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    Subject Term: Auditors

    8 publications with a total of 31 open recommendations including 6 priority recommendations
    Director: James R. McTigue Jr.
    Phone: (202) 512-9110

    14 open recommendations
    Recommendation: As LB&I finishes implementing its new approach and decides which selection methods will be used with the campaigns, the Commissioner of Internal Revenue should ensure that the documentation gaps in policies and procedures are addressed for six internal control principles for the selection methods that will be used, including defining objectives to identify risk and defining risk tolerances.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As LB&I finishes implementing its new approach and decides which selection methods will be used with the campaigns, the Commissioner of Internal Revenue should ensure that the documentation gaps in policies and procedures are addressed for six internal control principles for the selection methods that will be used, including identifying, analyzing, and responding to risks to achieving the objectives.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As LB&I finishes implementing its new approach and decides which selection methods will be used with the campaigns, the Commissioner of Internal Revenue should ensure that the documentation gaps in policies and procedures are addressed for six internal control principles for the selection methods that will be used, including designing control activities to achieve objectives and responding to risks.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As LB&I finishes implementing its new approach and decides which selection methods will be used with the campaigns, the Commissioner of Internal Revenue should ensure that the documentation gaps in policies and procedures are addressed for six internal control principles for the selection methods that will be used, including using quality information to achieve objectives.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As LB&I finishes implementing its new approach and decides which selection methods will be used with the campaigns, the Commissioner of Internal Revenue should ensure that the documentation gaps in policies and procedures are addressed for six internal control principles for the selection methods that will be used, including communicating internally the necessary quality information about the objectives.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As LB&I finishes implementing its new approach and decides which selection methods will be used with the campaigns, the Commissioner of Internal Revenue should ensure that the documentation gaps in policies and procedures are addressed for six internal control principles for the selection methods that will be used, including evaluating issues and remediating identified internal control deficiencies on a timely basis.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: Also in accordance with federal internal control standards, the Commissioner should direct LB&I to adopt a standard process for monitoring audit selection decisions in the field, such as by modifying the existing quality control system.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To further ensure that the new campaigns under LB&I's new approach for addressing tax compliance are implemented successfully, the Commissioner should create a timetable with specific dates for implementing its new compliance approach.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To further ensure that the new campaigns under LB&I's new approach for addressing tax compliance are implemented successfully, the Commissioner should establish metrics to help determine whether the campaign effort overall meets LB&I's goals.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To further ensure that the new campaigns under LB&I's new approach for addressing tax compliance are implemented successfully, the Commissioner should finalize and document plans to evaluate the human resources expended on campaign activities.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To further ensure that the new campaigns under LB&I's new approach for addressing tax compliance are implemented successfully, the Commissioner should document lessons learned from stakeholder input and past performance.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To further ensure that the new campaigns under LB&I's new approach for addressing tax compliance are implemented successfully, the Commissioner should monitor overall performance across future campaigns, not just individual compliance projects, and in doing so ensure that the data used for monitoring accounts for the costs beyond the auditor's time can clearly be linked with specific selection methods, including the Discriminant Analysis System method, to the extent that the selection methods continue to operate.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To further ensure that the new campaigns under LB&I's new approach for addressing tax compliance are implemented successfully, the Commissioner should develop and document criteria to use in choosing selection methods for campaigns using audits.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To further ensure that the new campaigns under LB&I's new approach for addressing tax compliance are implemented successfully, the Commissioner should set a timetable to analyze and mitigate risks and document specific metrics for assessing mitigation of identified risks.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: James R. McTigue, Jr.
    Phone: (202) 512-9110

