Corrective Action Plans

Finding 516750 (2023-003)

None 2023

CA

Subrecipient Monitoring Questioned Costs

Under the University’s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the fede...

Under the University’s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: Employee training and management; Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University’s Information Technology system, we noted through inquiry that a formal risk assessment of the University’s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Corrective Action Planned The organization has engaged an outside IT consultant to manage the organization’s IT needs moving forward. Responsible PersonnelDouglas Burnet Chief Financial OfficerPhone: 415-425-0666 Burnet@hnu.edu

View Audit 334723

Finding 516666 (2023-001)

Significant Deficiency 2023

Philip Health Services, Inc.

SD

Special Tests & Provisions Questioned Costs Subrecipient Monitoring

RE: Audit Finding Corrective Action Plan Philip Health Services recognizes the need for an account to be designated for the loan reserve of $210,564. We will designate a CD in the CDARS Accounts in the amount of $250,000 that is insured by FDIC with a term of 2 years. When this CD is renewed, ...

RE: Audit Finding Corrective Action Plan Philip Health Services recognizes the need for an account to be designated for the loan reserve of $210,564. We will designate a CD in the CDARS Accounts in the amount of $250,000 that is insured by FDIC with a term of 2 years. When this CD is renewed, it will continue to be reserved until the loan reaches an amount that will no longer require the designation. Respectfully, Maureen Cadwell Chief Executive Officer Philip Health Services, Inc.

View Audit 334657

Finding 516587 (2023-002)

Significant Deficiency 2023

Southwestern Wisconsin Community Action Program, Inc.

WI

Questioned Costs Reporting Significant Deficiency § 200.512

2023-002: Late Audit Submission Auditor's Recommendation: SWCAP should take steps to ensure that its financial records are available in a timely manner to allow the audit to begin sufficiently before the audit due date. SWCAP also should work with their auditing firm to agree upon information that w...

2023-002: Late Audit Submission Auditor's Recommendation: SWCAP should take steps to ensure that its financial records are available in a timely manner to allow the audit to begin sufficiently before the audit due date. SWCAP also should work with their auditing firm to agree upon information that will and will not be prepared by SWCAP so that a proper audit plan can be developed for timely completion. Corrective Action: SWCAP acknowledges the delay in completing the 2023 audit. The unforeseen staffing challenges by our auditing firm in conjunction with our internal turnover significantly impacted our timeline. SWCAP has identified and implemented changes with its personnel and hired an outsourced accounting firm. SWCAP has implemented proactive measures to streamline its audit preparation and submission processes to prevent similar delays in the future. These include enhancing internal review procedures, ensuring clear communication with auditors, and allocating sufficient resources for timely compliance with reporting requirements, federal regulations, and guidelines. Responsible for Corrective Action: Finance Team (Outsourced accounting firm, Operations Manager, Executive Director). Anticipated Completion Date: Completed as of December 2024.

View Audit 334558

Finding 516516 (2023-002)

None 2023

Camcare Health Corporation

NJ

Questioned Costs Special Tests & Provisions Cash Management

CAMcare has made significant changes to the patient payment collection process. Updates were made to the Patient Payments, Refusal to Pay, Waiver/Reduction of Charges Policy, Sliding Fee Scale Policy, and Patient Payments Policy, and a Patient Payments Policy was introduced. The new EMR system allow...

CAMcare has made significant changes to the patient payment collection process. Updates were made to the Patient Payments, Refusal to Pay, Waiver/Reduction of Charges Policy, Sliding Fee Scale Policy, and Patient Payments Policy, and a Patient Payments Policy was introduced. The new EMR system allows for individual Patient Service Representatives (front desk personnel) to monitor management's adherence to collection efforts.

View Audit 334424

Finding 516515 (2023-001)

Significant Deficiency 2023

Camcare Health Corporation

NJ

Questioned Costs Special Tests & Provisions HUD Housing Programs

CAMcare has made significant revisions to the financial screening department's leadership and workflows. We have since revised our Sliding Fee Scale Policy, the scale itself, and the SOPs for both Financial Screening of Uninsured and Underinsured Patients and Financial Assistance. All patient regist...

