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Corrective Action Plans

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Finding 366885 (2022-001)
Material Weakness 2022
Del Norte Child Care Council
CA
Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties
Management agrees that due to turnover in staff during 2022 and 2023, there were gaps in communication leading to the cost allocation formulas and leadsheet account reconciliations not being updated on a continuing basis as reimbursement requests were being to the California Department of Social Ser...
Management agrees that due to turnover in staff during 2022 and 2023, there were gaps in communication leading to the cost allocation formulas and leadsheet account reconciliations not being updated on a continuing basis as reimbursement requests were being to the California Department of Social Services. Management believes that all key accounting positions have since been filled by qualified personnel. A formal close process and reconciliation of all balance sheet accounts and indirect cost allocations each month will ensure reimbursement requests are complete and accurate. Process documentation is also being prepared to help personnel in the accounting department follow proper control procedures. Action: Develop and document process for drawdown calculation and year end reconciliation to accounting records. Due Date: 3/1/23 Staff: Don Reynolds, contracted CFO
View Audit 290035
Finding 366811 (2022-001)
Material Weakness 2022
Northern Maine General
ME
Reporting Matching / Level of Effort / Earmarking
Finding 2022-001 Corrective Action Plan Northern Maine General (the Organization) has created a policy to annually review the federal compliance supplement to ensure compliance and reporting requirements with federal programs. As additional federal funding is received the Organization will conduct a...
Finding 2022-001 Corrective Action Plan Northern Maine General (the Organization) has created a policy to annually review the federal compliance supplement to ensure compliance and reporting requirements with federal programs. As additional federal funding is received the Organization will conduct a thorough review to maintain compliance with all programs. Responsible Party: Michelle Raymond, CEO Missy Boutot, Accounting Supervisor Estimated Completion Date: 09/11/2023
View Audit 289857
Finding 366772 (2022-004)
Material Weakness 2022
Center for Disease Dynamics Economics & Policy Inc.
MD
Internal Control / Segregation of Duties Cash Management Material Weakness § 200.302 § 200.303
Agree with the finding. We will implement the segregation of duties matrix as part of SOPs. We will ensure that authorization and review of cash draws of fedral funds are done by some one other than the individual who initiates and records the transaction . We have implemented the same and Dr EIli (...
Agree with the finding. We will implement the segregation of duties matrix as part of SOPs. We will ensure that authorization and review of cash draws of fedral funds are done by some one other than the individual who initiates and records the transaction . We have implemented the same and Dr EIli (pi) is reviewing and approving the report before each withdrawal. The Finance Head ( Nafih) is withdrawing the fund .Anticipated Completion Date : 12/31/2022 Actual date of implementation :01/24/2023
View Audit 289832
Finding 366756 (2022-007)
Material Weakness 2022
South Bend Community School Corporation
IN
Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management § 200.302 § 200.303 § 200.328 § 200.329 § 200.334
FINDING 2022-007 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Finding: No oversight of reports and supporting documentation did not agrees to report submitted Recommendation: Provide oversight of reports submitted and retain supporting documentation that a...
FINDING 2022-007 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Finding: No oversight of reports and supporting documentation did not agrees to report submitted Recommendation: Provide oversight of reports submitted and retain supporting documentation that agrees to reports submitted Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Deb Martin, Director of Student Learning & Title I Contact Phone Number and Email Address: Kareemah Fowler (574) 393-6088; kfowler@sbcsc.k12.in.us Deb Martin (574) 393-6053; dmartin@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports and supporting documentation, which supports each report submitted, will be reviewed/approved by the program director. All supporting documentation will be retained for future audits. Anticipated Completion Date: December 8, 2024
View Audit 289747
Finding 366754 (2022-005)
Material Weakness 2022
South Bend Community School Corporation
IN
Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303
FINDING 2022-005 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card/High School Graduation Rate Summary of Finding: Finding: Exit documentation was missing or incorrectly matched with student mobility codes for students in the testing sa...
