Corrective Action Plans

(A) CDOT will work with various divisions to devise a plan that will comply with this finding and the recommendations noted within. This plan shall include identifying a centralized location for all policies and procedures related to subrecipient monitoring. We will look at all policies and procedur...

(A) CDOT will work with various divisions to devise a plan that will comply with this finding and the recommendations noted within. This plan shall include identifying a centralized location for all policies and procedures related to subrecipient monitoring. We will look at all policies and procedures to ensure they clearly identify responsibilities and requirements for non-compliance. (B) CDOT will work with various divisions to devise a plan that will comply with this finding and the recommendations noted within. This plan shall include establishing a process by which an analysis of contracted entities will be performed to identify and properly record entities as a vendor or subrecipient.

View Audit 282464

Finding 316224 (2022-050)

Material Weakness 2022

State of Colorado

CO

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

(B) The Department revised its training model which is on track and will be fully rolled out to all eligibility sites by July 2022. (D) The Department disagrees with the auditor?s findings and questioned costs related to capitation payments under the Eligibility Issues Identified through Data Analy...

(B) The Department revised its training model which is on track and will be fully rolled out to all eligibility sites by July 2022. (D) The Department disagrees with the auditor?s findings and questioned costs related to capitation payments under the Eligibility Issues Identified through Data Analyses section. These costs are related to cases that were ?not eligible? in CBMS but were showing as ?eligible? in Colorado interChange that were already identified by the Department. The Department was actively working to resolve these cases with CMS prior to the Public Health Emergency (PHE). The Department developed and implemented a reconciliation report that is used to research and resolve CBMS and Colorado interChange interface mismatches. Members identified on the reconciliation reports were being manually updated until March 2020. CMS instructed the Department to cease work on these cases when the PHE was implemented. During the PHE the Department was not allowed to terminate benefits for anyone receiving benefits prior to March 2020, even if eligibility was determined incorrectly prior to the PHE. During this unprecedented time, the authority and operations regarding these cases was not immediately available. The auditors? retrospective review fails to address the uncertainty that occurred during this period of the PHE. The Department agrees to resume work on the manual reconciliation process when authorized by CMS.

View Audit 282464

Finding 316202 (2022-048)

Material Weakness 2022

State of Colorado

CO

Subrecipient Monitoring Eligibility Allowable Costs / Cost Principles

(A) Caseworker errors can be caused by an array of issues, including, training material retention; a lack of adequate funding to balance caseload inventory versus available work hours and staffing levels; a lack of quality review and performance reinforcement; and an assortment of local issues that ...

(A) Caseworker errors can be caused by an array of issues, including, training material retention; a lack of adequate funding to balance caseload inventory versus available work hours and staffing levels; a lack of quality review and performance reinforcement; and an assortment of local issues that lead to employee turnover. The Department will continue to work with eligibility sites regarding caseworker errors identified through this audit. The Department?s caseworker training resources, or Staff Development Center (SDC), is in the process of revamping all of their foundational training materials into a "Process-Based Training" model to be more effective and efficient based on training industry best practice. In addition, the SDC is converting all training materials into several different training modalities (instructor led courses, eLearning courses, desk aids, process manuals, infographics, workbooks, etc.) to be more engaging, effective, and accessible to adult learners with varying needs and preferences across large geographical areas. The revised training model is on track to be completed by July 31, 2021 and fully rolled out to all counties by Fiscal year end 2022. (C) The Department has thoroughly researched the issues identified in this audit and has made changes to CBMS to ensure that it is using the correct income information, income thresholds in determining eligibility, and buy-in premiums are assessed. These issues were fixed May 2019, February 2020, and March 2020, and in June 2021 the income information system issue will be corrected. The Department disagrees with the auditor?s questioned costs and projection of those questions costs. The Department disagrees with the auditor?s sampling, stratification, and costs used to generate the projected questioned costs. The costs incorrectly include members who remain eligible once the identified error had been resolved, payments that will be recovered by the Department through an existing process to recover capitation payments from deceased members, a Social Security Administration (SSA) interface error outside the control of the Department, and costs related to an already identified issue regarding reconciling eligibility between CBMS and Colorado interChange. Some of these costs are related to cases that were ?not eligible? in CBMS but were showing as ?eligible? in Colorado interChange that were already identified by the Department and should have been excluded from the questioned costs and the resulting projections. The Department will resume the reconciliation process between CBMS and Colorado interChange when authorized by CMS. Regarding the SSA interfaces, SSA posted results that are valid conditions for Medicaid eligibility, so those costs should have been excluded from the resulting projections. The Department agrees to bring interface issues to the attention of SSA. The Department has heard that other individuals have been notified on an SSA incarceration status which was incorrect. We have reached out to SSA concerning interface issues and will reach out again. In the meantime we will work with our eligibility workers to attempt to update these cases when they occur.