CAMcare has made significant revisions to the financial screening department's leadership and workflows. We have since revised our Sliding Fee Scale Policy, the scale itself, and the SOPs for both Financial Screening of Uninsured and Underinsured Patients and Financial Assistance. All patient registration areas have the latest board-approved sliding fee scale, and the changes were announced during a weekly staff huddle. All PSRs and Financial Screeners were made aware of the change. The new Manager of the financial screening department has provided the team with subject matter expertise, additional training, and increased accountability in work product. CAMcare also has a new EMR system, Epic, (December of 2023) where applications are housed and tracked, creating a single record for financial screening with patient changes being more streamlined. The latest sliding fee scales have been uploaded to the EMR. Patients with applications in progress can be edited as needed more efficiently.

View Audit 334424

Finding 516504 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of Fort Myers

FL

Questioned Costs Eligibility HUD Housing Programs

The following procedure is put in place to prevent the conditins found during a recent audit review of the LIPH and HCV files: All staff will read HUD requirements for reexamining income and family composition for families in the Public Housing and Housing Voucher Programs. Property managers will ...

The following procedure is put in place to prevent the conditins found during a recent audit review of the LIPH and HCV files: All staff will read HUD requirements for reexamining income and family composition for families in the Public Housing and Housing Voucher Programs. Property managers will be reuqiqred to complete training courses in 2024. Property clerks and leasing specialists will be required to complete Rent Calculation courses that coorelate to their program type. HACFM is actively working on creating operation procedures and process manuals. the Procedure manaul will include the following reuqirements: Annual recertificaton packets will be sent to the resident 120 days from the houshold's annual effective date. Submission of reuqired documentation from resident will be enforced according to the lease agreements. A certification review checklist to support staff in ensuring all documnetation is in the file and all requried signatures are present. The Checklist will ensure that the submitter is verifying the file, the property manager has certified the file prior to finalizing the review in the tenant software program and uploading the file to the records. The property manager is reuqired to conduct 5% audit of the files monthly and correct any deficiencies found. An audit checklist will be created to support this required task. The management analyst position is required to audit 5 random files from each site on a quarterly basis. Ans audit checklist will be createdto support this required task.

View Audit 334417

Finding 516482 (2023-001)

Material Weakness 2023

Wahkiakum County

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the County is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the County is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The County did not have adequate controls for ensuring compliance with federal requirements for allowable activities and costs. Name, address, and telephone of County contact person: Tammy Peterson, PO Box 85, 360-795-8005 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). A request was made to the payroll department for a report for the Sheriff’s office for the August payroll. I meant the July time issued on August 5th. The report I received was for August time with a September 5th pay date. This was a misunderstanding and not an intentional oversight. In the future, we will ensure that the report dates match the payroll we are requesting. Anticipated date to complete the corrective action: September 13, 2024

View Audit 334391 Questioned Costs: $1

Finding 516472 (2023-009)

Material Weakness 2023

Academy of America

MI

Questioned Costs Subrecipient Monitoring Material Weakness § 200.303

View of Responsible Officials and Corrective Action Plan – Management will monitor the review and approval procedures for reporting to ensure that reports are signed off to indicated and document that review and approval has been made.

View Audit 334382

Finding 516365 (2023-001)

Significant Deficiency 2023

Urban Community School

OH

Questioned Costs Internal Control / Segregation of Duties

Corrective Actions: We have re-assigned responsibility for submitting receipts for credit card charges to the Manager of the Food Service Program, who has been running our program for 18 years. We sent our policy on receipt requirements for all credit card receipts to all relevant staff. The CFO and...

Corrective Actions: We have re-assigned responsibility for submitting receipts for credit card charges to the Manager of the Food Service Program, who has been running our program for 18 years. We sent our policy on receipt requirements for all credit card receipts to all relevant staff. The CFO and Business Manager will both review the monthly credit card charges for appropriate supporting documentation for credit card charges.

View Audit 334301

Finding 516358 (2023-001)

None 2023

United Community Corporation

NJ

Questioned Costs Reporting

UCC to ensure timely filing of SF-SAC form for fiscal 2024

View Audit 334188

Finding 516326 (2023-003)

Significant Deficiency 2023

All Nations Health Center, Inc.

