Corrective Action Plans

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Auditors’ Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Grantee Response: We will comply with the auditors’ recommendation. Anticipated Completion Date: June 30, 2026 Views of responsible officials and planned corrective actions: We ...
Auditors’ Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Grantee Response: We will comply with the auditors’ recommendation. Anticipated Completion Date: June 30, 2026 Views of responsible officials and planned corrective actions: We will comply with the auditors’ recommendations.
Corrective Action Plan - Public and Indian Housing - interfund receivable balance. Contact person: Alana Burnet, Executive Director, Housing Authority of Gilmer, 104 Circle Drive, Gilmer, TX 75644-0397, telephone number (903) 843-3141. Correction action planned: The PHA will have its Section 8 new c...
Corrective Action Plan - Public and Indian Housing - interfund receivable balance. Contact person: Alana Burnet, Executive Director, Housing Authority of Gilmer, 104 Circle Drive, Gilmer, TX 75644-0397, telephone number (903) 843-3141. Correction action planned: The PHA will have its Section 8 new construction program reimburse the Public and Indian Housing Program for the interfund balance and make sure any interfund activity is reimbursed on a monthly basis. Anticipated completion date: Immediately.
Auditor’s Recommendation: The Authority should perform a random inspection of 20% of the units in each building as per the housing payments contracts and ensure documentation of a “passed” housing quality inspection is maintained. A thorough review of tenant files should be performed for the purpose...
Auditor’s Recommendation: The Authority should perform a random inspection of 20% of the units in each building as per the housing payments contracts and ensure documentation of a “passed” housing quality inspection is maintained. A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Grantee Response: HQS inspections were performed upon move-in of a new tenant. We will continue the move-in inspections and perform the required random sample of inspections for 20% of the units under contract in each building. Anticipated Completion Date: June 30, 2026
Auditor’s Recommendation: This is a repeat finding. A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Grantee Response: We will comply with the auditor’s recommendation. Anticipated Completion Date: June 30, 2025
Auditor’s Recommendation: This is a repeat finding. A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Grantee Response: We will comply with the auditor’s recommendation. Anticipated Completion Date: June 30, 2025
Recommendation: The Department of Social Services should provide the necessary resources and institute procedures to ensure that it uses all information from eligibility, income, and death matches to ensure that it correctly issues benefits to or on behalf of eligible clients. DSS should return fede...
Recommendation: The Department of Social Services should provide the necessary resources and institute procedures to ensure that it uses all information from eligibility, income, and death matches to ensure that it correctly issues benefits to or on behalf of eligible clients. DSS should return federal reimbursements for unallowable expenditures claimed under Medicaid and SNAP. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. DSS staff is in the development phase of implementing new automated procedures to ensure timely and accurate action is taken to discontinue benefits of deceased clients when date of death information is received and matched to the Connecticut Department of Public Health’s State Vital Records Office. Action has been taken to correct the errors cited, including discontinuing the benefits of the individuals that were verified as deceased, and recouping the overpayments as appropriate. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Dan Giacomi, Program Division Director (860) 424-5080
Recommendation: The Department of Housing should strengthen internal controls to ensure that it properly calculates and supports Section 8 Housing Choice Vouchers and Mainstream Vouchers housing assistance and utility benefit payments. Corrective Action Plan as Reported by the Department of Housing:...
Recommendation: The Department of Housing should strengthen internal controls to ensure that it properly calculates and supports Section 8 Housing Choice Vouchers and Mainstream Vouchers housing assistance and utility benefit payments. Corrective Action Plan as Reported by the Department of Housing: We agree with the finding. DOH did contract with a third-party entity to provide these services; however, DOH retains overall responsibility for the program. Recently, DOH established a Section 8 division within DOH to provide more oversight over the program and contactor. We are working closely with the contractor to strengthen their internal control, develop policies and procedures. DOH will continue collaborating with the contractor to enhance system controls and minimize the risk of future issues. All identified errors in this finding have been corrected including the questionable cost. DOH remains committed to continuous improvement and effective oversight of the program and contractor. Anticipated Completion Date: April 30, 2026 Department of Housing Contact Person: Melvin Castillo, Asst. Chief Fiscal Admin. Services Natasha Khemraj, Accounting Program Manager (860) 899-6585
Recommendation: The Department of Housing should properly monitor its contractor to ensure that it only awards benefits to eligible recipients. Corrective Action Plan as Reported by the Department of Housing: We agree with the finding. DOH did contract with a third-party entity to provide these serv...