FINDING 2022-005 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card/High School Graduation Rate Summary of Finding: Finding: Exit documentation was missing or incorrectly matched with student mobility codes for students in the testing sample of the 2022 cohort. Contact Person Responsible for Corrective Action: Rafi Nolan-Abrahamian, Assistant Superintendent of Accountability and Innovation Contact Phone Number and Email Address: 574-393-6179; rnolan-abrahamian@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: SBCSC will conduct re-training of all High School principals and data technicians to review SBCSC withdrawal policies (outlined below), along with required documentation for each exit/mobility code. This training will be conducted in January 2024. District staff will confirm with each high school that procedures below are in place by reviewing cohort binders with the principal and data technician. Meetings will be scheduled in the Spring of 2024. Procedure for Withdrawing Students from all SBCSC High Schools Anytime a parent requests that a student withdraw from a high school, the following steps must be followed. If a parent is not requesting a transfer, the principal will complete an exit interview. All transfers will follow this procedure. (Please also see the procedure for processing no shows.) 1. Only the principal is allowed to sign the withdrawal form. If the principal is not available, an assistant principal may sign the withdrawal form and immediately email it to the principal. 2. Prior to signing the withdrawal form, the principal will speak with the parents and student to gather any information that may help the school understand why a withdrawal is necessary. Once this conversation has happened, the principal will advise the parent and student. 43 INDIANA STATE BOARD OF ACCOUNTS South􀀃Bend􀀃Community􀀃School􀀃Corporation􀀃 215􀀃South􀀃Dr.􀀃Martin􀀃Luther􀀃King􀀃Jr.􀀃Boulevard􀀃􀀃 􀀃South􀀃Bend,􀀃Indiana􀀃46601􀀃􀀃 574􀇦393􀇦6100􀀃􀀃 􀀃 􀀃 􀀃 􀀃 INTEGRITY􀀃•􀀃ACCOUNTABILITY􀀃•􀀃EMPOWERMENT􀀃 􀀃 ACADEMIC􀀃QUALITY􀀃|􀀃EQUITY,􀀃INCLUSION􀀃&􀀃JUSTICE􀀃|􀀃FINANCIAL􀀃 SUSTAINABILITY􀀃|􀀃COMMUNITY􀀃PARTNERSHIPS􀀃 􀀃 3. If it is determined that the student will transfer, the signed withdrawal form will be filed in a binder based on class cohort. For example, all students scheduled to graduate in the spring of 2022 will be filed with the 2022 cohort. The principal must determine the name and contact information for the receiving school. 4. It is the responsibility of the data technician to manage these cohorts by checking Learning Connection weekly. If discrepancies are visible in Learning Connection, a data technician will contact the SBCSC Department of Research and Evaluation and the IDOE. 5. The secretary of student management will forward any requests for records to the data technician to file with the student’s withdrawal paperwork. (We must have a request for records for every student withdrawing from SBCSC.) 6. The data technician will follow up regarding any student with whom we did not receive a request for records for within one week of the withdrawal. The data technician will contact the receiving school and parent to locate the records request. 7. The data technician will continue to locate a request for records weekly until the request is received by SBCSC. 8. Documentation will be maintained of all efforts made to collect the information. Anticipated Completion Date: Spring 2024
View Audit 289747
Finding 366753 (2022-004)
Material Weakness 2022
South Bend Community School Corporation
IN
Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334
FINDING 2022-004 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: Finding: Detail data on the Form 9 and Reimbursement Request was not provided to knowledgeable individuals for review. Recommendation: Design control that provides sufficient data to knowle...
FINDING 2022-004 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: Finding: Detail data on the Form 9 and Reimbursement Request was not provided to knowledgeable individuals for review. Recommendation: Design control that provides sufficient data to knowledgeable individuals for review. Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Contact Phone Number and Email Address: (574) 393-6088; kfowler@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Form 9 Data The Human Resources Department has added a second review to verify all employee distribution codes are correct when recording/updating employee requisitions. Additionally, detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed December 8, 2023, and May 2023 Reimbursement Requests Summary level payroll data is no longer being used to support reimbursement requests. Detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed May 2023.
View Audit 289747
Finding 366751 (2022-002)
Material Weakness 2022
South Bend Community School Corporation
IN
Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303
FINDING 2022-002 Finding Subject: Title I Grants to Local Educational Agencies -Internal Controls Summary of Finding: Finding: Ineffective internal controls over Eligibility, Level of Efforts and Earmarking Recommendation: That the School Corporation design and implement a proper system of internal ...