MT

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.303

The Business and Finance Department at ANHC has mandated, from all departments at ANHC, an approval form for all “Autopay” transactions to be signed by the ED immediately.

View Audit 334164

Finding 516325 (2023-002)

Material Weakness 2023

All Nations Health Center, Inc.

MT

Questioned Costs Subrecipient Monitoring Eligibility

All Nations Health Center has switched EHR systems that allows for intake coordinators to suspend/pause eligibility status until all proper documentation has been obtain from the client, scanned into the system, and filed appropriately.

View Audit 334164

Finding 516134 (2023-002)

Material Weakness 2023

Kalama School District

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kalama School District No. 402 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Fed...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kalama School District No. 402 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: James Capen Director of Business Services 360-673-5282 Corrective action the auditee plans to take in response to the finding: The Kalama School District has taken the following steps to ensure that we are currently in compliance, and will continue to stay in compliance, with the Davis-Bacon Act; 1. All new contractors and existing contractors covered by the Davis-Bacon Act will submit certification attesting to compliance of prevailing wage requirements. 2. District staff will review the State Labor and Industries prevailing wage and certification website on a weekly basis when work is performed or collect a certified payroll record from the contractor on a weekly basis. 3. All new staff that have purchasing or financial oversight will be trained on these procedures when hired and on an ongoing basis. Anticipated date to complete the corrective action: 7-26-24

View Audit 333974

Finding 516078 (2023-001)

Significant Deficiency 2023

Chesapeake Hospital Authority

VA

Questioned Costs Subrecipient Monitoring Reporting § 200.512

2023-001 – Reporting – Submission of the Data Collection Form Individuals Responsible for Corrective Action Plan: J. Neal Bolton, Director of Revenue Management & Budget Shemaine Rose, Controller Anticipated Completion Date: December 2024 Management acknowledges that the reporting package and dat...

2023-001 – Reporting – Submission of the Data Collection Form Individuals Responsible for Corrective Action Plan: J. Neal Bolton, Director of Revenue Management & Budget Shemaine Rose, Controller Anticipated Completion Date: December 2024 Management acknowledges that the reporting package and data collection form for the year ended June 30, 2023, was not filed with the Federal Audit Clearinghouse on or before the deadline of March 31, 2024. Management maintains that appropriate schedules and notes thereto were prepared accurately and timely, and that the delay was due primarily to the unique nature of Provider Relief Funds being reported, which resulted in evolving compliance requirements over the funding and reporting periods. Management will file the reporting package and data collection form immediately upon completion and will continue to monitor and adhere to future Federal compliance updates to prevent such delays in the future.

View Audit 333892

Finding 515976 (2023-005)

Significant Deficiency 2023

The National Judicial College

NV

Questioned Costs Reporting Internal Control / Segregation of Duties

Shifts in operational priorities during the Spring and Summer of 2024, led to resource conflicts that hindered the audit process during critical periods. These changes, driven by direction from the Board of Trustees created unforeseen challenges that affected the timely completion of certain audit-r...

Shifts in operational priorities during the Spring and Summer of 2024, led to resource conflicts that hindered the audit process during critical periods. These changes, driven by direction from the Board of Trustees created unforeseen challenges that affected the timely completion of certain audit-related tasks. The College is committed to accelerating the fieldwork of future audits to ensure it is better prepared to handle unscheduled resource demands that may lead to delays in the audit process. In addition, the College, the auditors and the Audit Chair will meet to establish a timeline and dates for the audit planning and preparation, completion of the audit field work and the submission of the audited report. Patrick Grimes is the individual responsible for oversight of this corrective action plan.

View Audit 333783

Finding 515975 (2023-004)

Significant Deficiency 2023

The National Judicial College

NV

Procurement, Suspension & Debarment Subrecipient Monitoring Questioned Costs § 200.213

Personnel changes, including the introduction and the departure of a new Director of Grants, led to a vulnerability in the debarment step of the processes for contracting with consultants under federal grants in isolated circumstances. In this particular instance, a long-term consultant entered into...