Recommendation: The Department of Housing should properly monitor its contractor to ensure that it only awards benefits to eligible recipients. Corrective Action Plan as Reported by the Department of Housing: We agree with the finding. DOH did contract with a third-party entity to provide these services. The contractor has been experiencing technical difficulties accessing the HUD system. We are aware of this current situation, and we are working with HUD to resolve this issue as soon as possible. Anticipated Completion Date: Ongoing Department of Housing Contact Person: Melvin Castillo, Asst. Chief Fiscal Admin. Services Natasha Khemraj, Accounting Program Manager (860) 899-6585
Recommendation: The Department of Housing should strengthen internal controls to ensure that it properly calculates Section 8 Housing Choice Vouchers and Mainstream Vouchers housing assistance and utility benefit payments. Corrective Action Plan as Reported by the Department of Housing: We agree wit...
Recommendation: The Department of Housing should strengthen internal controls to ensure that it properly calculates Section 8 Housing Choice Vouchers and Mainstream Vouchers housing assistance and utility benefit payments. Corrective Action Plan as Reported by the Department of Housing: We agree with the finding. DOH did contract with a third-party entity to provide these services; however, DOH retains overall responsibility for the program. Recently, DOH established a Section 8 division within DOH to provide more oversight over the program and the contactor. We are working closely with the contractor to strengthen their internal control, develop policies and procedures. DOH will continue collaborating with the contractor to enhance system controls and minimize the risk of future issues. All identified errors in this finding have been corrected including the questionable cost, and the software now includes a new feature designed to prevent similar problems going forward. DOH remains committed to continuous improvement and effective oversight of the program and contractor. Anticipated Completion Date: April 30, 2026 Department of Housing Contact Person: Melvin Castillo, Asst. Chief Fiscal Admin. Services Natasha Khemraj, Accounting Program Manager (860) 899-6585
Recommendation: The Department of Public Health should strengthen internal controls over cash management to ensure that federal drawdowns align with the immediate cash needs to administer the program. Corrective Action Plan as Reported by the Department of Public Health: Management Assurance and Fis...
Recommendation: The Department of Public Health should strengthen internal controls over cash management to ensure that federal drawdowns align with the immediate cash needs to administer the program. Corrective Action Plan as Reported by the Department of Public Health: Management Assurance and Fiscal have worked together to identify gaps and inefficiencies in the drawdown tool. Management Assurance will periodically evaluate the drawdown tool’s usefulness and effectiveness as a cash management internal control. Fiscal will continue to monitor grant draws through the use of the improved drawdown tool. Anticipated Completion Date: Ongoing Department of Public Health Contact Person: Chuma Amechi, Fiscal Administrative Manager chukwuma.amechi@ct.gov (860) 509-7233 Ryan Wenzel, Supervising Accounts Examiner ryan.wenzel@ct.gov (860) 509-7822
Recommendation: The Department of Social Services should strengthen internal controls over sanctions to ensure compliance with Temporary Assistance for Needy Families child support enforcement requirements. Corrective Action Plan as Reported by the Department of Social Services: The Department agree...