FINDING 2022-002 Finding Subject: Title I Grants to Local Educational Agencies -Internal Controls Summary of Finding: Finding: Ineffective internal controls over Eligibility, Level of Efforts and Earmarking Recommendation: That the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Contact Person Responsible for Corrective Action: Rafi Nolan-Abrahamian, Assistant Superintendent of Accountability and Innovation Kareemah Fowler, Assistant Superintendent of Business and Finance Debra Martin, Director of Student Learning and of Title I Contact Phone Number and Email Address: Rafi Nolan-Abrahamian (574) 393-6179; rnolan-abrahamian@sbcsc.k12.in.us Kareemah Fowler (574) 393-6088; kfowler@sbcsc.k12.in.us Deb Martin (574) 393-6053; dmartin@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Eligibility The district has followed the procedures below to ensure the publishing of accurate eligibility information. The district has now clearly documented the procedures for future audit cycles. Titan (lunch status data) is imported into PowerSchool every week by the Student Information System administrator in the lead up to October reporting deadlines. Prior to certification, the Data Content Manager republishes all of the student demographic/identification records to update the certified values. Pupil Enrollment rosters from Data Exchange are compared to files from Titan to verify alignment of all individual student lunch status values. Anticipated Completion Date: Completed October 2023 39 INDIANA STATE BOARD OF ACCOUNTS South􀀃Bend􀀃Community􀀃School􀀃Corporation􀀃 215􀀃South􀀃Dr.􀀃Martin􀀃Luther􀀃King􀀃Jr.􀀃Boulevard􀀃􀀃 􀀃South􀀃Bend,􀀃Indiana􀀃46601􀀃􀀃 574􀇦393􀇦6100􀀃􀀃 􀀃 􀀃 􀀃 􀀃 INTEGRITY􀀃•􀀃ACCOUNTABILITY􀀃•􀀃EMPOWERMENT􀀃 􀀃 ACADEMIC􀀃QUALITY􀀃|􀀃EQUITY,􀀃INCLUSION􀀃&􀀃JUSTICE􀀃|􀀃FINANCIAL􀀃 SUSTAINABILITY􀀃|􀀃COMMUNITY􀀃PARTNERSHIPS􀀃 􀀃 Level of Effort The Human Resources Department has added a second review to verify all employee distribution codes are correct when recording/updating employee requisitions. Additionally, detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed December 8, 2023, and May 2023 Earmarking Summary level payroll data is no longer being used to support reimbursement requests. Detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed May 2023
View Audit 289747
Boys & Girls Club of North Alabama, INC
AL
Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303
Finding 2022-003 Finding: CACFP requires that non-Federal entities receiving Federal Awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. As part of our review of the Child and...
Finding 2022-003 Finding: CACFP requires that non-Federal entities receiving Federal Awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. As part of our review of the Child and Adult Care Food Program (CACFP) it was noted the Club was not adhering to accrual accounting as it pertains to reporting of expenses. Response: Adjustments have been made to the process of monthly adjustments. Additional procedures will be put in place to ensure financial reporting is done correctly.
View Audit 289590
Boys & Girls Club of North Alabama, INC
AL
Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303
Finding 2022-002 Finding: CACFP requires that non-Federal entities receiving Federal Awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. As part of our review of the Child and...
Finding 2022-002 Finding: CACFP requires that non-Federal entities receiving Federal Awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. As part of our review of the Child and Adult Care Food Program (CACFP) it was noted some of the Club’s daily food invoices were missing the site supervisor’s signature for having received the meals specified. Response: The monitor and director will review each month’s daily food invoices from all sites to ensure they are complete. Additional procedures will be put in place to ensure all daily food invoices have the appropriate receiving signatures.
View Audit 289590
Boys & Girls Club of North Alabama, INC
AL
Cash Management Reporting Matching / Level of Effort / Earmarking § 200.303
Finding 2022-001 Finding: CACFP requires that non-Federal entities receiving Federal Awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. The Club was unable to replicate exact...
Finding 2022-001 Finding: CACFP requires that non-Federal entities receiving Federal Awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. The Club was unable to replicate exact payroll expenses that were reported to the state monthly for the program. This is due to a lack of payroll documentation retained monthly. This documentation took time to replicate during the audit. No fraud is suspected related to payroll reporting issues for the program. Response: Adjustments were made to the payroll process to retain all supporting documentation and to replicate any prior period paperwork. The Club switched to a new payroll processor which has enabled improved payroll reporting.
View Audit 289590
Finding 366549 (2022-003)
Significant Deficiency 2022
City of Warwick, Rhode Island
RI
Questioned Costs Reporting Significant Deficiency § 200.303
Warwick Public Schools is in the process of hiring an assistant controller responsible for grants finance. This individual will reconcile expenses monthly, record revenues, receivables and reimbursements on a monthly basis. This will prevent the amount of year-end cleanup going forward.
Warwick Public Schools is in the process of hiring an assistant controller responsible for grants finance. This individual will reconcile expenses monthly, record revenues, receivables and reimbursements on a monthly basis. This will prevent the amount of year-end cleanup going forward.
