We also reviewed the        •   Cash Management – We determined that the Plan held an excess
 Plan’s cash management activities and         working capital deposit of $1,132,580 in the dedicated FEHBP
 practices related to FEHBP funds from         investment account as of June 30, 2017. We also questioned a net
 2012 through February 2017, and the           amount of $75,726 because the Plan improperly managed funds,
 Plan’s Fraud and Abuse Program for            consisting of $86,604 (net) owed to the Plan for reimbursable
 2015 and 2016. Due to concerns with           costs and $162,330 due to the FEHBP for LII calculated on funds
 the Plan’s working capital funds and          deposited untimely into the dedicated FEHBP investment account.
 management of FEHBP funds, we
                                           •   Fraud and Abuse Program – We determined that the Plan is not in
 expanded our scope to also include
                                               compliance with the communication and reporting requirements
 these funds from March 2017 through
                                               for fraud and abuse cases that are set forth in FEHBP Carrier
 June 2017 and July 2017, respectively.
                                               Letter 2014-29. We also identified several non-compliance issues
                                               regarding the Plan’s Fraud and Abuse Program policies and
                                               procedures and 2016 Annual Fraud, Waste, and Abuse Report.


  Michael R. Esser
  Assistant Inspector General
  for Audits                                           i
	
                    ABBREVIATIONS


CFR            Code of Federal Regulations
CL             Carrier Letter
FAR            Federal Acquisition Regulations
FEHB           Federal Employees Health Benefits
FEHBAR         Federal Employees Health Benefits Acquisition Regulations
FEHBP          Federal Employees Health Benefits Program
FWA            Fraud, Waste, and Abuse
Guidelines     Letter of Credit System Guidelines
HMO            Health Maintenance Organization
HMSA or Plan   Hawaii Medical Service Association
LII            Lost Investment Income
OIG            Office of the Inspector General
OPM            U.S. Office of Personnel Management
PBM            Pharmacy Benefit Manager
SIU            Special Investigations Unit




                                     ii
	
                        TABLE OF CONTENTS

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

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

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

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

III.   AUDIT FINDINGS AND RECOMMENDATIONS.................................................8
	

       A. MISCELLANEOUS HEALTH BENEFIT PAYMENTS AND CREDITS ...........8

       B. ADMINISTRATIVE EXPENSES...........................................................................8
	

       C. CASH MANAGEMENT .........................................................................................8
	

            1. Excess Working Capital Deposit .......................................................................8
	
            2. Improper Management of Funds......................................................................11
	

       D. FRAUD AND ABUSE PROGRAM .....................................................................15
	

            1. Special Investigations Unit ..............................................................................15
	

       APPENDIX: Hawaii Medical Service Association Draft Report Response, dated
       February 16, 2018

       REPORT FRAUD, WASTE, AND MISMANAGEMENT
                                  I. BACKGROUND

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
the Hawaii Medical Service Association (HMSA or Plan). The Plan is located in Honolulu,
Hawaii.

The audit was performed by the Office of Personnel Management’s (OPM) Office of the
Inspector General (OIG), as established 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 (CFR). Health insurance coverage is made available
through contracts with various health insurance carriers.

The Plan is an experience-rated health maintenance organization (HMO) that provides health
benefits to Federal enrollees and their families.1 Enrollment is open to all Federal employees and
annuitants in the Plan’s service area, which includes all of Hawaii.

The Plan’s contract (CS 1058) with OPM is experience-rated. Thus, the costs of providing
benefits in the prior year, including underwritten gains and losses that have been carried forward,
are reflected in current and future years’ premium rates. In addition, the contract provides that in
the event of termination, unexpended program funds revert to the FEHBP Trust Fund. In
recognition of these provisions, the contract requires that an accounting of program funds be
submitted at the end of each contract year. The accounting is made on a statement of operations
known as the Annual Accounting Statement.

Compliance with laws and regulations applicable to the FEHBP is the responsibility of the Plan’s
management. In addition, management of the Plan is responsible for establishing and
maintaining a system of internal controls.




1
 Members of an experience-rated HMO plan have the option of using a designated network of providers or using
out-of-network providers. A member’s choice in selecting one healthcare provider over another has monetary and
medical implications. For example, if a member chooses an out-of-network provider, the member will pay a
substantial portion of the charges and covered benefits may be less comprehensive.

                                                        1                     Report No. 1D-87-00-17-038
    All findings from our prior audit of the Plan (Report No. 1D-87-00-12-041, dated February 21,
    2013), covering contract years 2007 through 2011, have been satisfactorily resolved.

    The results of this audit were provided to the Plan in written audit inquiries; were discussed with
    Plan officials throughout the audit and at an exit conference on December 21, 2017; and were
    presented in detail in a draft report, dated January 19, 2018. The Plan’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.




                                                     2                   Report No. 1D-87-00-17-038


.
II. OBJECTIVES, SCOPE, AND METHODOLOGY

OBJECTIVES

The objectives of our audit were to determine whether the Plan charged costs to the FEHBP and
provided services to FEHBP members in accordance with the terms of the contract. Specifically,
our objectives were as follows:

       Miscellaneous Health Benefit Payments and Credits

       x	 To determine whether miscellaneous payments charged to the FEHBP were in
          compliance with the terms of the contract.

       x	 To determine whether credits and miscellaneous income, such as refunds and
          pharmacy drug rebates, relating to FEHBP benefit payments were returned timely to
          the FEHBP.

       Administrative Expenses

       x	 To determine whether administrative expenses charged to the contract were actual,
          allowable, necessary, and reasonable expenses incurred in accordance with the terms
          of the contract and applicable regulations.

       Cash Management

       x	 To determine whether the Plan handled FEHBP funds in accordance with the contract
          and applicable laws and regulations concerning cash management in the FEHBP.

       Fraud and Abuse Program

       x	 To determine whether the Plan's communication and reporting of fraud and abuse
          cases were in compliance with the terms of Contract CS 1058 and FEHBP Carrier
          Letter 2014-29.