Recommendation: The Department of Social Services should strengthen internal controls over sanctions to ensure compliance with Temporary Assistance for Needy Families child support enforcement requirements. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with the finding. DSS Economic Security and Office of Child Support Services implemented a new child support non-cooperation referral process on November 25, 2025. It is task based, assures an accurate and complete universe of sanction notices for child support non-cooperation are provided, and assures staff process and document all required sanctions. Anticipated Completion Date: November 25, 2025 Department of Social Services Contact Person: Tricia Morelli, Program Administrative Manager (860) 424-5519
Recommendation: The Department of Social Services should strengthen internal controls to ensure that only eligible recipients receive temporary family assistance in accordance with federal laws and the Temporary Assistance for Needy Families State Plan. Corrective Action Plan as Reported by the Depa...
Recommendation: The Department of Social Services should strengthen internal controls to ensure that only eligible recipients receive temporary family assistance in accordance with federal laws and the Temporary Assistance for Needy Families State Plan. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. The error occurred due to a system issue that did not trigger the discontinuance of benefits for a household that had received 60 months of time-limited benefits. The Department will take action to correct the system functionality to ensure incorrect payments are not made to households that have received 60 months of time-limited benefits. An overpayment has been created, and the recovery of the error amount is in process. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Dan Giacomi, Program Division Director (860) 424-5080
Recommendation: The Department of Housing should promptly submit required financial information to the Department of Housing and Urban Development in accordance with Title 24 U.S. Code of Federal Regulations Part 5.801. Corrective Action Plan as Reported by the Department of Housing: We agree with t...
Recommendation: The Department of Housing should promptly submit required financial information to the Department of Housing and Urban Development in accordance with Title 24 U.S. Code of Federal Regulations Part 5.801. Corrective Action Plan as Reported by the Department of Housing: We agree with the finding. The Department of Housing (DOH) submitted its 2019 audit in August 2025 and is currently awaiting the Auditor’s approval. With the new stablished Section-8 Division, the additional support has made a great impact, and it has helped expedite this work. However, the process is time consuming because we cannot submit audits for subsequent years until the prior year’s audit is approved. Once the 2019 audit is approved, we will begin work on the 2020 audit and continue sequentially until we are fully up to date. Our goal is to be fully caught up by December 31, 2027. Anticipated Completion Date: Ongoing Department of Housing Contact Person: Melvin Castillo, Asst. Chief Fiscal Admin. Services Natasha Khemraj, Accounting Program Manager (860) 899-6585
Recommendation: The Department of Mental Health and Addiction Services should strengthen internal controls to ensure providers maintain sufficient and current documentation to support the reasonableness of rent for the Continuum of Care Program. Corrective Action Plan as Reported by the Department o...
Recommendation: The Department of Mental Health and Addiction Services should strengthen internal controls to ensure providers maintain sufficient and current documentation to support the reasonableness of rent for the Continuum of Care Program. Corrective Action Plan as Reported by the Department of Mental Health and Addiction Services: DMHAS Housing and Homeless Services Unit verbally instructed providers that they must complete, prior to client move-in, accurately, sign and retain documentation regarding the comparable units when completing the Rent Reasonableness on December 17, 2024. On December 24, 2024 and December 19, 2025, these instructions were sent to the providers via email. On February 4, 2025, DMHAS updated the CoC Operations Guide with the full instructions for completing the Rent Reasonableness and the retention of supporting documentation. DMHAS will continue to randomly review a sample of Rent Reasonable documents throughout the year and will provide training and technical assistance to providers on the completion and retention of Rent Reasonableness documentation. Anticipated Completion Date: June 30, 2026 Department of Mental Health and Addiction Services Contact Person: Alice Minervino, Director, Housing and Homeless Services Alice.minervino@ct.gov (860) 418-6942
Recommendation: The Department of Mental Health and Addiction Services should strengthen internal controls to ensure providers maintain sufficient documentation to support participant eligibility and accurately calculate client income and rental assistance payments in the Continuum of Care Program. ...
