Corrective Action Plans

Finding 449988 (2022-002)

Significant Deficiency 2022

Mayo Clinic

MN

Questioned Costs Procurement, Suspension & Debarment

Finding 2022-002Federal Program InformationFederal Agency: U.S. Department of Health and Human Services Federal Cluster: Research and Development (R&D)Pass-Through Entities: University of Iowa (93.397) and NYU Grossman School of Medicine (93.838)Assistance Listing Nos.: 93.310, 93.394, 93.397 and 93...

Finding 2022-002Federal Program InformationFederal Agency: U.S. Department of Health and Human Services Federal Cluster: Research and Development (R&D)Pass-Through Entities: University of Iowa (93.397) and NYU Grossman School of Medicine (93.838)Assistance Listing Nos.: 93.310, 93.394, 93.397 and 93.838Award Numbers: OD23121, CA212162, CA97274 and HL16847Award Periods: VariousCorrective Action PlannedResearchers and/or their delegates will collaborate timely with appropriate Supply Chain Management team to execute their known procurements and to ensure federal funds documentation is completed. When required for known procurements in excess of $250k, researchers and/or their delegates will collaborate timely with Mayo Clinic Supply Chain Contracting team to complete request for proposal (RFP). As of June 2023, an additional compensating control was added to verify RFP documentation meets documentation retention requirements.Persons Responsible for Corrective ActionBruce Mairose, SCM Division Chair, Sourcing/Network ManagementTarget Completion DateJune 30, 2023

View Audit 313337 Questioned Costs: $1

Finding 449792 (2022-019)

Material Weakness 2022

State of Utah

UT

Questioned Costs Eligibility Subrecipient Monitoring

Missing Documentation for Emergency Rental Assistance PaymentsState Agency: Department of Workforce ServicesFederal Program: Emergency Rental AssistanceA new process with updated procedures was implemented in March of 2022. This included adding two additional quality control analysts. We anticipat...

Missing Documentation for Emergency Rental Assistance PaymentsState Agency: Department of Workforce ServicesFederal Program: Emergency Rental AssistanceA new process with updated procedures was implemented in March of 2022. This included adding two additional quality control analysts. We anticipate the program ending spring of 2023 based on remaining funds and current spend rate. For the next 4-6 months, monthly quality control reviews and training will occur with supervisors and staff.Contact Person: Lyle Ward, ERA Program ManagerAnticipated Correction Date: November 30, 2022

View Audit 313334 Questioned Costs: $1

Finding 449776 (2022-023)

Significant Deficiency 2022

State of Utah

UT

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Improper Spending and Monitoring of Coronavirus Relief Fund ActivityState Agency: Governor?s Office of Planning and BudgetFederal Program: Coronavirus Relief FundGOPB will formally document eligibility for Thrive 125 grants and the state?s COVID-19 response dashboard to prepare the state for futur...

Improper Spending and Monitoring of Coronavirus Relief Fund ActivityState Agency: Governor?s Office of Planning and BudgetFederal Program: Coronavirus Relief FundGOPB will formally document eligibility for Thrive 125 grants and the state?s COVID-19 response dashboard to prepare the state for future reviews by the Department of the Treasury. While closing out the CARES Act CRF grant, GOPB will review expenses allocated for liability insurance to determine if any additional costs should be adjusted to not be charged to the CRF or document if they are appropriately charged as direct costs.Contact Person: Duncan Evans, Senior Managing Director of Budget and Operations, 801-538-1592Anticipated Correction Date: April 10, 2023

View Audit 313334 Questioned Costs: $1

Finding 449774 (2022-022)

Significant Deficiency 2022

State of Utah

UT

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.327

Suspension and Debarment Not Verified Prior to Awarding ContractsState Agency: Governor?s Office of Planning and BudgetFederal Program: Coronavirus State and Local Fiscal Recovery FundsGOPB will review its September 2022 guidance on requirements for SLFRF agreements and reissue the document to rem...