                                               3		               Report No. 1D-87-00-17-038
SCOPE

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 reviewed the Plan’s Annual Accounting Statements for contract years 2012 through 2016.
During this period, the Plan paid approximately $1.3 billion in FEHBP health benefit payments
and charged the FEHBP $108 million in administrative expenses.


                                  Hawaii Medical Service Association
                                          Contract Charges

                                300


                                200
                   $ Millions




                                100


                                  0
                                       2012      2013       2014       2015     2016
                                                        Contract Years
                                      Health Benefit Payments      Administrative Expenses


Specifically, we reviewed miscellaneous health benefit payments and credits (e.g., cash and auto
recoupment refunds, pharmacy and medical drug rebates, and fraud recoveries) and the Plan’s
cash management activities and practices from 2012 through February 2017, as well as
administrative expenses from 2012 through 2016. We also reviewed the Plan’s Fraud and Abuse
Program activities and practices from 2015 through 2016. Due to concerns with the Plan’s
working capital deposit and management of FEHBP funds, we expanded our scope to also
include these items from March 2017 through June 2017 and July 2017, respectively.

In planning and conducting our audit, we obtained an understanding of the Plan’s internal control
structure to help determine the nature, timing, and extent of our auditing procedures. This was
determined to be the most effective approach to select areas of audit. For those areas selected,
we primarily relied on substantive tests of transactions and not tests of controls. Based on our

                                                           4                     Report No. 1D-87-00-17-038
testing, we did not identify any significant matters involving the Plan’s internal control structure
and its operations. However, since our audit would not necessarily disclose all significant
matters in the internal control structure, we do not express an opinion on the Plan’s system of
internal controls taken as a whole.

We also conducted tests to determine whether the Plan had complied with the contract, the
applicable procurement regulations (i.e., Federal Acquisition Regulations (FAR) and Federal
Employees Health Benefits Acquisition Regulations (FEHBAR), as appropriate), and the laws
and regulations governing the FEHBP. The results of our tests indicate that, with respect to the
items tested, the Plan did not comply with all provisions of the contract and Federal procurement
regulations. Exceptions noted in the areas reviewed are set forth in detail in the "Audit Findings
and Recommendations" section of this audit report. With respect to the items not tested, nothing
came to our attention that caused us to believe that the Plan had not complied, in all material
respects, with those provisions.

In conducting our audit, we relied to varying degrees on computer-generated data provided by
the Plan. Due to time constraints, we did not verify the reliability of the data generated by the
various information systems involved. However, while utilizing the computer-generated data
during our audit, nothing came to our attention to cause us to doubt its reliability. We believe
that the data was sufficient to achieve our audit objectives.

The audit was performed at the Plan’s office in Honolulu, Hawaii from July 18, 2017, through
August 11, 2017. Audit fieldwork was also performed at our offices in Jacksonville, Florida and
Washington, D.C. through January 18, 2018. Throughout the audit process, we encountered
several instances where the Plan responded untimely, or initially provided incomplete responses,
to various requests for explanations and supporting documentation. As a result, completion of
our audit work and issuance of our draft and final reports were delayed.

METHODOLOGY

We obtained an understanding of the internal controls over the Plan’s financial, cost accounting,
and cash management systems by inquiry of Plan officials.

We interviewed Plan personnel and reviewed the Plan’s policies, procedures, and accounting
records during our audit of miscellaneous health benefit payments and credits. For the period
2012 through February 28, 2017, we also judgmentally selected and reviewed the following
FEHBP items:




                                                  5                   Report No. 1D-87-00-17-038
   Health Benefit Refunds

   x	 A high dollar sample of 43 health benefit refund cash receipts, totaling $2,584,993, (from
      a universe of 7,310 FEHBP refund cash receipt amounts, totaling $4,337,870). Our high
      dollar sample included all refund cash receipt amounts of $10,000 or more.

   x	 A high dollar sample of 77 health benefit refunds returned via auto recoupments, totaling
      $18,080,995 (from a universe of 58,445 FEHBP refunds returned via auto recoupments,
      totaling $60,739,354). Our high dollar sample included all auto recoupment amounts of
      $100,000 or more.

   Other Health Benefit Payments, Credits, and Recoveries

   x	 21 high dollar miscellaneous health benefit payment amounts, totaling $15,827,158, from
      a universe of 74 miscellaneous health benefit payment amounts, totaling $54,807,016,
      that were charged to the FEHBP during the audit scope. For this sample, we
      judgmentally selected three or more (a maximum of six) high dollar payment amounts
      from each year for 2012 through 2016. These miscellaneous health benefit payments
      mostly included charges that were applicable to the Plan’s programs for Disease and
      Utilization Management, Quality, and Patient Centered Medical Homes.

   x	 All 24 pharmacy drug rebate amounts, totaling $29,606,340, for the audit scope.

   x	 16 high dollar fraud recoveries, totaling $1,564,384, from a universe of 207 fraud
      recoveries, totaling $2,136,171. For this sample, we selected all fraud recoveries of
      $50,000 or more.

   x	 24 high dollar subrogation recoveries, totaling $829,781, from a universe of 312
      subrogation recoveries, totaling $1,134,077. For this sample, we selected all
      subrogation recoveries of $10,000 or more.

   x	 All 28 medical drug rebate amounts, totaling $180,169, for the audit scope.

We reviewed these samples to determine if health benefit refunds and recoveries, including
pharmacy and medical drug rebates, were timely returned to the FEHBP and if miscellaneous
payments were properly charged to the FEHBP. Since we did not use statistical sampling, the
results of these samples were not projected to the applicable universes.




                                                6		                Report No. 1D-87-00-17-038
We judgmentally reviewed administrative expenses charged to the FEHBP for contract years
2012 through 2016. Specifically, we reviewed administrative expenses relating to the
Patient Protection and Affordable Care Act that were allocated and charged to the FEHBP
(i.e., health insurance provider, transitional reinsurance, and “Patient-Centered Outcomes
Research Institute” fees). We used the FEHBP contract, the FAR, the FEHBAR, and/or the
Affordable Care Act (Public Law 111-148) to determine if these charges were allowable,
allocable, and reasonable.