    7 open recommendations
    Recommendation: To help ensure SB/SE's audit selection program meets its mission and selects returns fairly, the Commissioner of Internal Revenue should clearly define and document the key term "fairness" for return selection activities.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed to incorporate a definition of fairness into the Internal Revenue Manual (IRM), which serves as a single point of reference for guidance to IRS examiners. In February 2016, the Deputy Commissioner of Services and Enforcement (S&E) reiterated IRS's definition of fairness in the examination process to S&E employees. In January 2017, IRS issued interim guidance on fairness in examination case selection. IRS officials said that this guidance is considered "final" until the IRM is updated, no later than January 2019. In February 2017, IRS issued an article on its IRWeb and a message from the Deputy Commissioner S&E on defining fairness in the exam process. We are awaiting resolution of how this definition will be used in three other recommendations on communicating examples as well as developing both a related objective and measure.
    Recommendation: To help ensure SB/SE's audit selection program meets its mission and selects returns fairly, the Commissioner of Internal Revenue should clearly communicate examples of fair selections to staff to better assure consistent understanding.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed to communicate examples of fairness to managers and examiners involved in selecting tax returns for examination. In March 2017, the Director of IRS Small Business/Self Employed (SB/SE) Examination-Headquarters issued a memo to SB/SE examination directors that included examples illustrating the fairness definition in return selection. The examples were to be shared with directors, management, and examiners involved in return selection. To close this recommendation, we are waiting for resolution of how the fairness definition will be implemented through related recommendations on developing program objectives and measures assessing fairness in return selection.
    Recommendation: To help ensure SB/SE's audit selection program meets its mission and selects returns fairly, the Commissioner of Internal Revenue should develop, document, and implement program-level objective(s) to evaluate whether the return selection process is meeting its mission of applying the tax law with integrity and fairness to all.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed to review its current objectives for the SB/SE examination program and found that an additional program-level objective to evaluate fairness in the return selection was necessary. The new objective is "Ensure examinations are initiated based on indicators of noncomplicance. In addition, ensure a review of the decisions to survey a return (i.e., not initiate an examination) are based on upon factors outlined in the Internal Revenue Manual (IRM) and approved by an appropriate level of management." In March 2017, IRS issued interim guidance communicating the new objective, which was sent to Examination Directors. The guidance and objective were also posted on the IRweb, which is available to all IRS employees. IRS officials said that the interim guidance is considered final until it can be incorporated into the IRM, which should be done within 2 years of when the interim guidance is issued. We are awaiting IRS's response to a related recommendation on developing a measure for this selection objective before deciding to close this recommendation.
    Recommendation: To help ensure that SB/SE's audit selection objective(s) on fairness are used and met, the Commissioner of Internal Revenue should develop, document, and implement related performance measures that would allow SB/SE to determine how well the selection of returns for audit meets the new objective(s).

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed to develop, document, and implement additional performance measures if new objectives related to fair return selection were implemented. In March 2017, IRS developed a new objective on fair return selection. In April 2017, IRS officials said that they were working on performance measures related to the new objective on fair return selection. They plan to meet with GAO in 1-2 months to obtain our feedback on the measures.
    Recommendation: To help ensure that SB/SE's audit selection objective(s) on fairness are used and met, the Commissioner of Internal Revenue should incorporate the new objective(s) for fair return selection into the SB/SE risk management system to help identify and analyze potential risks to fair selections.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed to consider any new objectives related to fair return selection within SB/SE's current risk management process framework. In March and April 2017, SB/SE developed a tool (RAFT) to include the fair selection objective (and related activities) into its risk register, which is monitored quarterly. IRS provided documentation from the Exam Risk Council meeting that they have discussed and assessed these risks. IRS is still working on documentation to show they are addressing our recommendations and the associated risks. IRS officials said the documentation is due in August 2017.
    Recommendation: The Commissioner of Internal Revenue should develop and implement consistent documentation requirements to clarify the reasons for selecting a return for audit and who reviewed and approved the selection decision.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed to evaluate the need to improve its documentation of return selection decisions and the review and approval process. In March 2017, various IRS functions completed templates showing the current status of return selection documentation requirements. As a result, they found that they could improve the consistency and clarity in documentation, approval and review requirements across workstreams by clearly defining procedures and ensuring they are formally documented in the IRM. The Director of Exam Case Selection issued a memo directing that documentation requirements be made consistent in the IRM. IRS officials said that revised documentation requirements are due in August 2017, with IRM incorporation at a later date.
    Recommendation: The Commissioner of Internal Revenue should develop, document, and implement monitoring procedures to ensure that decisions made and coding used to select returns for audit are appropriate.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS agreed to review its current procedures for monitoring return selection decisions and coding used to select returns. In April 2017, IRS officials provided documentation showing they had reviewed campus examination selection dollar thresholds and campus source code definitions. They found that improvements could be made in clarifying source code definitions and reviewing dollar thresholds used to categorize and select, respectively, returns for examination. IRS has issued an IRM procedural update to implement these changes. During our meeting with IRS, we clarified that our recommendation covered monitoring selection decisions more broadly, which IRS acknowledged. Officials said that additional documentation on monitoring selection decisions will be due by August 2017.
    Director: Asif A. Khan
    Phone: (202) 512-9869

    1 open recommendations
    including 1 priority recommendation
    Recommendation: To help meet its financial management improvement and audit readiness goals, the Secretary of Defense should direct the Under Secretary of Defense (Comptroller) to reconsider the status of the three panel recommendations that DOD classified as met that we determined were partially met and take the necessary actions to reasonably assure that these recommendations have been met.