Personnel changes, including the introduction and the departure of a new Director of Grants, led to a vulnerability in the debarment step of the processes for contracting with consultants under federal grants in isolated circumstances. In this particular instance, a long-term consultant entered into a new contract with the College while an existing contract for related activities was outstanding. The College will formalize a policy requiring that all new contracts under federal grants, even for previously established contractors, be reviewed and processed according to the updated procedures. Patrick Grimes is the individual responsible for oversight of this corrective action plan.

View Audit 333783

Finding 515829 (2023-005)

Significant Deficiency 2023

Isanti County

MN

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

Federal Agency: US Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2205MN5ADM, 2023 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: • Significant Deficiency in ...

Federal Agency: US Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2205MN5ADM, 2023 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Recommendation: We recommend the County puts in place the proper procedures to ensure it has proper controls in place to properly document support for all payroll expenditures coded to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review its procedures and controls over payroll to ensure supporting documentation is retained, reviewed and approved for all employees. Name(s) of the contact person(s) responsible for corrective action: Angie Larson, Auditor-Treasurer / Chief Financial Officer Planned completion date for corrective action plan: December, 31 2024

View Audit 333691 Questioned Costs: $1

Finding 515609 (2023-001)

Significant Deficiency 2023

Kansas Association of Conservation Districts

KS

Questioned Costs Procurement, Suspension & Debarment Significant Deficiency § 200.319

Management agrees with the findings and recommendation. The District will update its policies and procedures to ensure they meet the Uniform Guidance Requirements. .

View Audit 333385

Finding 515558 (2023-009)

Significant Deficiency 2023

Unity Health Care, Inc.

MD

Allowable Costs / Cost Principles Questioned Costs § 200.303

Management Response #2023-009: Due to the staff shortages and turnover the Corporation did not have adequate personnel or infrastructure in place to monitor costs in order to calculate and determine Corrective Action Plan: The Finance Team will develop overall operational costs reports to calculate...

Management Response #2023-009: Due to the staff shortages and turnover the Corporation did not have adequate personnel or infrastructure in place to monitor costs in order to calculate and determine Corrective Action Plan: The Finance Team will develop overall operational costs reports to calculate and support a new rate. The proposed rate will be submitted for approval. This will allow us to ensure the calculation for indirect costs and documentation supporting the indirect cost pool conform to the current regulations. Responsible Party: Tamara Barnes, CFO

View Audit 333283

Finding 515549 (2023-006)

Material Weakness 2023

Unity Health Care, Inc.

MD

Allowable Costs / Cost Principles Questioned Costs Matching / Level of Effort / Earmarking § 200.431

Management Response #2023-006: Due to the financial system and time keeping infrastructure, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Also, the current fringe cost rate and allocations is based on historical assumptions. Corrective Action Plan: • The...

Management Response #2023-006: Due to the financial system and time keeping infrastructure, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Also, the current fringe cost rate and allocations is based on historical assumptions. Corrective Action Plan: • The finance team will work to ensure fringe costs are entered into the financial system based on actual costs paid by the Corporation for each employee. • The grants finance department will also create actual to budget reports in accordance with HRSA guidelines for fringe costs. • The Finance Team will develop fringe costs reports to calculate, monitor and support the current rate. This will allow us to ensure the fringe cost allocation conform to the current regulations. Responsible Party: Tamara Barnes, CFO

View Audit 333283

Finding 515487 (2023-120)

Significant Deficiency 2023

State of Arizona

AZ

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs

Assistance listing number and program name: 93.658 Foster Care—Title IV-E 93.658 COVID-19 - Foster Care—Title IV-E Agency: Arizona Department of Child Safety (DCS) Name of contact person and title: Emilio Gonzales, DCS Audit Administrator Anticipated completion date: Fiscal Year 2025 Agency’s Respo...