We reviewed the Plan’s cash management activities and practices to determine whether the Plan
handled FEHBP funds in accordance with Contract CS 1058 and applicable laws and regulations.
Specifically, we reviewed a sample of 76 letter of credit account drawdown amounts, totaling
$107,682,167 (from a universe of 1,209 letter of credit account drawdowns, totaling
$1,480,145,605, during the period 2012 through February 28, 2017), for the purpose of
determining if the Plan’s letter of credit account drawdowns were appropriate and adequately
supported.2 We also reviewed the Plan’s working capital calculations, adjustments and/or
balances from 2012 through June 30, 2017; United States Treasury offsets and interest income
transactions from 2012 through February 28, 2017; and the Plan’s dedicated FEHBP investment
account activity from 2012 through July 31, 2017, and the balance as of July 31, 2017.

We also interviewed the Plan’s Special Investigations Unit (SIU) regarding the effectiveness of
the Fraud and Abuse Program, as well as reviewed the Plan’s communication and reporting of
fraud and abuse cases to test compliance with Contract CS 1058 and FEHBP Carrier Letter
2014-29.




2
  Our sample included a week of letter of credit account drawdowns (representing four or five drawdown amounts)
judgmentally selected from each semi-annual period from 2012 through 2014, and two weeks of letter of credit
account drawdowns (representing four or five drawdown amounts for each week) judgmentally selected from each
semi-annual period from 2015 through February 28, 2017. Since we did not use statistical sampling, the sample
results were not projected to the universe of letter of credit account drawdowns.

                                                        7                     Report No. 1D-87-00-17-038
III. AUDIT FINDINGS AND RECOMMENDATIONS

 A. MISCELLANEOUS HEALTH BENEFIT PAYMENTS AND CREDITS

   The audit disclosed no significant findings pertaining to miscellaneous health benefit
   payments and credits, except for the finding pertaining to improper management of FEHBP
   funds noted in the “Cash Management” section. Overall, we concluded that the Plan timely
   returned health benefit refunds and recoveries, including pharmacy drug rebates, to the
   FEHBP and properly charged miscellaneous payments to the FEHBP.

 B. ADMINISTRATIVE EXPENSES

   The audit disclosed no findings pertaining to administrative expenses. Overall, we concluded
   that the administrative expenses charged to the FEHBP were actual, allowable, necessary,
   and reasonable expenses incurred in accordance with Contract CS 1058 and applicable laws
   and regulations.

 C. CASH MANAGEMENT

   1. Excess Working Capital Deposit                                                 $1,132,580

      As of June 30, 2017, the Plan held a working capital deposit of $1,132,580 over the
      amount needed to meet the Plan’s daily cash needs for FEHBP claim payments.

      OPM’s “Letter of Credit System Guidelines” (Guidelines), dated May 2009, state:
      “Carriers should maintain a working capital balance equivalent to an average of 2 days of
      paid claims. The working capital fund should be established using federal funds.
      Carriers are required to monitor their working capital funds on a monthly basis and adjust
      if necessary on a quarterly basis. . . . The working capital is not required but strongly
      recommended.” Based on these Guidelines, the Carrier’s working capital calculation
      must also exclude electronic fund transfers.

      In addition, based on the regulations governing the financing of Federal programs by the
      letter of credit method, as established in 31 CFR 205 (Treasury Department Circular No.
      10750), electronic fund transfers should not be included in the Plan’s working capital
      calculation. These instructions are established under the provisions of Treasury
      Department Circular No. 1083 (Regulations Governing the Utilization of the U.S.
      Treasury Financial Communication Systems), 5 CFR Part 890, and 48 CFR Chapter 16.

                                               8                  Report No. 1D-87-00-17-038
        Based on industry practice (e.g., other FEHBP experience-rated Carriers), the working
        capital deposit should be recalculated on a regular basis to determine if the amount
        currently maintained is adequate to meet the Carrier’s daily cash needs for FEHBP claim
        payments. If the working capital deposit amount is over or under funded, then the Plan
        should make an appropriate adjustment.

        We noted that the Plan reviewed the working capital deposit on a regular basis (usually
        quarterly) from 2012 through February 28, 2017.3 When reviewing the Plan’s working
        capital calculation (as of December 31, 2016), we determined that the Plan included the
        following items in the calculation: check presentments and electronic fund transfers for
        FEHBP claim payments; electronic fund transfers to the Pharmacy Benefit Manager
        (PBM) for pharmacy drug claims; and electronic fund transfers for dental claims and
        applicable excise taxes. Based on the Guidelines, the Plan’s working capital calculation
        must exclude electronic fund transfers.

        In our opinion, by including the weekly or biweekly electronic fund transfers to the PBM
        in the Plan’s working capital calculation, as well as the electronic fund transfers for the
        dental claims and applicable excise taxes, the Plan is significantly overstating the
        working capital deposit amount that is actually needed to meet the Plan’s daily financial
        obligations for the FEHBP experience-rated HMO plan. Since the Plan pays these health
        benefit costs by electronic fund transfers on behalf of the FEHBP from the Plan’s
        corporate account, the Plan has adequate time to request and withdraw these funds from
        the letter of credit account to timely reimburse themselves for these costs.

                                           During the fieldwork phase, the Plan recalculated the
            The Plan held an excess
                                           working capital deposit (excluding electronic fund
           working capital deposit of
                                           transfers) and determined that, as of June 30, 2017, the
          $1,132,580 in the dedicated
                                           working capital deposit should only be $3,481,799.
          FEHBP investment account
                                           However, the Plan held a working capital deposit of
              as of June 30, 2017.
                                           $4,614,379. We reviewed and accepted the Plan’s
        working capital calculation as of June 30, 2017. Therefore, as of that date, the Plan held
        a working capital deposit with an excess amount of $1,132,580 ($4,614,379 minus
        $3,481,799) over the amount actually needed to meet the Plan’s daily cash needs for
        FEHBP claim payments. Since the Plan maintained these excess working capital funds in
        the dedicated FEHBP investment account, lost investment income (LII) is not applicable.


