While management’s calculation of lost revenues for 2020 was determined to be accurate, as the 2019 and 2020 reported numbers in the portal submission reconciled and agreed to MEMN’s audited net revenue amounts for those periods, the calculation of lost revenues for 2021 was not accurate. The report...
While management’s calculation of lost revenues for 2020 was determined to be accurate, as the 2019 and 2020 reported numbers in the portal submission reconciled and agreed to MEMN’s audited net revenue amounts for those periods, the calculation of lost revenues for 2021 was not accurate. The reported amounts of net revenue from fiscal year 2021 and fiscal year 2022 (partially from calendar year 2021) did not reconcile or agree to the audited amounts of net patient revenue from these periods.
Actions:
1. Establish Reporting Review Procedures:
• Develop a formal procedure for reviewing all reports and submissions to federal agencies before submission.
• Designate a responsible party within management to oversee the review process and ensure compliance with established procedures.
2. Documentation and Record-Keeping:
• Implement a documentation system to track the review process for each report or submission.
3. Dual Review Requirement:
• Ensure that all reports and submissions to federal agencies undergo a dual review process, when possible.
• While we understand the importance of accuracy and compliance in our reporting processes, instituting a dual review requirement may not be feasible for MEMN given our size and resource constraints. As a small company, we operate with limited staff and resources, and imposing a dual review requirement could impose unnecessary burdens on our team members and hinder efficiency.
Instead, we will explore alternative measures to ensure the accuracy of our reports and submissions. This includes implementing robust internal controls, enhancing documentation procedures, and providing guidance to staff involved in the reporting process. By strengthening our internal processes and promoting a culture of accountability and mindfulness, we can mitigate the risk of errors and discrepancies without imposing additional layers of review.
Additionally, a more practical approach would be to designate a single individual within our organization to oversee the review process. This individual would be responsible for conducting a thorough review of each report or submission before it is finalized and submitted. This approach maintains accountability while avoiding the logistical challenges associated with implementing a dual review requirement.
4. Enhanced Reconciliation Procedures:
• Improve reconciliation procedures between reported amounts and audited financial data.
• Conduct regular reconciliations between reported net revenue figures and audited net patient revenue amounts to identify discrepancies promptly.
5. Internal Controls Enhancement:
• Strengthen internal controls related to financial reporting and submissions to federal agencies.
Timeline:
• Establish Reporting Review Procedures and Documentation: Complete within three months, May 2024
• Review Requirement: Implement immediately, February 2024
• Enhanced Reconciliation Procedures: Begin within three months, May 2024
• Internal Controls Enhancement: Implement within four months, June 2024
Monitoring and Evaluation:
• Regular progress meetings to track the implementation of corrective actions.
• Monitor the effectiveness of the dual review process and reconciliation procedures through periodic assessments.
• Conduct internal audits to evaluate compliance with established procedures and identify areas for improvement.
Contact:
• Alain Viaud, aviaud@som.umaryland.edu, 667-214-2051