Suspension and Debarment Not Verified Prior to Awarding ContractsState Agency: Governor?s Office of Planning and BudgetFederal Program: Coronavirus State and Local Fiscal Recovery FundsGOPB will review its September 2022 guidance on requirements for SLFRF agreements and reissue the document to remind agencies of the need to perform timely suspension and debarment checks. GOPB will also provide training to agencies and remind them to include a suspension and debarment clause in contract agreements. GOPB will update the reference guide for agencies with standardized language about suspension and debarment checks to be used in new agreements. GOPB will include this review in its regular monitoring activities and sample contract agreements to verify inclusion of the appropriate contractual provisions.Contact Person: Darcy Jaimez, Fiscal Grant Manager, 385-377-3373Anticipated Correction Date: April 30, 2023

View Audit 313334 Questioned Costs: $1

Finding 449773 (2022-021)

Significant Deficiency 2022

State of Utah

UT

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties

Improper Controls and Monitoring of State and Local Fiscal Recovery Funds ActivityState Agency: Governor?s Office of Planning and BudgetFederal Program: Coronavirus State and Local Fiscal Recovery FundsGOPB will work with all agencies managing SLFRF projects to verify that adequate internal contro...

Improper Controls and Monitoring of State and Local Fiscal Recovery Funds ActivityState Agency: Governor?s Office of Planning and BudgetFederal Program: Coronavirus State and Local Fiscal Recovery FundsGOPB will work with all agencies managing SLFRF projects to verify that adequate internal controls have been established to reduce the risk of errors and noncompliance. GOPB will provide a reference guide to agencies to help them develop and implement proper controls over allowable activities and costs. GOPB will update its policies and procedures to sample agency compliance, with a greater focus on agencies that have less experience administering federal funds.To correct the $15.00 of questioned costs made by the courts, GOPB will work with the courts to charge the questoned amount to a different funding source.Contact Person: Duncan Evans, Senior Managing Director of Budget and Operations,801-538-1592Anticipated Correction Date: April 30, 2023

View Audit 313334 Questioned Costs: $1

Finding 449769 (2022-016)

Significant Deficiency 2022

State of Utah

UT

Questioned Costs Subrecipient Monitoring Reporting § 200.303

FFATA Award Information Not Submitted for UOVC?s 2020 Award & Inaccurate Information Submitted for 5 of UOVC?s 2019 SubawardsState Agency: Commission on Criminal and Juvenile JusticeFederal Program: Crime Victim AssistanceUOVC will follow the Audit recommendation by entering the final award informat...

FFATA Award Information Not Submitted for UOVC?s 2020 Award & Inaccurate Information Submitted for 5 of UOVC?s 2019 SubawardsState Agency: Commission on Criminal and Juvenile JusticeFederal Program: Crime Victim AssistanceUOVC will follow the Audit recommendation by entering the final award information into the FSRS website rather than preliminary information. This will be done timely and according to policy. The UOVC Grant Management Team, in alliance with the Federal Fund Financial Manager, will meet to discuss and determine the best way to implement a review process to ensure compliance and accuracy in correcting this audit finding.Contact Person: Tallie Viteri, UOVC Asst. Director, Assistance Grant Program Mgr., 801-300-6605Gary Scheller, UOVC Director, 801-227-9375Mark Peterson, UOVC Financial Manager II, 801-793-8264Anticipated Correction Date: June 30, 2023 (New Grant awards will take place July 2023)

View Audit 313334 Questioned Costs: $1

Finding 449768 (2022-004)

Material Weakness 2022

State of Utah

UT

Questioned Costs Subrecipient Monitoring Equipment & Real Property Management § 200.303

Food Commodity Shipments, Disbursements, and Inventory Not TrackedState Agency: Utah State Board of EducationFederal Program: Emergency Food Assistance Program (Food Commodities)?State agencies, sub distributing agencies, and eligible recipient agencies must maintain records to document the receipt...

Food Commodity Shipments, Disbursements, and Inventory Not TrackedState Agency: Utah State Board of EducationFederal Program: Emergency Food Assistance Program (Food Commodities)?State agencies, sub distributing agencies, and eligible recipient agencies must maintain records to document the receipt, disposal, and inventory of commodities received under this part that they, in turn, distribute to eligible recipient agencies. (7 CFR 251.10(a)(1)? Therefore, as the distributing agency, the USBE Child Nutrition Program (CNP), shares responsibility for accountability of commodities the state of Utah receives as part of The Emergency Food Assistance Program (TEFAP) with the Utah Food Bank (UFB)?the sub distributing agency. The collaborative relationship between CNP and UFB, and maintenance of sufficient records, resulted in resolution of the initial differences calculated as part of the audit.As required by 7 CFR 251.10(e), CNP monitors the operation of TEFAP, including performance of required annual reviews of recipients, and of physical inventory. In addition to the monitoring procedures currently in place, CNP will enact a policy to reconcile book inventories of donated foods at least annually as required by 7 CFR 250.12(b).Contact Person(s):Michelle Martin, USBE Program Development Coordinator, 801-538-7687Melissa Cowder, USBE Food Distribution Specialist, 801-538-7697Anticipated Correction Date: USBE will develop a policy by September 30, 2022, that will outline procedures to reconcile book inventories of donated foods annually. Reconciliation will be based on the federal fiscal year.