View Audit 282464

Finding 316201 (2022-054)

Material Weakness 2022

State of Colorado

CO

Eligibility Subrecipient Monitoring Allowable Costs / Cost Principles § 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 316199 (2022-052)

Material Weakness 2022

State of Colorado

CO

Internal Control / Segregation of Duties Reporting Eligibility

(A) The Department agrees with the audit recommendation to develop and implement formal written policies and procedures. Prior to this audit, the Department began creating formal written policies and procedures for site case reviews, maintenance of supporting documentation, timely training for faile...

(A) The Department agrees with the audit recommendation to develop and implement formal written policies and procedures. Prior to this audit, the Department began creating formal written policies and procedures for site case reviews, maintenance of supporting documentation, timely training for failed workers, and performance of timely re-certification of presumptive eligibility sites (PE site). This finding had no known questionable cost associated with it. (B) The Department agrees with the audit recommendation to develop an effective tracking mechanism to identify and monitor PE sites that are due for re-certification every two years and ensuring that the recertifications are performed. Prior to this audit, the Department began developing a tracking mechanism for PE site re-certifications. This finding had no known questionable cost associated with it. (C) The Department fixed enrollment information for Fiscal Year 2020 and 2021 in CBMS for beneficiaries who were no longer eligible for presumptive eligibility and have either had their benefits terminated or were moved to the regular Medicaid and Children?s Basic Health Plan programs. The Department is currently performing regular reviews to appropriately terminate applicants? presumptive eligibility in CBMS when appropriate. However, the Department has not addressed the programming and system issues in CBMS. The Department plans to fully implement this recommendation by December 2022.

View Audit 282464

Finding 316198 (2022-051)

Material Weakness 2022

State of Colorado

CO

Reporting

(A) The training materials have been created, and the training will take place on June 23, 2022. (B) The policies and procedures have been updated and were effective on July 1, 2022. (C) The Department implemented procedures and coding sufficient to allow proper reporting of overpayments returned ...

(A) The training materials have been created, and the training will take place on June 23, 2022. (B) The policies and procedures have been updated and were effective on July 1, 2022. (C) The Department implemented procedures and coding sufficient to allow proper reporting of overpayments returned greater than one year from the date of discovery for the CMS quarterly reports. (D) The Program Integrity Division has created a supervisory review process that is included in the updated policies and procedures. This process was effective July 1, 2022.

View Audit 282464

Finding 316197 (2022-049)

Material Weakness 2022

State of Colorado

CO

Eligibility Subrecipient Monitoring HUD Housing Programs

(A) The Department will create written procedures documenting system and monitoring processes used to prevent claims from paying after a beneficiary?s date-of-death is verified. In addition, the procedures will document the processes used to recover payments made between a beneficiary?s verified dat...

(A) The Department will create written procedures documenting system and monitoring processes used to prevent claims from paying after a beneficiary?s date-of-death is verified. In addition, the procedures will document the processes used to recover payments made between a beneficiary?s verified date-of-death and the date the Colorado interChange system is updated with the date-of-death. (B) The system issues described in this audit were resolved as of April 2020 for fee-for-service claims and November 2020 for capitation payments. Once a beneficiary's date-of-death is verified, payments that were made after to the date-of-death will be recovered through the Department's existing processes. As noted in the Department?s response to Recommendation (A), the Department will create written procedures documenting system and monitoring processes used to prevent claims from paying after a beneficiary?s date-of-death is verified. In addition, the procedures will document the processes used to recover payments made between a beneficiary?s verified date-of-death and the date the Colorado interChange system is updated with the date-of-death. (C) The review for FFS claims is complete and all Notices of Adverse Action have been sent to providers. At this time we are waiting on any requests for informal reconsiderations, appeals, and/or payments to process.