Assistance listing number and program name: 93.658 Foster Care—Title IV-E 93.658 COVID-19 - Foster Care—Title IV-E Agency: Arizona Department of Child Safety (DCS) Name of contact person and title: Emilio Gonzales, DCS Audit Administrator Anticipated completion date: Fiscal Year 2025 Agency’s Response: Concur The Department will comply with the Federal Funding Accountability and Transparency Act (FFATA) and Federal Uniform Guidance regulations in accordance with the Department’s Grant policies and procedures. As of November 2024, the Department worked with the federal agency to resolve the inability to submit outstanding subaward information prior to January 2024. The FFATA reporting was completed for fiscal years 2024, 2023, 2022 and 2021. The Department will also continue to follow its policies and procedures for reporting subaward actions, as required.

View Audit 333243

Finding 515471 (2023-133)

Significant Deficiency 2023

State of Arizona

AZ

Internal Control / Segregation of Duties Questioned Costs Eligibility

Assistance listing number and program name: 93.778 Medicaid Assistance Program (part of the Medicaid Cluster 93.778 COVID-19 Medicaid Assistance Program Agency: Arizona Health Care Cost Containment System (AHCCCS) Name of contact person and title: Jeff Tegen, Assistant Director, AHCCCS Division of B...

Assistance listing number and program name: 93.778 Medicaid Assistance Program (part of the Medicaid Cluster 93.778 COVID-19 Medicaid Assistance Program Agency: Arizona Health Care Cost Containment System (AHCCCS) Name of contact person and title: Jeff Tegen, Assistant Director, AHCCCS Division of Budget and Finance Anticipated completion date: December 31, 2024 Agency’s Response: Concur AHCCCS concurs with the finding in this audit and would like to note this finding is related to no notice of disenrollment being mailed to a deceased member, and not related to enrollment ineligibility. AHCCCS Division of Member and Provider Services (“DMPS”) will identify the standard process for notification that should have been followed for this case. Once the root cause of the issue has been established, AHCCCS will assess current processes and procedures, as appropriate, to address this issue.

View Audit 333243

Finding 515470 (2023-132)

Material Weakness 2023

State of Arizona

AZ

Questioned Costs Special Tests & Provisions Material Weakness

Assistance listing number and program name: 93.778 Medicaid Assistance Program (part of the Medicaid Cluster 93.778 COVID-19 Medicaid Assistance Program Agency: Arizona Health Care Cost Containment System (AHCCCS) Name of contact person and title: Jeff Tegen, Assistant Director, AHCCCS Division of B...

Assistance listing number and program name: 93.778 Medicaid Assistance Program (part of the Medicaid Cluster 93.778 COVID-19 Medicaid Assistance Program Agency: Arizona Health Care Cost Containment System (AHCCCS) Name of contact person and title: Jeff Tegen, Assistant Director, AHCCCS Division of Budget and Finance Anticipated completion date: December 31, 2024 Agency’s Response: Concur AHCCCS concurs with the finding and would like to note this matter was discovered through internal review of OIG recoupment documentation and filings with CMS. This matter was reviewed in detail by our financial management team and AHCCCS determined this was caused by a few factors: (1) staffing issues and employee turnover in all units involved in the process to return OIG recoupments to CMS. (2) A breakdown of inter and intra-departmental communication and collaboration. Efforts to eliminate this from occurring in the future include recently filling the related following positions that experienced turnover: Accounting Supervisor, Reporting Administrator, and 2 Accounting Specialists. In addition, AHCCCS has increased collaboration across the respective departments and divisions to ensure the federal share of all case recoupments is timely returned to CMS. Further, we have revised our standard work processes to include monthly reconciliations of case recoupments among the various departments and divisions. AHCCCS anticipates to have returned the federal share to CMS for all case recoupments identified by December 31, 2024.

View Audit 333243 Questioned Costs: $1

Finding 515469 (2023-131)

Material Weakness 2023

State of Arizona

AZ

Questioned Costs Special Tests & Provisions Material Weakness

Assistance listing number and program name: 93.778 Medicaid Assistance Program (part of the Medicaid Cluster 93.778 COVID-19 Medicaid Assistance Program Agency: Arizona Health Care Cost Containment System (AHCCCS) Name of contact persons and titles: Vanessa Templeman, Inspector General, AHCCCS Offic...