    Agency: Department of Defense
    Status: Open
    Priority recommendation

    Comments: In September 2015, we reported that DOD had completed action on 6 of the Committee Panel's 29 recommendations. However, we disagreed with DOD's reported status of met for 3 other recommendations related to (1) attestations on audit readiness to be included in each of the Financial Improvement and Audit Readiness (FIAR) Plan Status Reports; (2) inclusion of FIAR-related goals in Senior Executive Service performance plans, and rewarding and evaluating performances over time based on those goals; and (3) the review of audit readiness assertions by component senior executive committees. In response to our recommendation, in its November 2015 FIAR Plan Status Report, DOD revised the implementation status for these three recommendations from met to partially met and gave further consideration to actions needed to reasonably assure whether the recommendations had been met. In its May 2016 FIAR Plan Status Report DOD stated that it had completed corrective action on one of these three Committee Panel recommendations and reported actions on the other two recommendations as partially met. As of May 2017, DOD reported that its actions for all three Congressional Panel recommendations met those recommendations. However, DOD had not yet identified a method to reward executives based on evaluated performance on FIAR-related goals. In addition, DOD needs to continue to state in each FIAR Plan Status Report whether DOD is on track to be audit ready as of September 30, 2017. Therefore, as of August 30, 2017, this recommendation was still open.
    Director: Asif A. Khan
    Phone: (202) 512-9869

    1 open recommendations
    Recommendation: To improve the quality of DOD's financial statement audits and ensure that corrective actions to address audit recommendations are fully and effectively implemented prior to their closure, the Department of Defense Inspector General should ensure that Marine Corps corrective actions fully address audit recommendations and document auditor review of the actions taken before closing the related recommendations.

    Agency: Department of Defense: Office of the Inspector General
    Status: Open

    Comments: Our follow up in fiscal year 2015 was limited to a request for a documented process the DOD-IG may have developed and implemented to ensure all control issues detailed in the NFRs have been fully resolved; related corrective action plans were relevant and reviewed consistently and adequately; and the IPA/DOD-IG reviews were documented as part of the NFR review process. DOD-IG was not able to provide such documentation to support the statement provided in its response to our recommendation at the time the report was issued. Consequently, there was no documentation for us to review. In August 2017, we contacted the DOD-IG and requested an update on the status of efforts to address this recommendation. Also, per the contract with an IPA for the USMC's fiscal year 2017 financial statement audit, the IPA is to follow up on status of efforts to address prior year recommendations.
    Director: Jacqueline M. Nowicki
    Phone: (617) 788-0580

    1 open recommendations
    Recommendation: To help ensure that states are better able to sustain RTT reforms and that Education can effectively support other grant programs managed by the Office of State Support, the Secretary of Education should direct the Office of State Support to fully implement and incorporate into its coordinated technical assistance policies and procedures the types of support that would be useful in sustaining RTT reforms and providing effective support to grantees in other programs supporting education reform that the Office of State Support oversees. These could include: (1) providing individualized technical assistance to states, such as that currently provided by Education program officers; (2) facilitating communities of practice to promote opportunities for collaboration across states; (3) providing professional development (or training) throughout the grant period, as opposed to only during the early stages of the grant; (4) making training more easily accessible by conducting training locally in their respective states, when possible; and (5) to the extent permissible in the context of federal and state requirements and restrictions, exploring the possibility of assisting states in identifying skilled contractors to help implement reform efforts.

    Agency: Department of Education
    Status: Open

    Comments: In 2015, Education stated that the Office of State Support drafted a technical assistance plan that is being revised based on stakeholder input. Officials stated that the technical assistance plan addresses all of the suggestions included in our recommendation. In September 2017, Education provided a "Draft Conceptual Framework for OSS Technical Assistance Plan" dated March 2016, which the agency confirmed to be a final version. However, this document is a plan that does not show the activities were actually implemented. We will consider closing this recommendation when the agency provides documentation that the activities have been completed.
    Director: Robert Goldenkoff
    Phone: (202) 512-2757

    3 open recommendations
    including 3 priority recommendations
    Recommendation: To assist the interagency working group, known as the Federal Agency Skills Team (FAST), to better identify government-wide skills gaps having programmatic impacts and measure its progress towards closing them, the Director of OPM--in conjunction with the CHCO Council--should strengthen its approach and methodology by (1) assisting FAST in developing goals for closing skills gaps with targets that are both clear and measurable; (2) working with FAST to design outcome-oriented performance metrics that align with overall targets for closing skills gaps and link to the activities for addressing kills gaps; (3) incorporating greater input from subject matter experts, as planned; and (4) ensuring FAST consistently follows key practices for project planning.