View Audit 313334 Questioned Costs: $1

Finding 449756 (2022-001)

Material Weakness 2022

City of Long Beach

CA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking

Program: HOME Investment Partnership Program (HOME)Finding: 2022-001Contact Person: April ApodacaFinancial Services OfficerDevelopment Services DepartmentPhone: (562) 570-6611Email: april.apodaca@longbeach.govPlanned Actions:The Development Services Department (Department) will securely file all...

Program: HOME Investment Partnership Program (HOME)Finding: 2022-001Contact Person: April ApodacaFinancial Services OfficerDevelopment Services DepartmentPhone: (562) 570-6611Email: april.apodaca@longbeach.govPlanned Actions:The Development Services Department (Department) will securely file all HOME monitoring documents and ensure it is accessible to multiple staff. As of June 27, 2023, thirteen of the fifteen non-compliant samples have been secured and communication has been sent to retrieve the remaining two from the developers. The final two samples are due on July 21, 2023, and we fully expect to show compliance documentation by that date. If the documents are not received by the due date, the Department will continue to communicate with the developers by telephone, mail, and email to provide second and third notices. If no response is submitted by the third notice (August 7, 2023) the Department will escalate the matter to the City Attorney?s Office to formally begin taking action for non-compliance

View Audit 313326 Questioned Costs: $1

Finding 449497 (2022-008)

Significant Deficiency 2022

Baltimore County, Maryland

MD

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

2022-008 COVID-19-Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimburse...

2022-008 COVID-19-Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Office of Budget and Finance in conjunction with the Executive?s office of Government Reform and Strategic Initiative will review all employee files to ensure that an effort attestation exists, or that the employee is properly trained on the importance of effort reporting through a timesheet as a chargeback mechanism.Name(s) of the contact person(s) responsible for corrective action: Elisabeth Sachs and Rebecca LangPlanned completion date for corrective action plan: 7/1/2023

View Audit 313273 Questioned Costs: $1

Finding 449495 (2022-007)

Significant Deficiency 2022

Baltimore County, Maryland

MD

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

2022-007 COVID-19-Emergency Rental Assistance ? Assistance Listing No. 21.023Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can sub...

2022-007 COVID-19-Emergency Rental Assistance ? Assistance Listing No. 21.023Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Baltimore County DHCD follows Baltimore County?s general payroll policies and procedures. DHCD allocates time and attendance based on a preset budgeted formula and monitors the staff?s time and attendance through biweekly timesheet prepared by the staff members and approved by unit managers and the review of payroll register. Baltimore is County is discontinuing the use of current payroll system CGI Advantage and will be migrating to Workday system which has more robust features and capabilities to capture time and attendance.Name(s) of the contact person(s) responsible for corrective action: Amir AssadiPlanned completion date for corrective action plan: 7/1/2023

View Audit 313273 Questioned Costs: $1

Finding 449482 (2022-006)

Significant Deficiency 2022

Baltimore County, Maryland

MD

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

2022-006 CDBG Entitlement Grant Cluster ? Assistance Listing No. 14.218Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substanti...

2022-006 CDBG Entitlement Grant Cluster ? Assistance Listing No. 14.218Recommendation: The County should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The County should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: DHCD follows Baltimore County?s general payroll policies and procedures. DHCD allocates time and attendance based on a preset budgeted formula and monitors the staff?s time and attendance through biweekly timesheet prepared by the staff members and approved by unit managers and the review of payroll register. Baltimore County is discontinuing the use of current payroll system CGI Advantage and will be migrating to Workday system which has more robust features and capabilities to capture time and attendance.Name(s) of the contact person(s) responsible for corrective action: Amir AssadiPlanned completion date for corrective action plan: 7/1/2023

View Audit 313273 Questioned Costs: $1

Finding 447023 (2022-005)

Significant Deficiency 2022

East Alton Wood River Community High School No. 14

IL

Questioned Costs Cash Management Reporting

Education Stabilization Fund: 2022-005 Condition: We noted during ESSER III testing the District was reimbursed for duplicated expenditures reported on the 3rd and 4th quarter reports. ...