Recommendation: The Department of Mental Health and Addiction Services should strengthen internal controls to ensure providers maintain sufficient documentation to support participant eligibility and accurately calculate client income and rental assistance payments in the Continuum of Care Program. Corrective Action Plan as Reported by the Department of Mental Health and Addiction Services: In 2026, DMHAS will continue to conduct trainings on CoC Fiscal Requirements. As in the past, these trainings will be recorded and available for viewing on the Connecticut Balance of State Continuum of Care (CTBOS) website. DMHAS Housing and Homeless Services Unit staff conduct mandatory in-person and virtual Technical Assistance visits for the funded agencies to provide guidance and training on the United States Department of Housing and Urban Development (HUD) required eligibility regulations Income Calculation and Documentation. On November 1, 2023, DMHAS implemented a Microsoft Excel Workbook that is fully inclusive of the DMHAS required paperwork, including the income calculation, lease, contract, as well as initial and recertification which standardizes the documents for each participant. On December 19, 2025, the workbook was updated to enhance internal controls over the use of Rent Reasonableness forms and calculations of client income and rental assistance payments. The DMHAS Housing and Homeless Services Unit will continue to work with the DMHAS Fiscal Services Bureau to ensure payments are made accurately, correctly and on-time. Anticipated Completion Date: June 30, 2026 Department of Mental Health and Addiction Services Contact Person: Alice Minervino, Director, Housing and Homeless Services Alice.minervino@ct.gov (860) 418-6942
Finding: The operating cash account balance was over the Federal Deposit Insurance Corporation (FDIC) limit of $250,000 during the year ended August 31, 2025, however, the Organization was not actively monitoring the financial institution credit rating as required by HUD. We recommend management dev...
Finding: The operating cash account balance was over the Federal Deposit Insurance Corporation (FDIC) limit of $250,000 during the year ended August 31, 2025, however, the Organization was not actively monitoring the financial institution credit rating as required by HUD. We recommend management develop internal processes and controls surrounding activities allowed or unallowed. This includes following the requirements as outlined by HUD to have the operating cash be FDIC insured or actively be monitoring the credit rating of the financial institution. Corrective Response: Management will implement quarterly reviews of HUD cash balances as well as review the credit ratings of the financial institutions holding HUD cash balances. Anticipated Completion Date: 3/31/26 Responsible Contact Person: Brenda Satterfield, CFO and Errol Meinholz, Controller 920-245-9275
HACA will develop a standardized checklist protocol for HQS deficiency followup by 04/30/2026. Staff training on required HUD timelines and documentation standards is ongoing and will be emphasized. HACA is currently working with an outside housing programs consultant to review and update work proce...
HACA will develop a standardized checklist protocol for HQS deficiency followup by 04/30/2026. Staff training on required HUD timelines and documentation standards is ongoing and will be emphasized. HACA is currently working with an outside housing programs consultant to review and update work processes related to HQS enforcement and ensure compliance. We anticipate completion by 09/30/2026.
Recommendation: We recommend that the Authority develop and implement procedures for the Housing Quality Standards which provide for re-inspections within the period provided by the standards for housing quality violations. Views of Responsible Officials and Planned Corrective Actions: The Authority...
Recommendation: We recommend that the Authority develop and implement procedures for the Housing Quality Standards which provide for re-inspections within the period provided by the standards for housing quality violations. Views of Responsible Officials and Planned Corrective Actions: The Authority will amend the timing and procedures related to the voucher tenant inspections to provide staff with resources to timely follow up on failed inspections including the ability to re-inspect properties within the period provided by the standards when violations are determined.
FINDING 2025-008 Name of Responsible Individual: Tracey Jenkins, Student Account Billing Coordinator/Lisa Simon, CPA, CFO Corrective Action: Wheeling University worked with ECSI regarding Perkins information last year. With the Perkins program ending, we realized that we needed to move in the direct...