    Agency: Office of Personnel Management
    Status: Open
    Priority recommendation

    Comments: As of October 2016, OPM has sought to strengthen the methodology for closing skills gaps by offering skills gap closure training to 1) agency officials with respect to agency-specific skills gaps, and 2) interagency working groups with respect to government-wide skills gaps. Held during the spring of 2016, this OPM-led training sought to provide agency officials with methodologies for identifying the root causes for skills gaps, as well as provide assistance in developing action plans for implementing and monitoring their strategies to address these skills gaps. OPM officials stated that these interagency teams will report on a quarterly basis to the OPM Director on their progress to implement these strategies, beginning in January 2017. OPM, in conjunction with OMB, agencies, and the CHCO Council, needs to ensure that this infrastructure is implemented as developed.
    Recommendation: To ensure that OPM builds the predictive capacity to identify emerging skills gaps across the government--including the ability to collect and use reliable information on the competencies of the federal workforce for government-wide workforce analysis--the Director of OPM should (1) establish a schedule specifying when OPM will modify its Enterprise Human Resources Integration database to capture staffing data that it currently collects from agencies through its annual workforce data reporting process; and (2) work with agency CHCOs to bolster the ability of agencies to assess workforce competencies by sharing competency surveys, lessons learned, and other tools and resources.

    Agency: Office of Personnel Management
    Status: Open
    Priority recommendation

    Comments: As of October 2016, officials reported that OPM has partnered with the Chief Learning Officers Council to leverage resources to develop a framework to support agencies efforts to develop competency assessments. Additionally, OPM reported that it has created an internal working group to determine whether its Enterprise Human Resources Integration (EHRI) personnel database can support having a predictive capacity for identifying emerging skills gaps across the government, including the ability to collect and use information on the competencies of the federal workforce. OPM needs to work with agencies to improve competency assessment across the government and to pursue modifying EHRI to support the collection of staffing and competency data.
    Recommendation: To help agencies and OPM better monitor progress toward closing skills gaps within agencies and government-wide, the Director of OPM should (1) work with the CHCO Council to develop a core set of metrics that all agencies should use as part of their HRstat data-driven reviews; and (2) coordinate with FAST personnel and explore the feasibility of collecting information needed by FAST as part of agencies' HRstat reviews.

    Agency: Office of Personnel Management
    Status: Open
    Priority recommendation

    Comments: As of October 2016, officials reported that OPM has partnered with the CHCO Council to implement a government-wide set of metrics for use as part of a government-wide benchmarking effort. However, it has no plans to coordinate the data collection efforts of agencies' HRstat reviews with the collection efforts of OPM's and agencies' working groups to identify and address skills gaps. OPM stated that coordinating the data collection was not possible because agencies' HRstat reviews have different goals and collect different types of data than the working groups. We maintain that action on our recommendation is important because it is likely that the core metrics collected under HRstat could help inform the efforts of the working groups and thus reduce duplicative efforts. Moreover, the use of a core set of metrics from agencies' HRstat reviews could aid in monitoring actual progress in closing skills gaps government-wide.
    Director: Mctigue Jr, James R
    Phone: (202) 512-7968

    3 open recommendations
    including 2 priority recommendations
    Recommendation: Congress should consider altering the TEFRA audit procedures to require partnerships to designate a qualified Tax Matters Partner (TMP) and, if that TMP is an entity, to also identify a representative who is an individual and for partnerships to keep the designation up to date.