Education Stabilization Fund: 2022-005 Condition: We noted during ESSER III testing the District was reimbursed for duplicated expenditures reported on the 3rd and 4th quarter reports. Recommendation: We recommend the District compare and reconcile the expenditure reports filled with the general ledger before submitting.

View Audit 312909 Questioned Costs: $1

Finding 443056 (2022-002)

Material Weakness 2022

Bergman School District

AR

Questioned Costs Allowable Costs / Cost Principles Equipment & Real Property Management

Corrective Action Plan: ? 2022-002. The District will implement procedures to read each Fund stipulations to ensure our Staff follows the requirements set within the Fund Documentation. From this day forward, we will certify that each guideline is followed and completed exactly as required before...

Corrective Action Plan: ? 2022-002. The District will implement procedures to read each Fund stipulations to ensure our Staff follows the requirements set within the Fund Documentation. From this day forward, we will certify that each guideline is followed and completed exactly as required before requesting reimbursement

View Audit 312731 Questioned Costs: $1

Finding 443055 (2022-001)

Material Weakness 2022

Bergman School District

AR

Questioned Costs Special Tests & Provisions Cash Management

Corrective Action Plan: ? 2022-001. The District will implement procedures to read each Fund stipulations to ensure our Staff follows the requirements set within the Fund Documentation. From this day forward, we will certify that each guideline is followed and completed exactly as required before...

Corrective Action Plan: ? 2022-001. The District will implement procedures to read each Fund stipulations to ensure our Staff follows the requirements set within the Fund Documentation. From this day forward, we will certify that each guideline is followed and completed exactly as required before requesting reimbursement.

View Audit 312731 Questioned Costs: $1

Finding 442921 (2022-001)

Significant Deficiency 2022

San Antonio Early Childhood Education Municipal Development Corporation

TX

Questioned Costs Eligibility Significant Deficiency

GSA_MIGRATION

View Audit 312523 Questioned Costs: $1

Finding 442919 (2022-009)

Material Weakness 2022

Circle of Nations School INC

ND

Questioned Costs Allowable Costs / Cost Principles § 200.430

2022-009 A/B. Allowable Costs and Cost Principles/Activities Allowed or UnallowedEducation Stabilization Fund CFDA #84.425Material Weakness in Internal Control over Compliance and Immaterial Instance of NoncomplianceFinding Summary: During the course of the engagement, Eide Bailly noted instances o...

2022-009 A/B. Allowable Costs and Cost Principles/Activities Allowed or UnallowedEducation Stabilization Fund CFDA #84.425Material Weakness in Internal Control over Compliance and Immaterial Instance of NoncomplianceFinding Summary: During the course of the engagement, Eide Bailly noted instances of expendituresthat were not COVID related and therefore not allowable under the terms of the grant.Corrective Action Plan: The School will review internal controls surrounding allowable costs andactivities to ensure they are adequate to identify unallowable expenditures.Anticipated Completion Date: June 30, 2023

View Audit 312521 Questioned Costs: $1

Finding 442913 (2022-002)

Significant Deficiency 2022

American Society of Nephrology, Inc.

DC

Questioned Costs

See Corrective Action Plan for chart/table

View Audit 312520 Questioned Costs: $1

Finding 442908 (2022-002)

Material Weakness 2022

Beacon Health System, Inc.

IN

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding 2022-002 ? EligibilityA qualified opinion was issued for Assistance Listing 93.011 as the auditors noted that the Corporation expended the full balance of gift cards purchased during the fiscal year 2022 rather than the amount that was distributed to eligible participants. Participants are e...