View Audit 289401
Finding 366545 (2022-001)
Material Weakness 2022
Cleveland Municipal School District
OH
Equipment & Real Property Management Matching / Level of Effort / Earmarking Special Tests & Provisions
The District acknowledges it did not obtain certified payroll information from Panzica Construction until December 2022 which was after the Auditor raised the issue with the District. The District will work to ensure compliance with grant terms, in this instance, by assigning compliance responsibil...
The District acknowledges it did not obtain certified payroll information from Panzica Construction until December 2022 which was after the Auditor raised the issue with the District. The District will work to ensure compliance with grant terms, in this instance, by assigning compliance responsibility to the Cost Center Manager who negotiates, monitors, and receives invoices, and authorizes payments. Standard prevailing wage contract language will be developed in consultation with General Counsel’s Office with the language inserted into future contracts, as appropriate.
View Audit 289386
Finding 366543 (2022-002)
Significant Deficiency 2022
St. Barnabas Health System, Inc.
PA
Allowable Costs / Cost Principles Questioned Costs Reporting § 200.303
Management will work to make all necessary corrections on the period 6 report, if available. If period 6 is not available then we will work with HRSA to correct reporting errors outlined above through a revision to past reporting, providing additional documentation directly to the agency, or updates...
Management will work to make all necessary corrections on the period 6 report, if available. If period 6 is not available then we will work with HRSA to correct reporting errors outlined above through a revision to past reporting, providing additional documentation directly to the agency, or updates via future reporting, as applicable and deemed appropriate by the federal agency official.
View Audit 289380
Finding 366541 (2022-001)
Significant Deficiency 2022
St. Barnabas Health System, Inc.
PA
Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303
Management will work with the HRSA to correct reporting errors outlined above through a revision to past reporting, providing additional documentation directly to the agency, or updates via future reporting, as applicable and deemed appropriate by the federal agency official.
Management will work with the HRSA to correct reporting errors outlined above through a revision to past reporting, providing additional documentation directly to the agency, or updates via future reporting, as applicable and deemed appropriate by the federal agency official.
View Audit 289380
Finding 366522 (2022-001)
Significant Deficiency 2022
State of Hawaii Department of the Attorney General
HI
Reporting Questioned Costs Student Financial Aid § 200.512 § 200.514
Views of Responsible Officials and Planned Corrective Action
Views of Responsible Officials and Planned Corrective Action
View Audit 289361
Finding 366522 (2022-001)
Significant Deficiency 2022
State of Hawaii Department of the Attorney General
HI
Reporting Questioned Costs Student Financial Aid § 200.512 § 200.514
The Department understands the importance of complying with the Uniform Guidance with respect to the timely submission of single audit reports and the Data Collection Form, and have established policies and procedures to ensure compliance. The late submission in the prior year was primarily due to ...
The Department understands the importance of complying with the Uniform Guidance with respect to the timely submission of single audit reports and the Data Collection Form, and have established policies and procedures to ensure compliance. The late submission in the prior year was primarily due to unforeseen circumstances delaying the completion of the 2021 audit engagement.
View Audit 289361
Finding 322674 (2022-006)
Significant Deficiency 2022
Heartland Care Center Inc.
IA
Internal Control / Segregation of Duties Subrecipient Monitoring Matching / Level of Effort / Earmarking
GSA_MIGRATION
GSA_MIGRATION
View Audit 282473
Finding 322673 (2022-005)
Significant Deficiency 2022
Heartland Care Center Inc.
IA
Internal Control / Segregation of Duties Reporting Matching / Level of Effort / Earmarking
GSA_MIGRATION
GSA_MIGRATION
View Audit 282473
Heartland Care Center Inc.
IA
Internal Control / Segregation of Duties Subrecipient Monitoring Matching / Level of Effort / Earmarking
INSURANCE POLICY CO-OBLIGEE Criteria: The Organization is responsible for having the USDA Rural Development listed as a co-obligee on fidelity bonds or mortgagee (loss payee) on the property insurance policy....