FINDING 2025-008 Name of Responsible Individual: Tracey Jenkins, Student Account Billing Coordinator/Lisa Simon, CPA, CFO Corrective Action: Wheeling University worked with ECSI regarding Perkins information last year. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. The University is currently working with ECSI so that we can submit Perkins information/files to the Department of Education. We have gathered information (promissory notes, bankruptcy details, payment information, etc.) as we have been able to locate it, and and we have sorted account in alpha order to assist ECSI with the process. We will continue to update this process. Anticipated Completion Date: June 2026
Federal Agency Name: Program Name: Finding Summary: Corrective Action Plan: Responsible Individual: Department of Housing and Urban Development Supportive Housing for Persons with Disabilities Federal Assistance Listing #14.181 The Corporation did not have a separate review over the budget worksheet...
Federal Agency Name: Program Name: Finding Summary: Corrective Action Plan: Responsible Individual: Department of Housing and Urban Development Supportive Housing for Persons with Disabilities Federal Assistance Listing #14.181 The Corporation did not have a separate review over the budget worksheet HUD-92457-A by someone other than the preparer prior to submitting it to HUD. We will implement controls to ensure the budget worksheet HUD-92457-A is reviewed by someone other than the preparer prior to being submitted to HUD. Josh Plecity, Finance Director Anticipated Completion Date: 12/31/2026
Federal Agency Name: Program Name: Finding Summary: Corrective Action Plan: Responsible Individual: Department of Housing and Urban Development Supportive Housing for Persons with Disabilities Federal Assistance Listing #14.181 The Corporation did not deposit project funds in a federally insured acc...
Federal Agency Name: Program Name: Finding Summary: Corrective Action Plan: Responsible Individual: Department of Housing and Urban Development Supportive Housing for Persons with Disabilities Federal Assistance Listing #14.181 The Corporation did not deposit project funds in a federally insured account within 60 days of the fiscal year end. The Corporation did not have the deposit amount determined timely enough to have the project funds deposited within 60 days of the fiscal year end. We will implement controls to ensure the required amount of project fund are deposited within 60 days following the end of the fiscal year. Josh Plecity, Finance Director Anticipated Completion Date: 12/31/2026
Deposits in Excess of FDIC & Pledged Securities Coverage (same as financial finding # 2025-001).
Deposits in Excess of FDIC & Pledged Securities Coverage (same as financial finding # 2025-001).
Finding 2025-002: Significant Deficiency in Internal Control Over Compliance and Non-Material Noncompliance Federal Awarding Agency: Department of Housing and Urban Development (HUD) Responsible Person: Eric Keeler, Director, Department of Housing and Community Development Estimated Completion: Apri...
Finding 2025-002: Significant Deficiency in Internal Control Over Compliance and Non-Material Noncompliance Federal Awarding Agency: Department of Housing and Urban Development (HUD) Responsible Person: Eric Keeler, Director, Department of Housing and Community Development Estimated Completion: April 15, 2026 Corrected Action: 1. The Housing Choice Voucher (HCV) Program transitioned to a new client management software on August 1, 2025 and program staff are reviewing all of the existing inspection due dates in the software to ensure the dates are correct based on the last biennial inspection or initial inspection. 2. Staff will continue to utilize the monthly Section Eight Management Assessment Program (SEMAP) Indicators Report in HUD’s Public and Indian Housing Information Center (PIC) database and provide that information to the inspectors monthly. 3. Staff will begin to utilize the Housing Quality Standards (HQS) Inspection Report that is now available in HUD’s Public and Indian Housing Information Center (PIC) database. This report allows staff to see all inspections that will be due in the next year, according to PIC data. The HCV Program Manager will review the report with the Housing Inspectors monthly to verify that all of the upcoming inspections are scheduled. 4. The HCV Program Manager will schedule monthly meetings to review upcoming Inspections Due with the two Housing Inspectors on staff. The HCV Program Manager will verify that each of the inspections due are scheduled in advance and check the next month’s list of completed inspections to ensure all of the inspections scheduled were completed in a timely manner. If the inspections are not completed in a timely manner, the HCV Program Manager will investigate the cause and determine if corrective action and/or additional quality assurance is needed. 5. The HCV Program Manager will review the Completed Inspections Report from the software provider to ensure that it provides a complete list of all failed inspections. This will be completed on a monthly basis with the Housing Inspectors by comparing the list with Inspection Records for the month. 6. An additional Housing Inspector position was added in FY 2026, which allows the inspections to be divided between the two Housing Inspectors. This added position will allow more time for Housing Inspectors to review reports, prepare for, and schedule inspections.