3
 Although the audit scope for the Plan’s cash management activities and practices initially included 2012 through
February 2017, we expanded the scope for the working capital funds to also include March 2017 through June 2017.

                                                        9                      Report No. 1D-87-00-17-038
Plan Response:

The Plan agrees with this finding. The Plan returned the questioned excess working
capital funds to the FEHBP via letter of credit account drawdown adjustment. Going
forward, the Plan will properly calculate the working capital deposit in accordance
with the requirements.

OIG Comment:

As part of our review, we verified that the Plan returned the questioned excess working
capital funds of $1,132,580 to the FEHBP in September 2017.

Recommendation 1

We recommend that the contracting officer require the Plan to return $1,132,580 to the
FEHBP for the excess working capital deposit. However, since we verified that the Plan
returned $1,132,580 to the FEHBP for the excess working capital deposit, no further
action is required for this questioned amount.

Recommendation 2

We recommend that the Plan implement corrective actions to ensure that the working
capital deposit is properly calculated in accordance with the Guidelines and applicable
regulations. If an exception for the working capital calculation is necessary, then the Plan
should request prior approval (a waiver) from the contracting officer.

Recommendation 3

Since the use of electronic fund transfers by the experience-rated Carriers to pay FEHBP
claim payments have substantially increased in the past several years, we recommend that
the contracting officer(s) and/or OPM’s Benefits Insurance Accounting Office review and
revise (if necessary) the Guidelines, including the formula for the working capital
calculation, and propose regulation changes if applicable.




                                          10                 Report No. 1D-87-00-17-038
2. Improper Management of Funds                                                        $75,726

  The Plan did not properly manage or account for all FEHBP funds from 2012 through
  July 2017. As a result, we are questioning a net amount of $75,726 for this audit finding,
  consisting of $86,604 (net) owed to the Plan for reimbursable costs and $162,330 due to the
  FEHBP for applicable LII calculated on funds deposited untimely into the dedicated FEHBP
  investment account.

  Contract CS 1058, Part III, section 3.5 (a) states, “The Carrier . . . shall keep all FEHBP
  funds for this contract (cash and investments) physically separate from funds obtained
  from other sources.” 48 CFR 1632.771 (c) states, "FEHBP funds shall be maintained
  separately from other cash and investments of the carrier or underwriter."

  48 CFR 31.201-5 states, “The applicable portion of any . . . rebate, allowance, or other
  credit relating to any allowable cost and received by or accruing to the contractor shall be
  credited to the Government either as a cost reduction or by cash refund.” Also, based on
  Contract CS 1058 (Part II, Section 2.3 (i)), all health benefit refunds and recoveries,
  including pharmacy and medical drug rebates, must be deposited into the working capital
  or investment account within 30 days and returned to or accounted for in the LOCA
  within 60 days after receipt by the Plan.

  FAR 52.232-17(a) states, “all amounts that become payable by the Contractor … shall
  bear simple interest from the date due … The interest rate shall be the interest rate
  established by the Secretary of the Treasury as provided in 41 U.S.C. 7109, which is
  applicable to the period in which the amount becomes due, as provided in paragraph
  (e) of this clause, and then at the rate applicable for each six-month period as fixed by the
  Secretary until the amount is paid.”

  The Plan’s dedicated FEHBP investment account generally includes working capital
  funds, approved letter of credit account drawdown reimbursements, health benefit
  refunds and recoveries from providers and subscribers, interest income earned, and other
  cash items identified as due to the FEHBP. Based on Contract CS 1058, all funds
  deposited into the dedicated FEHBP investment account (such as health benefit refunds
  and recoveries, interest income, and excess working capital funds), should be returned to
  the FEHBP by adjusting the letter of credit account within 60 days after receipt by the
  Plan. In addition, approved reimbursements from the letter of credit account that are
  deposited into the dedicated FEHBP investment account should be timely transferred
  from this investment account to the Plan’s corporate account.



                                            11                  Report No. 1D-87-00-17-038
        As part of the Plan’s cash management process, the Plan pays numerous types of costs
        from HMSA’s corporate bank account on behalf of the FEHBP (such as pharmacy drug
        claims, dental claims and applicable excise taxes, and radiology claims). The Plan also
        receives an estimated monthly amount for administrative expenses (based on the contract
        limitation) and an approved monthly amount for the service charge. These monthly
        amounts are reimbursed to the Plan through the letter of credit account drawdown process
        and deposited into the Plan’s dedicated FEHBP investment account, and then netted
        against certain amounts (such as pharmacy and medical drug rebates) due to the FEHBP.

        For the period 2012 through July 2017, we noted that the Plan had not deposited certain
        types of miscellaneous health benefit recoveries (such as pharmacy and medical drug
        rebates) into the dedicated FEHBP investment account.4 Instead, the Plan deposited these
        recoveries into HMSA’s corporate bank account and then returned these funds to the
        FEHBP through the Plan’s “netting” process. Specifically, the Plan netted the amount
        owed to the FEHBP for these miscellaneous health benefit recoveries against the amount
        owed to the Plan for items such as administrative expenses, miscellaneous health benefit
        payments, and the service charge.
        .
                                            After the Plan performs the netting process, the
             The Plan did not deposit
                                            approved reimbursements from the letter of credit
            funds into and/or transfer
                                            account are deposited into the dedicated FEHBP
             funds from the dedicated
                                            investment account. Based on the netting process, if
           FEHBP investment account
                                            the amount owed to the Plan is more than the amount
               on a consistent basis.
                                            due to the FEHBP, the Plan transfers the difference to
        HMSA’s corporate account. In this situation, the funds owed to the Plan should be
        timely and totally transferred from the dedicated FEHBP investment account to HMSA’s
        corporate account. However, during our review of health benefit refunds and recoveries,
        pharmacy drug rebates and medical drug rebates, and miscellaneous health benefit
        payments, we noted the Plan did not deposit funds into and/or transfer funds from the
        dedicated FEHBP investment account on a consistent basis. This made reviewing these
        items challenging to complete. Based on our experience with auditing the FEHBP
        experience-rated Carriers, we have noted that substantially all of these Carriers deposit
        health benefit refunds and recoveries, pharmacy drug rebates, and/or medical drug
        rebates into the dedicated FEHBP investment account and then return the funds to the
        FEHBP via letter of credit account drawdown adjustments.