INSURANCE POLICY CO-OBLIGEE Criteria: The Organization is responsible for having the USDA Rural Development listed as a co-obligee on fidelity bonds or mortgagee (loss payee) on the property insurance policy. Condition: During our review of internal control procedures for the Community Facilities Loans & Grants Cluster, we identified the USDA Rural Development was not listed as a co-obligee on the fidelity bonds or mortgagee (loss payee) on the property insurance policy. Cause: The requirement was not met due to managements? oversight of the requirement to update the property insurance policy. Potential Effect: As a result, the Agency reserves the right to withdraw Agency funding. Recommendation: The Organization should review current procedures to ensure that they are complying with all requirements of the USDA Rural Development loan. Client Response: The Organization will review their monitoring procedures to ensure that they follow loan requirements and also update the insurance policy to include USDA Rural Development as the mortgagee (loss payee).
View Audit 282473
Heartland Care Center Inc.
IA
Internal Control / Segregation of Duties Reporting Matching / Level of Effort / Earmarking
REPORTING Criteria: The Organization is responsible for maintaining proper controls over programs to submit complete and accurate quarterly financial statements within 20 days of the quarte...
REPORTING Criteria: The Organization is responsible for maintaining proper controls over programs to submit complete and accurate quarterly financial statements within 20 days of the quarter end, and the annual budget must be submitted to the Agency 30 days prior to the beginning of the borrower?s fiscal year. Condition: During our review of internal control procedures for the Community Facilities Loans & Grants Cluster, we identified the quarterly financial statements were not submitted timely for the third quarter of 2021 and fourth quarter of 2021, the annual budget was not submitted timely, and the first quarter of 2022 financial statement was not submitted accurately. Cause: The submission of timely and complete reports was not met due to managements? oversight of the requirement to submit quarterly financials. Potential Effect: As a result, the Agency reserves the right to withdraw Agency funding. Recommendation: The Organization should review current processes and ensure the financial reports are reviewed for accuracy and submitted timely by someone who did not prepare the reports. Client Response: The Organization will modify the process to include review by another individual and monitor due dates to submit future reports accurately and on time.
View Audit 282473
Finding 316201 (2022-054)
Material Weakness 2022
State of Colorado
CO
Eligibility Questioned Costs Subrecipient Monitoring § 200.303
(A) The state implemented the first phase of the monitoring dashboard in June 2020 with Project 13889 that identifies members that are active with no SSN without exemptions. The second phase of the monitoring dashboard implementation was pushed back to July 2023 due to competing legislative mandates...
(A) The state implemented the first phase of the monitoring dashboard in June 2020 with Project 13889 that identifies members that are active with no SSN without exemptions. The second phase of the monitoring dashboard implementation was pushed back to July 2023 due to competing legislative mandates.
View Audit 282464
Finding 316200 (2022-053)
Significant Deficiency 2022
State of Colorado
CO
Eligibility Procurement, Suspension & Debarment Subrecipient Monitoring
(A) The Department completed the system enhancement, allowing on-going data feeds from DORA into the interChange. The enhancement included implementation of a front-end claim edit, to prevent claim payments to providers with an expired license. The edit will be functional once the impact to provider...
(A) The Department completed the system enhancement, allowing on-going data feeds from DORA into the interChange. The enhancement included implementation of a front-end claim edit, to prevent claim payments to providers with an expired license. The edit will be functional once the impact to providers has been determined. The project was completed mid July 2022 with courtesy notices to our provider network, to update license information as applicable. Policies and procedures were updated to address this finding on May 17, 2022. The policy and procedure is effective July 1, 2022. (B) The Department has updated its policies and procedure for reviewing license actions, effective July 1, 2022. (C) Licensure continues to be a quality monitoring criterion for the Department and the Fiscal Agent. The Department completed the system enhancement, allowing on-going data feeds from DORA into the interChange. The enhancement included implementation of a front-end claim edit, to prevent claim payments to providers with an expired license. The edit will be functional once the impact to providers has been determined. The project was completed mid July 2022 with courtesy notices to our provider network, to update license information as applicable.
View Audit 282464
Finding 316196 (2022-055)
Material Weakness 2022
State of Colorado
CO
Eligibility Questioned Costs Procurement, Suspension & Debarment § 200.303
(A) The Department continues to work with the Fiscal Agent to ensure that the required database matches occur and the interChange properly displays the results of Social Security Number and Federal Employer Identification Number verifications for all providers. The project was completed mid July 202...
(A) The Department continues to work with the Fiscal Agent to ensure that the required database matches occur and the interChange properly displays the results of Social Security Number and Federal Employer Identification Number verifications for all providers. The project was completed mid July 2022.