Finding 2025-001: Material Weakness in Internal Control Over Compliance and Non-Material Noncompliance Federal Awarding Agency: Department of Health and Human Services (HHS) Responsible Person: Deidra Bolden, Acting Director, Department of Family Services Estimated Completion: June 30, 2026 Correcte...
Finding 2025-001: Material Weakness in Internal Control Over Compliance and Non-Material Noncompliance Federal Awarding Agency: Department of Health and Human Services (HHS) Responsible Person: Deidra Bolden, Acting Director, Department of Family Services Estimated Completion: June 30, 2026 Corrected Action: 1. The Department of Family Services has implemented a Medicaid-focused caseworker structure and a specialized intake-and-ongoing case management model. This model reduces task switching and allows staff to develop proficiency more quickly by focusing on Medicaid and progressing from simpler to more complex case types. It also improves consistency in case processing and allows supervisors to provide more targeted oversight. The Department has also completed a Medicaid Overdue Resolution Project, significantly reducing backlog and stabilizing renewal processing. These structural changes, combined with reduced caseloads and increased supervisory capacity, allow for more focused case management, improved oversight, and more consistent application of eligibility policy. 2. The Department has expanded training capacity and structure to address prior limitations. A second trainer position has been added, doubling internal training capacity and enabling more frequent onboarding, refresher training, and targeted instruction. This allows the Department to better support both new and tenured staff and respond more quickly to identified training needs. In addition, the Department is implementing a competency-based training model that establishes structured learning pathways for new staff, experienced workers, and supervisors. This model incorporates modular curriculum, scenario-based application, and targeted refreshers tied to error trends, supporting more consistent policy application and stronger staff development over time. 3. The Department is strengthening monitoring and case review practices to improve early detection of issues and reinforce consistent oversight. As supervisory capacity has increased and caseloads have begun to stabilize, supervisors are better positioned to conduct more frequent and targeted case reviews, particularly for high-risk and time-sensitive work. The Department is also strengthening case review capacity and moving toward a higher percentage of routine case review to improve early detection of errors and reinforce policy compliance. Trend analysis is being expanded to identify patterns across workers, supervisors, and case types, allowing for more targeted and timely corrective action. These enhancements, supported by improved staffing levels and more manageable caseloads, strengthen the Department’s ability to identify issues earlier, reinforce expectations consistently, and reduce the likelihood of overdue or noncompliant cases. 4. The Department is strengthening how it evaluates the effectiveness of corrective actions by conducting on going case reviews, monthly performance monitoring to track timeliness and accuracy trends, performing trend analysis over time to measure improvement and identify recurring issues, and conducting executive-level reporting to monitor progress and ensure accountability. These evaluation methods provide a structured approach to verifying that corrective actions are implemented effectively and produce sustained improvement. 5. The Department has onboarded additional staff, including supervisors, case managers, a case reviewer, and a trainer, improving both workload distribution and monitoring capacity. Continued investment in staffing, combined with ongoing efforts to right-size caseloads, is expected to further strengthen supervisory oversight, expand case review capacity, and sustain improvements in timeliness and compliance.
Corrective Actions: Housing Authority of the City of Baldwin Park (HACBP) has taken immediate corrective actions. All required inspections now are current and supporting documentation is complete and properly filed. Management continues to monitor inspection activities to prevent recurrence of the c...