4
  Although the audit scope for miscellaneous health benefit payments and credits initially included 2012 through
February 2017, we expanded the scope to include March 2017 through July 2017 for these payments and credits, if
included in the Plan’s netting process.

                                                        12                     Report No. 1D-87-00-17-038
Based on our review, we noted the following exceptions:

x	 During our on-site fieldwork phase, we met with the Plan on several occasions to
   discuss the Plan’s netting process and procedures for returning health benefit refunds
   and recoveries, including pharmacy and medical drug rebates, to the FEHBP. The
   Plan could not adequately explain the netting process and demonstrate that these
   funds were deposited into the dedicated FEHBP investment account and returned to
   the letter of credit account. Therefore, we requested the Plan to provide a detailed
   analysis of the netting process from 2012 through July 2017, for the purpose of
   demonstrating if all health benefit refunds and recoveries, including pharmacy and
   medical drug rebates, were returned to the FEHBP, and thus making the Plan’s
   dedicated FEHBP investment bank account whole. The Plan provided an analysis
   detailing the amounts owed to the Plan (reimbursable costs) that were netted against
   the amounts due to the FEHBP (such as pharmacy and medical drug rebates). Based
   on the Plan’s analysis, the Plan is owed an additional $86,604 (net) for payments
   made on behalf of the FEHBP that inadvertently had not been transferred from the
   dedicated FEHBP investment account into HMSA’s corporate account. We reviewed
   and accepted the Plan’s analysis.

x	 As part of the analysis, the Plan also calculated LII on all FEHBP funds (such as
   pharmacy and medical drug rebates) that were untimely deposited into the dedicated
   FEHBP investment account. Based on the Plan’s calculation, the FEHBP is due LII
   of $162,330 on these funds. We reviewed and accepted the Plan’s LII calculation.

In total, we are questioning a net amount of $75,726 for this audit finding. This net
questioned amount consists of $86,604 (net) owed to the Plan for cost reimbursements
that inadvertently had not been transferred from the dedicated FEHBP investment
account into HMSA’s corporate account, and $162,330 due to the FEHBP for applicable
LII calculated on funds that were untimely deposited into the dedicated FEHBP
investment account.

Plan Response:

The Plan agrees with this finding. The Plan returned the questioned LII of $162,330
to FEHBP. However, the Plan states, “HMSA has not charged the FEHBP for the
$86,604 as we are waiting for the completion of the Office of the Inspector General
Audit and OPM permission to do so.




                                         13		               Report No. 1D-87-00-17-038
Going forward, HMSA will provide to OPM evidence or supporting documentation that
HMSA has implemented the necessary corrective actions to improve the netting process
and accountability of FEHBP funds as reported in the audit finding. HMSA will also
deposit, as required, all health benefit refunds and recoveries, including pharmacy and
medical drug rebates, into the working capital or investment account within 30 days
and return to or account for in the LOCA [letter of credit account] within 60 days after
receipt by the Plan.”

OIG Comment:

As part of our review, we verified that the Plan returned the questioned LII to the FEHBP
on August 25, 2017.

Recommendation 4

We recommend that the contracting officer require the Plan to return $162,330 to the
FEHBP for questioned LII calculated on the funds that were deposited untimely into the
FEHBP investment account. However, since we verified that the Plan returned $162,330
to the FEHBP for the questioned LII, no further action is required for this LII amount.

Recommendation 5

We recommend that the contracting officer allow the Plan to charge the FEHBP $86,604
(net) for costs that had not been reimbursed to the Plan.

Recommendation 6

We recommend that the contracting officer require the Plan to provide evidence or
supporting documentation ensuring that the Plan has implemented the necessary
corrective actions to improve the netting process and accountability of FEHBP funds (as
reported in the audit finding).

Recommendation 7

We recommend that the contracting officer require the Plan to provide evidence or
supporting documentation ensuring that the Plan now deposits all health benefit refunds
and recoveries, including pharmacy and medical drug rebates, into the dedicated FEHBP
working capital or investment account within 30 days and then returns these funds to the
letter of credit account within 60 days after receipt.


                                        14                  Report No. 1D-87-00-17-038
D. FRAUD AND ABUSE PROGRAM

  1. Special Investigations Unit                                                   Procedural


      The Plan did not report,      The Plan is not in compliance with the communication
      or did not timely report,     and reporting requirements for fraud and abuse cases that
      all fraud and abuse cases     are set forth in FEHBP Carrier Letter (CL) 2014-29.
              to the OIG.           Specifically, the Plan did not report, or did not timely
                                    report, all fraud and abuse cases to the OIG. Without
     awareness of these existing potential fraud and abuse issues, the OIG cannot investigate
     the broader impact of these potential issues on the FEHBP as a whole. We also identified
     several non-compliance issues regarding the Plan’s Fraud and Abuse Program process
     and procedures and the Plan’s 2016 Annual Fraud, Waste, and Abuse Reports.

     Contract CS 1058, Part III, Section 1.9 (a) states, “The Carrier must submit to OPM an
     annual analysis of the costs and benefits of its FWA [Fraud, Waste, and Abuse] program.
     The Carrier must submit annual reports to OPM by March 31 addressing . . . 9) Dollars
     Identified as Loss; 10) Estimated Financial Losses; 11) Non-Recoverable Loss; 12)
     Dollars Recovered by SIU and/or Vendor Activities; . . . 16) Prevented Loss . . . .”

     CL 2014-29 (Office of Personnel Management Federal Employees Health Benefits
     Fraud, Waste and Abuse), dated December 19, 2014, states that all Carriers “are required
     to submit a written notification to the OPM-OIG within 30 working days when there is
     potential reportable [fraud, waste, or abuse] that has occurred against the FEHB Program.
     OPM-OIG considers a potential reportable [fraud, waste, or abuse] as, after preliminary
     review of the complaint, the carrier takes an affirmative step to investigate the
     complaint.” There is no dollar threshold for this requirement.