View Audit 282464
Finding 316195 (2022-047)
Material Weakness 2022
State of Colorado
CO
Allowable Costs / Cost Principles Internal Control / Segregation of Duties Questioned Costs § 200.303 § 200.516 § 200.84
(B) The Department will review and revise, as necessary, its taxi claim billing requirements and rates to ensure that they are consistent. In addition, the Department will devise controls to ensure that taxi claims are paid in accordance with established requirements and rates and explore controls t...
(B) The Department will review and revise, as necessary, its taxi claim billing requirements and rates to ensure that they are consistent. In addition, the Department will devise controls to ensure that taxi claims are paid in accordance with established requirements and rates and explore controls to ensure that only permitted providers bill as a taxi. The Department is working on reductions in the max fee and unit limits for taxi claim billing codes, which it will have completed by the end of October 2021. In addition, the Department is considering systematically pricing the code at each taxi provider?s specific Public Utilities Commission (PUC) rate. This change, if pursued, will require a system change request, which will take a year or more, which is why the Department has selected an implementation date of December 2022. If this proves infeasible, alternate controls will be implemented. HCPF has met with DORA PUC. The Department is trying to establish a process to decide if the PUC taxi rate still applies or an internal rate can be created. Because of these discussions and needed system changes the implementation date has been moved to December 2023. (D) The Department intends to define in rule the types of documentation that NEMT providers must keep on hand and make clear that they must furnish records to the Department upon request. The July 2022 date will allow for the completion of formal rulemaking. The Department further intends to develop and implement a process to perform regular risk-based provider file reviews with a focus on noncompliant providers. These reviews will ensure, at a minimum, that the providers? paid claims are supported with appropriate documentation and represent the least costly option appropriate to meet each recipient?s needs. The Department met with the RAC team on February 22, 2023 to come up with a process to perform small audits for claims from providers that are outside the Intelliride service area. New systems will be implemented which has pushed the anticipated completion date to December 2023. (E) The Department will amend its contract with its NEMT broker by adding a mandatory annual audit so that it can reconcile trip scheduling data with paid claims data. This will help ensure that the Department pays accurately, pays for NEMT services, and pays for the least costly transportation option appropriate for each recipient. The Department chose July 2022 to add the audit through its annual contract amendment and renewal processes. The contract amendment was completed and signed June 30, 2022 that included a clause for an annual audit of claims. (F) The Department will develop a data review process to reconcile interChange data on NEMT trip claims to interChange data on Medicaid medical claims. This process will entail periodic reviews of NEMT claims to see if members have corresponding medical claims on those dates. If they do not, the Department will follow up with the appropriate NEMT provider to investigate. The July 2022 implementation date reflects the potential need for system changes. This is implemented, the Department has been pulling claims data and where corresponding medical claims are not found HCPF is investigating on a case by case basis to find the cause. (G) Department staff will work with the Department?s Program Integrity (PI) staff on processes to investigate and recover, as appropriate, the overpayments and inappropriate payments that the audit identified as known or likely questioned costs, and repay the federal portion, as appropriate. The December 2022 implementation date reflects the time needed to investigate and when appropriate, recover any overpayments. This has been implemented and the federal portion has been returned to CMS. (H) The Department will develop a process to track staff time and productivity to ensure that it has sufficient staff assigned to oversee and administer NEMT. This process will include documenting time spent each week on various tasks to get a sense of where help is needed, and which tasks take up the most staff resources. Based on its findings, the Department will explore staffing options, as needed. The Department selected the July 2022 implementation date to allow for data collection through the end of State Fiscal Year 2021-22. This has been implemented. New NEMT staff was hired November 1, 2022 to act as the liaison to the counties and clients in the 55 counties outside of the Intelliride service area.
View Audit 282464
Finding 316191 (2022-043)
Material Weakness 2022
State of Colorado
CO
Eligibility Questioned Costs Procurement, Suspension & Debarment § 200.303
(A) The Department and CBMS teams have strengthened their internal controls to ensure payments are only made to providers for eligible members. The Department and CBMS teams will update all member records identified on the Monthly Reconciliation report once the Public Health Emergency ends. TRAILS ...
(A) The Department and CBMS teams have strengthened their internal controls to ensure payments are only made to providers for eligible members. The Department and CBMS teams will update all member records identified on the Monthly Reconciliation report once the Public Health Emergency ends. TRAILS team has provided additional training to the Case Managers to prevent data integrity issues being submitted to CBMS and interChange; however, the TRAILS team does not plan to update the system's internal controls until funding is available. (B) The Department agrees to review the monthly eligibility reconciliation report and is looking forward to resolving the member records once the Public Health Emergency ends to fully resolve the audit finding.
View Audit 282464
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