View Audit 282464

Finding 316196 (2022-055)

Material Weakness 2022

State of Colorado

CO

Eligibility Procurement, Suspension & Debarment Subrecipient Monitoring § 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 Subrecipient Monitoring § 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 316194 (2022-046)

Material Weakness 2022

State of Colorado

CO

Subrecipient Monitoring Material Weakness Reporting § 200.303

The Department did not have strong enough controls for the initial checks on the financial data reporting templates. This process has been updated and will be rectified in coming cycles. The Department has modified its templates in order to address the concerns provided by the auditors including sig...

The Department did not have strong enough controls for the initial checks on the financial data reporting templates. This process has been updated and will be rectified in coming cycles. The Department has modified its templates in order to address the concerns provided by the auditors including signatures and supplemental reporting. Written policies and procedures for the validation and audit of the templates are being developed currently and will be in place and effective in December 2022. The Department will be correcting this error by posting the audit results along with other quality and audit reports on the following site: https:hcpf.colorado.gov/quality-and-healthimprovement-reports.

View Audit 282464

Finding 316193 (2022-045)

Material Weakness 2022

State of Colorado

CO

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

(A) The MLR report template has been updated and will now be reviewed at least yearly by the Department. In addition, new written policies and procedures are being developed and will be implemented before the submission of the next MLR for review. (B) The Department will add contract language and e...

(A) The MLR report template has been updated and will now be reviewed at least yearly by the Department. In addition, new written policies and procedures are being developed and will be implemented before the submission of the next MLR for review. (B) The Department will add contract language and enforcement mechanisms in order to receive accurate information in a timely manner. This includes specific timelines for correcting incomplete or inaccurate information in order to submit the MLR report timely to the Centers for Medicare & Medicaid Services.

View Audit 282464

Finding 316192 (2022-044)

Material Weakness 2022

State of Colorado

CO

Eligibility Subrecipient Monitoring Allowable Costs / Cost Principles

(B) The Department will continue our existing proactive approach to minimize this issue. The resolution of a SSN discrepancy is addressed through manual intervention by county eligibility technicians when identified through the system edit implemented in December 2020. The Department will continue t...

(B) The Department will continue our existing proactive approach to minimize this issue. The resolution of a SSN discrepancy is addressed through manual intervention by county eligibility technicians when identified through the system edit implemented in December 2020. The Department will continue the existing process to address duplicate SSNs. The Department has already made significant progress to monitor CBMS through the use of CBMS monitoring dashboards. These dashboards allow the Department to monitor and perform daily analysis. The Department meets bi-weekly to discuss findings and next steps to resolve any issues identified through the dashboard. These dashboards are being implemented over time as areas of improvements are identified. As part of the Department's continual improvement strategy, SSN discrepancy reports are included in the next implementation phase of the monitoring dashboards scheduled for June 2023. The Department will develop and implement policies and procedures outlining how the report will be used to effectively monitor and correct SSN and State ID discrepancies. Once that work is complete, the Department will send updated written guidance to our county and medical assistance sites on how to use system edits, reports, and dashboards to resolve duplicate SSNs. (C) The Department will continue our existing proactive approach to minimize this issue. The resolution of a SSN discrepancy is addressed through manual intervention by county eligibility technicians when identified through the system edit implemented in December 2020. The Department will continue the existing process to address duplicate SSNs. The Department has already made significant progress to monitor CBMS through the use of CBMS monitoring dashboards. These dashboards allow the Department to monitor and perform daily analysis. The Department meets bi-weekly to discuss findings and next steps to resolve any issues identified through the dashboard. These dashboards are being implemented over time as areas of improvements are identified. As part of the Department's continual improvement strategy, SSN discrepancy reports are included in the next implementation phase of the monitoring dashboards scheduled for June 2023. Once that work is complete, the Department will send updated written guidance to our county and medical assistance sites on how to use system edits, reports, and dashboards to resolve duplicate SSNs appropriately and in a timely manner.

View Audit 282464

Finding 316191 (2022-043)

Material Weakness 2022

State of Colorado

CO

Eligibility Procurement, Suspension & Debarment Subrecipient Monitoring § 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

Finding 308705 (2022-084)

Significant Deficiency 2022

State of Colorado

CO

GSA_MIGRATION

View Audit 282464

Finding 308704 (2022-083)

Significant Deficiency 2022

State of Colorado

CO

GSA_MIGRATION