Corrective Actions: Housing Authority of the City of Baldwin Park (HACBP) has taken immediate corrective actions. All required inspections now are current and supporting documentation is complete and properly filed. Management continues to monitor inspection activities to prevent recurrence of the conditions noted. Management has also taken immediate and comprehensive corrective measures, including: • Removal of the external consultant from all inspection-related responsibilities. • Return of HACBP’s in‑house inspector from extended leave, restoring full internal oversight of the HQS inspection process. • Assignment of inspection responsibilities solely to trained HACBP inspection and management staff. • Implementation of strengthened procedures for tracking, scheduling, and documenting all inspections including, initial, re-inspections, and annual/biennial inspections. • Verification that all inspection files are properly uploaded, retained, and accessible in accordance with HACBP’s file management policies.
Department: Health and Human Services Title: Internal control over Medicaid utilization control needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. This finding represents a mis...
Department: Health and Human Services Title: Internal control over Medicaid utilization control needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. This finding represents a misunderstanding of the applicable federal regulations and the state entity responsible for compliance. A Utilization Control (UC) program is the responsibility of the State Medicaid Agency as a whole, not the Program Integrity Unit (PIU). Additionally, there are many more federal regulations governing UC programs than cited by the Office of State Auditor (OSA) in the finding and touch on a host of controls that were not reviewed or considered in this audit. Moreover, the OSA appears to be basing findings on interpretations that are unsupported by the regulatory text cited. Second, the OSA confuses PIU's annual review plan (a yearly plan of focused program integrity areas of focus and review) with an agency-wide UC program: these are not the same, nor are they required to be. The Department's current processes for PIU's annual review plan were implemented in response to OSA findings in 2015 relating to an OSA finding that the Department was not fully utilizing available data analytics. In the intervening years, the OSA has not found Program Integrity's annual review plan, or the process of developing the plan, to be deficient. There has been no change in the Department's process or the regulation to justify the OSA's newly found position here. The OSA's criticism of PIU's use of data analytics contradicts a prior OSA findings on data analytics use, is contrary to accepted Department adjustments made in response, and represents a significant departure from federal guidance and industry standards around best practices for leveraging data analytics to prevent and detect improper payments and/or utilization. The PIU's annual review plan supplements post-payment reviews that PIU conducts based upon complaints and referrals. Finally, this finding’s singular focus on PIU's annual review plan fails to account for a myriad of other systems and processes the Department has in place to monitor utilization, including, but not limited to: 1. A contracted vendor (HMS) performing post-payment reviews of hospitals, nursing facilities, and other long-term care facilities; 2. MaineCare's Case Mix unit - performing look back reviews of documentation and services in nursing facilities and other long-term care units; 3. A contracted vendor (Acentra) reviewing authorization requests for behavioral health services and continuing stay reviews of services at designated intervals; 4. A contracted vendor (Maximus) that performs assessments and authorizations for nursing and personal care services; 5. A contracted vendor (Optum) that performs prior authorization reviews for pharmacy services and produces a variety of reports on drug utilization; 6. Fiscal intermediaries performing oversight and administrative support for self-directed services; 7. State staff who review and approve plans of care for Home and Community Based Waiver Services and conduct quality reviews of providers; 8. State staff performing quality assurance reviews of providers of mental and behavioral health services; 9. State staff monitoring and addressing inappropriate emergency department usage by beneficiaries; and 10. State staff with oversight and performing qualitative and quantitative reviews of a variety of programs operated under delivery service reform, including: Accountable Communities, Behavioral Health Homes, Certified Community Behavioral Health Clinics, Community Care Teams, MaineMOM, Opioid Health Homes, and Primary Care Plus. 11. State and contracted vendor (Gainwell) staff reviewing medical necessity and other allowability for medical services requiring prior authorization for initial requests and renewals. 12. A CMS-compliant Electronic Visit Verification (EVV) system, in accordance with Section 12006 of the 21st Century Cures Act, that ensures payment for applicable services is tied to an EVV record demonstrating that the service occurred; data from the system also contributes to post-payment reviews for applicable services. Completion Date: N/A Agency Contact: Michelle Probert, Director, Office of MaineCare Services, DHHS, 207-287-2093
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