Finding 2022-002 ? EligibilityA qualified opinion was issued for Assistance Listing 93.011 as the auditors noted that the Corporation expended the full balance of gift cards purchased during the fiscal year 2022 rather than the amount that was distributed to eligible participants. Participants are eligible to participate in the program and receive a gift card if they received a COVID-19 vaccine.Compliance with the eligibility requirements is the responsibility of Kimberly Green Reeves, Executive Director of Community Impact and the grant coordinator. As grants G32HS42634C6 and U3SHS45317C6 ended May 31, 2023, and July 31, 2023, respectively, no further correction action will be taken. However, effective August 15, 2023, if future programs are awarded Beacon Health System (the Corporation) will track the total gift cards purchased as a prepaid expense and expense the gift cards at the time they are distributed to eligible participants. The Corporation Finance will work with the grant administrator to obtain the total amount of gift cards purchased and have that recorded as a prepaid asset. Each month the Corporation Finance will work with the grant administrator to obtain a schedule showing the total amount of gift cards distributed, which will be used to record the appropriate expense each month.

View Audit 312518 Questioned Costs: $1

Finding 442905 (2022-001)

Significant Deficiency 2022

Community Legal Aid Society, Inc.

DE

Questioned Costs

GSA_MIGRATION

View Audit 312517 Questioned Costs: $1

Finding 442867 (2022-005)

Significant Deficiency 2022

United Way of Greater Cleveland

OH

Questioned Costs Allowable Costs / Cost Principles Cash Management

Vendor invoice processing is performed by the Accounting Coordinator who inputs pertinent invoice data into the accounting software for payment. The UWGC Senior Director of Finance or in her absence the UWGC Chief Financial Officer will provide a secondary level of review to verify invoices are app...

Vendor invoice processing is performed by the Accounting Coordinator who inputs pertinent invoice data into the accounting software for payment. The UWGC Senior Director of Finance or in her absence the UWGC Chief Financial Officer will provide a secondary level of review to verify invoices are applied to the correct period for the correct amount after the Accounting Coordinator inputs the data to ensure that Federal funds are reimbursed accurately and in the appropriate period

View Audit 312506 Questioned Costs: $1

Finding 442866 (2022-004)

Significant Deficiency 2022

United Way of Greater Cleveland

OH

Questioned Costs Allowable Costs / Cost Principles Cash Management

Vendor invoice processing is performed by the Accounting Coordinator who inputs pertinent invoice data into the accounting software for payment. The UWGC Senior Director of Finance or in her absence the UWGC Chief Financial Officer will provide a secondary level of review to verify invoices are app...

Vendor invoice processing is performed by the Accounting Coordinator who inputs pertinent invoice data into the accounting software for payment. The UWGC Senior Director of Finance or in her absence the UWGC Chief Financial Officer will provide a secondary level of review to verify invoices are applied to the correct period for the correct amount after the Accounting Coordinator inputs the data to ensure that Federal funds are reimbursed accurately and in the appropriate period.

View Audit 312506 Questioned Costs: $1

Finding 442865 (2022-003)

Significant Deficiency 2022

United Way of Greater Cleveland

OH

Questioned Costs Cash Management Reporting

To ensure the charging of indirect costs to federal programs are at the elected de minimis amount of 10% and in the correct fiscal period, the UWGC Chief Financial Officer or the UWGC Senior Director of Finance will perform a secondary review of the calculation prepared by the Finance Manager. The ...

To ensure the charging of indirect costs to federal programs are at the elected de minimis amount of 10% and in the correct fiscal period, the UWGC Chief Financial Officer or the UWGC Senior Director of Finance will perform a secondary review of the calculation prepared by the Finance Manager. The review will take place prior to the final completion of the report to ensure that Federal funds are reported in the correct time period as well.

View Audit 312506 Questioned Costs: $1

Finding 442859 (2022-002)

Significant Deficiency 2022

The Cleveland Play House

OH

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.302 § 200.403

Finding Number: 2022-002Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 fiscal yearwhich resulted in several vacancies, including the Director of Finance position, for a significant portion ofthe year. As a result, many of the reports that are standard practice...

Finding Number: 2022-002Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 fiscal yearwhich resulted in several vacancies, including the Director of Finance position, for a significant portion ofthe year. As a result, many of the reports that are standard practice in our organization were not beingcompleted. In addition, the filing of certain documentation to support expenditures was not being doneconsistently. The Director of Finance position was filled in the fall of 2022. As a result, documentationof allowable expenditures is being addressed for the fiscal 2023 audit.In addition to turnover, the organization transitioned to a new general ledger system with a new chartof accounts in fiscal year 2022. As a result of this transition and the vacancies mentioned above, certaindata pertaining to the federal programs was not being captured. Management has informed all staff ofthe requirements to track federal programs within the general ledger accounts.Anticipated Completion Date: June 30, 2023Responsible Contact Person: Erica Tkachyk, Director of Finance

View Audit 312500 Questioned Costs: $1

Finding 442852 (2022-004)

Material Weakness 2022

South Montgomery Community School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

FINDING 2022-004Contact Person Responsible for Corrective Action: Kristin CharlesContact Phone Number: 765-866-0203Views of the Responsible Official: The School Corporation is in agreement with the Finding.Description of Corrective Action Plan: This should not be an issue moving forward as now writ...