     Part II (Fraud and Abuse - Carrier Actions) of CL 2014-29 states, “FEHBP Carriers must,
     at a minimum, perform the following activities to prevent, detect, investigate, and report
     FEHBP [fraud, waste, and abuse]: . . . Develop programs to prevent, detect, and identify
     persons and organizations involved in suspicious claim activity . . . Provide claims data
     upon request from OPM-OIG . . . and track all data requests separately. . . . Provide
     liaison and investigative support to OPM-OIG . . . upon request. . . . Track all provider,
     member, and pharmacy case notifications sent to OPM-OIG and all other law
     enforcement agencies, and provide an annual report of such activity to OPM . . . Provide
     annual fraud, waste, and or abuse reports (medical and pharmacy), due March 31st, to
     Health Insurance, Federal Employees Insurance Operations, [OPM] . . . .”



                                              15                 Report No. 1D-87-00-17-038
Part III (Industry Standards) of CL 2014-29 states, “All FEHB Carriers must have, at a
minimum . . . commercial industry-based program standards to prevent, detect,
investigate, and report all FEHB related [fraud, waste, and abuse].” For example, each
Carrier must have a fraud, waste, and abuse manual with prevention, detection,
investigation, and reporting procedures. This fraud, waste, and abuse manual must
include all of the Carrier’s policies and procedures included in the Carrier’s Fraud and
Abuse Program.

Attachment 1, Part VI (Program Cost Evaluation) of CL 2014-29 states, “Fraud, Waste,
and Abuse Program Costs - Include all related SIU Costs, including salaries, benefits for
staffing, travel, and training, which are only related to your FEHB [fraud, waste, and
abuse] program costs.”

For the period January 1, 2015 through December 31, 2016, the Plan opened        fraud
and abuse cases with potential FEHBP exposure. From this universe, we selected and
reviewed a judgmental sample of 30 cases for the purpose of determining if the Plan
timely reported these cases to the OIG. Based upon our review of these 30 cases, we
determined that 28 cases were not reported to the OIG and 2 cases were untimely
reported to the OIG.

            Sample Results - Cases Opened with Potential FEHBP Exposure
                              (as Identified by the Plan)


                                       28
                                                                  Not Reported
                            2
                                                                  Reported Late




Ultimately, the Plan’s incomplete reporting of potential FEHBP cases to the OIG has
resulted in a failure to meet the communication and reporting requirements that are set
forth in CL 2014-29. The lack of notification by the Plan did not allow the OIG to
investigate whether other FEHBP Carriers are exposed to the identified fraudulent
activity. As a result, this lack of OIG notification by the Plan may result in additional
improper payments being made by other FEHBP Carriers. This also does not allow the
OIG’s Administrative Sanctions Group to be notified timely.




                                            16               Report No. 1D-87-00-17-038
The following are additional non-compliance issues that were identified during
discussions with the Plan’s SIU and/or while reviewing the Plan’s Fraud and Abuse
Program policies and procedures as well as the Plan’s 2016 Annual Fraud, Waste, and
Abuse Report:

x	 The Plan did not enter or track the applicable pharmacy data reported in the 2016
   Annual Fraud, Waste, and Abuse Report, stating that CVS, which is the Plan’s
   Pharmacy Benefit Manager (PBM), entered this specific data. The Plan also did not
   review or verify the data entered by CVS in this report.

x	 In the 2016 Annual Fraud, Waste, and Abuse Report, the data related to the PBM’s
   Fraud and Abuse Program should not be considered accurate or reliable if the Plan
   did not actually track or verify this data, especially since the PBM did not have a
   Fraud and Abuse Program. CVS specifically noted in the 2016 Annual Fraud, Waste,
   and Abuse Report that there was no Fraud and Abuse Program for the FEHBP
   pharmacy benefits in 2016. Therefore, the exclusion of the FEHBP costs, but
   inclusion of reported recoveries and actual savings, results in the inflation of the
   Plan’s return on investment for fraud, waste, and abuse.

x   CVS has a
                                                   These program services are purchasable
    software programs that CVS offers clients, including HMSA. While we agree that
    these CVS software program edits would help identify potential adverse drug
    interactions and/or over utilization, we do not believe that these CVS software edits
    represent a Fraud and Abuse Program.

x	 In 2016, all FEHBP Carriers were required to comply with Carrier Letter 2014-29.
   We noted that the Plan’s 2016 Annual Fraud, Waste, and Abuse Report did not track
   or report identified losses, estimated financial losses, non-recoverable losses,
   recoveries, savings, and prevented losses for fraud, waste, and/or abuse cases related
   to pharmacy drug claims.

x	 The Plan’s Fraud, Waste, and Abuse Process and Procedure Manual does not have
   PBM oversight and investigative procedures for tracking potential fraud, waste,
   and/or abuse leads, allegations, and/or cases that are received from the PBM.




                                         17		               Report No. 1D-87-00-17-038
Plan Response:

“Until the audit, HMSA was not in compliance with communication and reporting
requirements as set forth in FEHBP CL 2014-29. Going forward, HMSA will comply
with contract and Carrier Letter notification requirements by providing notification to
OPM-OIG within 30 working days after determining if there is reportable [fraud,
waste, or abuse] . . .

HMSA agrees that it did not enter, track, or validate the pharmacy data as set forth in
the 2016 Annual FWA [Fraud, Waste, and Abuse] Report. In the future, HMSA will
enter, track, and validate the pharmacy data as required by CL 2017-13.

HMSA agrees that it did not consistently track or validate the pharmacy data as set
forth in the 2016 Annual FWA Report and that the ‘exclusion of FEHBP pharmacy
costs but inclusion of recoveries and savings’ could have resulted in the inflation of
HMSA’s return of investment. In the future, HMSA will accurately enter, track,
validate, and report all information as required by CL 2017-13.