    Agency: Congress
    Status: Open

    Comments: In October 2015, H.R. 1314 was amended to include the Bipartisan Budget Act of 2015, which included provisions that would repeal the TEFRA audit procedures and put in place new audit procedures for partnerships with more than 100 partners. This legislation was signed into law in November 2015. According to the legislation, the new audit procedures would require partnerships to designate a qualified representative for the partnership audit. However, the legislation did not require audited partnerships to identify a representative who is an individual nor do they require that audited partnerships keep the designation up to date as suggested in GAO's report. The legislation does give IRS the authority to develop regulations about how the partnership representative should be designated by the partnership and such regulations may address the items in GAO's report. Currently regulations are under development at IRS. The legislation specifies that the new partnership audit procedures apply to partnership returns filed for tax years beginning after December 31, 2017.
    Recommendation: The Commissioner of Internal Revenue should track the results of large partnerships audits: (a) define a large partnership based on asset size and number of partners; (b) revise the activity codes to align with the large partnership definition; and (c) separately account for field audits and campus audits.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open
    Priority recommendation

    Comments: No executive action taken. IRS said that it plans to address parts of GAO's September 2014 recommendation about tracking the audit results on large partnerships but has not yet done so. In November 2014, IRS said that it plans to define large partnerships using asset size and the number of partners and to find an alternative method to account for field and campus large partnership cases using existing capabilities, but that revising IRS's activity codes to enable it to track large partnership audits would be dependent on future funding. In March 2017, IRS told GAO that it would need until September 2017 to address this recommendation as IRS continues to monitor efforts to implement the Bipartisan Budget Act (BBA). Section 1101 of the Bipartisan Budget Act of 2015 (Public law 114-74), which was enacted in November 2015, includes provisions that repeal TEFRA audit procedures and put in place audit procedures that would require partnerships with more than 100 partners to pay audit adjustments at the partnership level, among other changes. IRS explained that these changes significantly alter the procedural and administrative components of partnerships. IRS said it would need this additional time to analyze options and determine the most appropriate steps for effectively tracking the results of large partnership audits. Without changes to tracking partnership audit results, IRS cannot conduct analysis to identify ways to better plan and use IRS resources in auditing large partnerships as well as analyze whether large partnerships present a high noncompliance risk.
    Recommendation: The Commissioner of Internal Revenue should analyze the audit results by these activity codes and types of audits to identify opportunities to better plan and use IRS resources in auditing large partnerships.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open
    Priority recommendation

    Comments: As of October 2016, the Internal Revenue Service (IRS) said that based on completion of GAO's recommendations on tracking results and after sufficient large partnership audit results have been obtained, it still plans to conduct a study to analyze these results and recommend any ways in which resource use can be improved. IRS still expects to complete this analysis by September 2018.
    Director: Iritani, Katherine M
    Phone: (202) 512-7114

    1 open recommendations
    Recommendation: To improve transparency of and accountability for Medicaid non-DSH supplemental payments, Congress should consider requiring the Administrator of CMS to (1) improve state reporting of non-DSH supplemental payments, including requiring annual reporting of payments made to individual facilities and other information that the agency determines is necessary to oversee non-DSH supplemental payments; (2) clarify permissible methods for calculating non-DSH supplemental payments; and (3) require states to submit an annual independent certified audit verifying state compliance with permissible methods for calculating non-DSH supplemental payments.

    Agency: Congress
    Status: Open

    Comments: As of August 2017, no legislation had been enacted although at least one bill had been introduced in the Congress that would implement this Matter. If enacted, H.R. 541 would, among other things, require annual reporting of non-DSH supplemental payments made to individual institutional providers; information on type of ownership of providers that received the supplemental payments; and other information the agency determines is necessary to oversee non-DSH supplemental payments. However, CMS has taken some actions administratively to understand how to improve its oversight, which are underway. CMS had planned to publish a proposed rule for public comment in fall 2016 that could improve the oversight of supplemental payments made to individual providers. As of August 2017, the agency stated that it is gathering information from data submitted by states to better inform individual provider level payment criteria and establish policies and procedures to evaluate whether payments at the provider level are economic and efficient. They expect to complete this process by March 2018. CMS has also awarded a contract to review Medicaid supplemental payment information submitted by states that may, according to CMS officials, provide information to identify areas for future supplemental payment oversight, including issuing additional guidance on non-DSH supplemental payment submissions and developing standardized formatting. CMS reported that in 2016 it received approval from the Office of Management and Budget to issue standardized templates for all states to use when submitting the annual non-DSH supplemental payments for agency review, but did not specify when standard templates would be used. CMS also reported that the agency was developing a tool to assist in reviewing amendments to state plans and analyzing non-DSH supplemental payments. GAO plans to continue to monitor congressional action, as well as CMS's guidance on supplemental payments to individual providers and actions resulting from the contracted review to determine the extent to which improve state reporting of non-DSH supplemental payments, clarify permissible methods for calculating non-DSH supplemental payments, and require audits to verify that states use permissible methods to calculate non-DSH supplemental payments.