Assistance listing number and program name: 93.778 Medicaid Assistance Program (part of the Medicaid Cluster 93.778 COVID-19 Medicaid Assistance Program Agency: Arizona Health Care Cost Containment System (AHCCCS) Name of contact persons and titles: Vanessa Templeman, Inspector General, AHCCCS Office of Inspector General; Jeff Tegen, Assistant Director, AHCCCS Division of Budget and Finance Anticipated completion date: December 31, 2024 Agency’s Response: Concur AHCCCS OIG agrees with the finding as stated above. AHCCCS OIG commits to a review of the current Deferred Process and will determine areas of improvement to include; timelines for deferred case review completion, quarterly completed deferred case review reports, and required documentation for all deferred case processes.

View Audit 333243 Questioned Costs: $1

Finding 515468 (2023-130)

Material Weakness 2023

State of Arizona

AZ

Questioned Costs Special Tests & Provisions Procurement, Suspension & Debarment

Assistance listing number and program name: 93.778 Medicaid Assistance Program (part of the Medicaid Cluster 93.778 COVID-19 Medicaid Assistance Program Agency: Arizona Health Care Cost Containment System (AHCCCS) Name of contact person and title: Jeff Tegen, Assistant Director, AHCCCS Division of B...

Assistance listing number and program name: 93.778 Medicaid Assistance Program (part of the Medicaid Cluster 93.778 COVID-19 Medicaid Assistance Program Agency: Arizona Health Care Cost Containment System (AHCCCS) Name of contact person and title: Jeff Tegen, Assistant Director, AHCCCS Division of Budget and Finance Anticipated completion date: December 31, 2024 Agency’s Response: Concur In May 2023, AHCCCS announced its initial findings of credible and willful fraud by sober-living providers across the state. Since then, AHCCCS has suspended more than 300 providers, assisted over 10,000 individuals with the humanitarian response, and implemented more than 20 new initiates to combat fraud, waste, and abuse in the Medicaid program. As the extent of the fraud was revealed, AHCCCS recognized the need for holistic and systemwide changes. AHCCCS partnered with the Attorney General and Governor’s Office to develop a comprehensive plan to address the loopholes fraudulent providers were exploiting. Stop gap strategies implemented include, but may not limited to the following: · Increased scrutiny of claims based on claims volume. · Issued a moratorium on new provider registrations for impacted provider types · Prevented Reimbursement of Claims for Impossibly Rendered Services · Claims for Substance Abuse Services for Children under the age of 12 to Require Clinical Review Prior to Payment · Set thresholds for services to initiate a prepayment review. · Required claims to be billed for specific dates of service rather than ranges. · Flagged claims for services of the same style/overlapping codes. · Created a prepayment review process for providers utilizing suspicious billing practices. · Eliminated retroactive billing. · Credible Allegation of Fraud (“CAF”) suspensions include both provider entities and owners/ behavioral health (“BH”) practitioners. · Implemented ID.Me identity verification for AHCCCS Online. · Required providers to disclose any third-party billing relationships. · Behavioral Health Providers are now considered high-risk provider types for provider enrollment. · Per Diem codes have been set to only be able to be billed once per day. · Practitioners, including Behavioral Health Technicians, can no longer be patients at the same provider. · Worked with the Arizona Corporation Commission to flag suspicious registrations. · Ensured AHCCCS coding adhered to National Correct Coding Initiative (“NCCI”) standards and confirmed no edits had been turned off. · Streamlined AHCCCS reporting of bad actors to the appropriate professional oversight boards. Stop gap strategies in process include, but may not be limited to, the following: · Implementing eligibility integrity requirements for AIHP enrollment. · Linking BHP to BH companies they work for. · Link BH Providers to BH facilities they work at. · Conduct onsite quality of care reviews for patients in treatment longer than 90 days. · Require medical records to define specialized services. · Implement a new pre/post pay claims system. · Mandatory transition to Electronic Fund Transfer (direct deposit) for all AHCCCS provider reimbursements. AHCCCS continues to investigate and identify areas of concern and implement necessary system improvements until it is determined that the integrity of the AHCCCS provider network is restored.

View Audit 333243 Questioned Costs: $1

Corrective Action Plans

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