HMSA agrees that CVS has a
                           , and these services, along with the                      ,
support HMSA’s FWA Program. In addition to the data analytic capabilities that
assist in identifying potential FWA, these contracted services also provide targeted
interventions, pharmacy audit referrals and continuous monitoring. HMSA agrees
that these programs alone do not represent a FWA program.

HMSA agrees that in 2016, all FEHBP carriers were required to comply with [CL
2014-29] and that HMSA’s 2016 Annual FWA Report did not track or report the
identified losses, estimated financial losses, and non-recoverable losses, recoveries,
savings, and prevented loss for the pharmacy FWA program. In the future, HMSA will
accurately enter, track, validate, and report all information as required by CL 2017-13.

Going forward, HMSA will be refining its processes to meet these requirements and
document them in a revised FWA Manual.”




                                         18                 Report No. 1D-87-00-17-038
        OIG Comment:

        After reviewing the Plan’s additional information in response to the non-compliance
        issues that were identified during our discussions with Plan officials and/or while
        reviewing the Plan’s Fraud and Abuse Program policies and procedures and the Plan’s
        2016 Annual Fraud, Waste, and Abuse Report, we revised these non-compliance issues
        accordingly (see page 17), based on this additional information.

        Recommendation 8

        We recommend that the contracting officer require the Plan to provide evidence or
        supporting documentation ensuring that the Plan has implemented the necessary
        procedural changes to meet the communication and reporting requirements of fraud and
        abuse cases that are contained in CL 2014-29 and CL 2017-13 (OPM Federal Employees
        Health Benefits Fraud, Waste, and Abuse).5

        Recommendation 9

        We recommend that the contracting officer require the Plan to perform a comprehensive
        review (or self-assessment) of the Plan’s Fraud and Abuse Program. The Plan should
        provide the results of this comprehensive review to the contracting officer as well as the
        applicable corrective actions that were implemented (and/or will be implemented) to
        ensure compliance with the requirements of the FEHBP contract and CL 2017-13.

        Recommendation 10

        We recommend that the contracting officer require the Plan to revise the Fraud, Waste,
        and Abuse Process and Procedure Manual to include investigative procedures and
        systematic information for tracking potential fraud, waste, and/or abuse leads, allegations,
        and/or cases that are received from the PBM. The Plan should also implement the
        necessary procedures to ensure proper PBM oversight.




5
 CL 2017-13 (dated November 20, 2017) consolidates and updates the information from CL 2014-29, which is
superseded by this guidance. CL 2017-13 also supplements guidance from the FEHBP contract (Section 1.9 – Plan
Performance).

                                                       19                    Report No. 1D-87-00-17-038
Recommendation 11

We recommend that the contracting officer verify that the Plan provides a complete and
accurate 2017 Annual Fraud, Waste, and Abuse Report. We also recommend that the
Plan provide the contracting officer complete documentation (or have available for onsite
inspection) to support all entry items and data elements in this annual report.




                                         20                 Report No. 1D-87-00-17-038
                                                                         APPENDIX
	




February 16, 2018

                     , Group Chief
Experience-Rated Audits Group
Office of the Inspector General
U.S. Office of Personnel Management
1900 E Street, Room 6400
Washington, DC 20415-1100

Re:	 	 Audit of Hawaii Medical Service Association (HMSA)
       Audit Report Number 1D-87-00-17-038
Dear                  :
This letter is in response to the above-referenced U.S. Office of Personnel
Management (OPM) Draft Audit Report, issued on January 19, 2018, detailing the
results of the limited scope audit of the Federal Employee Health Benefits Program
(FEHBP) operations at HMSA. Our comments regarding the findings in this report are
as follows.
C. CASH MANAGEMENT
  1. Excess Working Capital (WC) Deposit	                                   $1,132,580

       As of June 30, 2017, the Plan held a WC deposit of $1,132,580 over the amount
       needed to meet the Plan’s daily cash needs for Federal Employee Health Benefit
       Program (FEHBP) claim payments.
       Recommendation 1
       We recommend that the contracting officer require the Plan to return $1,132,580
       to the FEHBP for the excess WC deposit. However, since we verified that the
       Plan returned $1,132,580 to the FEHBP for the excess WC deposit, no further
       action is required for this amount.

       Plan’s Response
       HMSA agrees with the finding. We have returned the excess WC, totaling
       $1,132,579.81, to the FEHBP by adjusting the Letter of Credit (LOC) Account as
       of October 2, 2017. Going forward, HMSA will properly compute the WC deposit
       according to FEHBP requirements.
2. Improper Management of FEHBP Funds                                       $75,726

  The Plan did not properly manage or account for all FEHBP funds from 2012
  through July 2017. As a result, we are questioning a net total amount of $75,726
  for this audit finding, consisting of $86,604 for a net amount owed to the Plan and
  $162,330 for applicable lost investment income (LII) due to the FEHBP.

  Recommendation 2
  We recommend that the contracting officer require the Plan to return the
  questioned LII to the FEHBP for funds that were not timely deposited into the
  dedicated FEHBP investment account. However, since we verified that the Plan
  returned the questioned LII to the FEHBP, no further action is required.

  Recommendation 3
  We recommend that the contracting officer allow the Plan to charge the FEHBP
  $86,604 for costs that had not been reimbursed to the Plan.

  Recommendation 4
  We recommend that the contracting officer require the Plan to provide evidence
  or supporting documentation ensuring that the Plan has implemented the
  necessary corrective actions to improve the netting process and accountability of
  FEHBP funds (as reported in the audit finding).

  Recommendation 5
  We recommend that the contracting officer require the Plan to deposit all health
  benefit refunds and recoveries, including pharmacy and medical drug rebates,
  into the working capital or investment account within 30 days and return to the
  LOCA within 60 days after receipt by the Plan.

        Plan’s Response
        HMSA agrees with the finding. HMSA returned the $162,330 of lost
        investment income to FEHBP on August 25, 2017. HMSA has not charged
        the FEHBP for the $86,604 as we are waiting for the completion of the
        Office of the Inspector General Audit and OPM permission to do so.