FINDING 2022-004Contact Person Responsible for Corrective Action: Kristin CharlesContact Phone Number: 765-866-0203Views of the Responsible Official: The School Corporation is in agreement with the Finding.Description of Corrective Action Plan: This should not be an issue moving forward as now write our grant to be used for our Co-Op Bill and do not pay salaries directly. In the future if we plan to pay with Federal Funding, we will require time and effort logs.Anticipated Completion Date: 4/1/2023

View Audit 312499 Questioned Costs: $1

Finding 433354 (2022-024)

Significant Deficiency 2022

State of Louisiana

LA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Dear Mr. Waguespack:The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor (LLA) dated February 27, 2023, regarding a reportable audit finding related to Inadequate Controls Over and Noncompliance with National Correct Coding Initiative...

Dear Mr. Waguespack:The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor (LLA) dated February 27, 2023, regarding a reportable audit finding related to Inadequate Controls Over and Noncompliance with National Correct Coding Initiative Requirements. LDH appreciates the opportunity to provide this response to your office?s findings.Finding: Inadequate Controls Over and Noncompliance with National Correct Coding Initiative RequirementsRecommendation: Management should ensure all required NCCI edits are properly applied to FFS claims.LDH Response: LDH partially concurs with this finding.LDH disagrees with the premise that a data pull compared with NCCI quarterly files represents an accurate and final adjudication of claims in a claims processing system. LDH disagrees that such a data pull could be used as the basis of a determination of inappropriate adjudication.The data pull does not consider the final adjudication of claims. Our review identified examples outside of the processing dates utilized by LLA where the NCCI edits applied and claims denied correctly in subsequent processing dates. A single data pull by the LLA may not dependably reflect the accurate final outcome of the applied edits.Fee-for-service (FFS) NCCI editing occurs within the integrated ClaimsXten Portfolio (CXT P) (formerly Change Healthcare) `ClaimCheck? product. System constraints of both the fiscal intermediary and ClaimCheck preclude applying Medically Unlikely Edits (MUE) to outpatient hospital and durable medical equipment (DME) claims.The LLA has been previously informed that Medicaid FFS is working with the fiscal intermediary (FI) and CXT P to implement and integrate the newest version of the clinical editing product, `ClaimsXten? which houses all of the Medicaid NCCI methodologies. This product replaces ClaimCheck and will not have the same constraints in applying NCCI edits. LDH is currently in the process of converting to `ClaimsXten?. The estimated completion date is March 24, 2023.The LLA is also aware that FFS Medicaid applies the Medicaid NCCI `procedure to procedure? (PTP) edits for practitioner, outpatient hospital (OPH), and durable medical equipment (DME) as well as the medically unlikely edits for practitioners. DME and OPH MUE are not currently applied due to previously mentioned system constraints. CMS is aware of the methodologies applied to Louisiana Medicaid FFS claims.LDH concurs that not all of the Medicaid NCCI edit methodologies are in place due to the limitations of the fiscal intermediary and the current integrated editing product.Corrective Action Plan:As ongoing corrective action, LDH is working with both the FI and CXT P to integrate and implement the updated clinical editing product `ClaimsXten? that will allow full compliance with all of the NCCI edit methodologies.LDH will continue to perform biweekly reviews that include examples of FFS NCCI edits to assure correct functionality. Once `ClaimsXten? is implemented, all methodologies will be able to be monitored. The estimated completion date is March 24, 2023.You may contact Tara A. Leblanc, Medicaid Director at (225) 219-7810 or via e-mail at Tara.LeBlanc@la.gov or Brandon Bueche, Medicaid Section Chief at (225) 384-0460 or via email at Brandon.Bueche@la.gov with any questions about this matter.

View Audit 312391 Questioned Costs: $1

Corrective Action Plans

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