        Going forward, HMSA will provide to OPM evidence or supporting
        documentation that HMSA has implemented the necessary corrective
        actions to improve the netting process and accountability of FEHBP funds
        as reported in the audit finding. HMSA will also deposit, as required, all
        health benefit refunds and recoveries, including pharmacy and medical
        drug rebates, into the working capital or investment account within 30
        days and return to or account for in the LOCA within 60 days after receipt
        by the Plan.




                                                          Report No. 1D-87-00-17-038
D. FRAUD AND ABUSE PROGRAM

 1. Special Investigations Unit (SIU)                                        Procedural

    HMSA is not in compliance with the communication and reporting requirements
    for fraud and abuse cases set forth in FEHBP Carrier Letter (CL) 2014-29.
    Specifically, the Plan did not report, or did not timely report, all fraud and abuse
    cases to the OIG.

    For the period January 1, 2015 through December 31, 2016, the Plan opened
         fraud and abuse cases with potential FEHBP exposure. From this universe,
    we selected and reviewed a judgmental sample of 30 cases for the purpose of
    determining if the Plan timely reported these cases to the OIG. Based upon our
    review of these 30 cases, we determined that 28 cases were not reported to the
    OIG and 2 cases were untimely reported to the OIG.

           Plan’s Response
           HMSA agrees with the statements.

           Until the audit, HMSA was not in compliance with communication and
           reporting requirements as set forth in FEHBP CL 2014-29. Going forward,
           HMSA will comply with contract and Carrier Letter notification
           requirements by providing notification to OPM-OIG within 30 working days
           after determining if there is reportable FWA.

    Deleted by the Office of the Inspector General – Not Relevant to the Final
    Report

    HMSA did not enter or track the applicable pharmacy data reported in the 2016
    Annual FWA Report, admitting that CVS entered this specific data. HMSA also
    did not review or verify the data entered by CVS on these reports. As a result, we
    interpret the comment in the 2016 Annual FWA Report, stating that CVS did not
    have a FWA Program for the FEHBP pharmacy benefits, as correct.

           Plan’s Response
           HMSA agrees that it did not enter, track, or validate the pharmacy data as
           set forth in the 2016 Annual FWA Report. In the future, HMSA will enter,
           track, and validate the pharmacy data as required by CL 2017-13.

    Deleted by the Office of the Inspector General – Not Relevant to the Final
    Report




                                                              Report No. 1D-87-00-17-038
In the 2016 Annual FWA Report, the data related to the PBM’s FWA program
cannot be considered accurate if HMSA did not track or verify this data,
especially since the PBM did not have a FWA Program. Again, CVS specifically
noted that there was no FWA program for the FEHBP pharmacy benefits in 2016.
The exclusion of the FEHBP costs, but inclusion of reported recoveries and
actual savings, results in the inflation of HMSA’s return on investment for FWA.
The PBM’s data cannot be considered reliable, accurate, or compliant with OPM
required reporting.

       Plan’s Response
       HMSA agrees that it did not consistently track or validate the pharmacy
       data as set forth in the 2016 Annual FWA Report and that the “exclusion
       of FEHBP pharmacy costs but inclusion of recoveries and savings” could
       have resulted in the inflation of HMSA’s return of investment. In the future,
       HMSA will accurately enter, track, validate, and report all information as
       required by CL 2017-13.

CVS does have a
                               These programs are a separately purchasable add-
on software program CVS offers its clients. While we agree that the software
edits would help identify potential adverse drug interactions or over utilization, we
do not believe that the CVS system software edits represent a FWA program.

       Plan’s Response
       HMSA agrees that CVS has a
                                                       and these services, along with
       the                          , support HMSA’s FWA Program. In addition to
       the data analytic capabilities that assist in identifying potential FWA, these
       contracted services also provide targeted interventions, pharmacy audit
       referrals and continuous monitoring. HMSA agrees that these programs
       alone do not represent a FWA program.

In 2016, all FEHBP Carriers were required to comply with Carrier Letter 2014-29.
We noted that HMSA’s 2016 Annual FWA Report did not track or report the
identified losses, estimated financial losses, and non-recoverable losses,
recoveries, savings, and prevented loss for the pharmacy FWA program.
Additionally, we question the validity of other CVS reported numbers in the report
being FWA related, as HMSA states there was no FWA program for the FEHBP.
It is unclear how the data was deemed FWA related, if CVS had no FWA
program.




                                                         Report No. 1D-87-00-17-038
             Plan’s Response
             HMSA agrees that in 2016, all FEHBP carriers were required to comply
             with CL 2014-20 and that HMSA’s 2016 Annual FWA Report did not track
             or report the identified losses, estimated financial losses, and non-
             recoverable losses, recoveries, savings, and prevented loss for the
             pharmacy FWA program. In the future, HMSA will accurately enter, track,
             validate, and report all information as required by CL 2017-13.

      HMSA’s FWA Process and Procedure Manual does not have PBM oversight and
      investigative procedures and systematic information for tracking potential FWA
      leads and/or cases that are received from the PBM.

             Plan’s Response
             HMSA agrees with the statement.

             Going forward, HMSA will be refining its processes to meet these
             requirements and document them in a revised FWA Manual.


HMSA appreciates the opportunity to provide our responses to the Draft Audit Report
and request that our comments be included in the Final Audit Report. Thank you for the
opportunity to better serve our FEHBP members.

Sincerely,




Executive Vice President, Chief Member Services Officer




                                                            Report No. 1D-87-00-17-038
	                                                                        



               Report Fraud, Waste, and
                   Mismanagement
	
                          Fraud, waste, and mismanagement in
                       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:


     By Internet: 	        http://www.opm.gov/our-inspector-general/hotline-to-
                           report-fraud-waste-or-abuse


       By Phone: 	         Toll Free Number:                  (877) 499-7295
                           Washington Metro Area:             (202) 606-2423


        By Mail:           Office of the Inspector General
                           U.S. Office of Personnel Management
                           1900 E Street, NW
                           Room 6400
                           Washington, DC 20415-1100