Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Finding 2022-704: Research and Development Cluster?Unallowable Costs Background: During FY 2021-22, UW institutions were awarded $741.6 million in federal funding as part of the Research and Development Cluster, for which UW Madison expended the majority of the funding. UW Madison purchases a variety of supplies and other goods or services to conduct its research activities. Criteria: Under 2 CFR s. 200.303, UW Madison is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, 2 CFR s. 200.405 (a) specifies that for a cost to be allocable to a federal award the cost must be incurred specifically for the federal award; benefit both the federal award and other work; be distributed in proportions; be necessary to overall institutional operations; and be assignable, in part, to the federal award. Condition: We found that UW-Madison charged two unallowable costs to two federal awards during FY 2021 22. First, we found that UW Madison charged $54 for facilities and maintenance expenses relating to a location not used for purposes related to the federal award. Second, we found that UW Madison charged $596 in software license fees to a federal award. However, it is UW Madison?s practice to charge such fees to a nonfederal project. Context: During FY 2021-22, UW-Madison expended $86.9 million in certain nonpayroll expenses using federal Research and Development Cluster funding. There were 84,230 transactions comprising this amount with an average dollar amount of $1,032. We reviewed 40 such transactions to determine if the expenses were allowable under federal regulations. To complete our testing, we requested supporting documentation and information from UW-Madison for the transactions we reviewed. Questioned Costs: We questioned $650 in known questioned costs and an undetermined amount for other expenses we did not review. Because our testing was based upon a sample of payments it is likely there are additional cases where the payment is inappropriately charged to a federal award. We estimate these additional questioned costs are likely over $25,000, which is required to be reported under 2 CFR s. 200.516. Effect: UW-Madison used $650 in federal funds from the Research and Development Cluster for unallowable costs during FY 2021-22. Because unallowable costs were charged to the Research and Development Cluster, UW-Madison was not in compliance with federal requirements for the use of federal funding. Cause: UW-Madison staff indicated that the charges were applied to incorrect accounting codes when the expenses were originally recorded. For example, the $54 for facilities and maintenance expenses was charged to a federal award in the accounting system due to a limitation of certain billing codes for applying such expenses to the correct location of the work. These errors were not identified or corrected during the review of the payment or of other UW Madison monitoring activities. In December 2022 and January 2023, UW Madison corrected these accounting codes for these transactions and transferred the expenses to nonfederal projects. Recommendation: We recommend the University of Wisconsin Madison provide guidance and training to staff to ensure all costs are properly charged to federal award accounting codes and only costs allowable under federal regulations are charged to federal funds. Finding 2022-704: Research and Development Cluster?Unallowable Costs Research and Development Cluster (various Assistance Listing numbers) Award Numbers Award Years Various Various Questioned Costs: $650 Type of Finding: Noncompliance Response from the University of Wisconsin Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Program: AL 21.023 ? COVID-19 Emergency Rental Assistance ? Allowability & Eligibility Grant Number & Year: N/A Federal Grantor Agency: U.S. Department of the Treasury Criteria: Per 2 CFR ? 1000.10 (January 1, 2022), the U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements set forth at 2 CFR part 200. 2 CFR ? 200.303 (January 1, 2022) states, in relevant part, the following: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. . . . Good internal controls require risk assessments to be performed, and procedures to verify the validity of applicants prior to payment. 2 CFR ? 200.403 (January 1, 2022) states, in part: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. * * * * (g) Be adequately documented. The Nebraska ERA Program FAQ states, ?Who is eligible? You are eligible if you answer YES to ALL of the following: . . .Your landlord is not an immediate family member.? Division N ? Additional Coronavirus Response and Relief, Title V ? Banking, Section 501(k)(3)(A) of the Consolidated Appropriations Act, 2021, states that an eligible household is a household of one or more individuals that is obligated to pay rent on a residential dwelling. Good internal controls require procedures to verify the validity of applicants prior to payment. Condition: Procedures were not adequate to ensure that payments were allowable, and individuals were eligible for assistance. A similar finding was noted in the prior audit. Repeat Finding: 2021-064 Questioned Costs: $76,050 known Statistical Sample: No Context: During testing of 40 aid payments, we noted one payment, totaling $1,350, made to an applicant whose landlord was an immediate relative. The total sample tested was $87,526, and total assistance payments for the fiscal year were $17,456,087. The dollar error rate for the sample was 1.54% ($1,350/$87,526), which estimates the potential dollars at risk for fiscal year 2022 to be $268,824 (dollar rate multiplied by the population.) In the prior and current audit, we noted that the Agency identified likely fraudulent payments. As of January 9, 2023, the Agency had identified $155,360 and $822,188 of likely fraudulent payments in fiscal years ended June 30, 2021, and June 30, 2022, respectively. We reviewed five of these payments, totaling $74,700, in fiscal year 2022. For all five payments, we noted indicators of possible fraud, as information on the application provided was inconsistent with the information from other databases or systems. Examples of such indicators include the following: 1) the owner of the property per the County Assessors website not agreeing to the owner listed on the application; 2) generic and editable supporting documentation; and 3) tenants and landlords having out-of-state identification and telephone numbers. According to the Agency, these payments have been referred to the State Patrol for further investigation. Cause: The Agency had various procedures for ensuring that application information was accurate; however, verifying the property owner to County Assessor information was not required. Effect: There is an increased risk for fraudulent payments. Once fraudulent payments have been made, the likelihood of recouping them is low. Recommendation: We recommend the Agency improve its procedures for verifying the validity of applicants prior to payments. We further recommend the Agency continue to work with law enforcement to recoup improper payments. Management Response: The Military Department does not agree with this finding. The State has implemented a strong system of internal controls to determine program eligibility. These controls include detailed pre-payment and post-payment analytics to help identify applications at risk for fraud. As the ERA program progressed in Nebraska and nationally, program procedures continued to be enhanced to monitor for and prevent potentially fraudulent applications. During its life the program provided proactive fraud detection for over 56,000 tenant and landlord applications and prevented approximately $23M of funding from being paid out erroneously. Additionally, the State turns over any paid applications that have been subsequently determined at risk of being fraudulent to the State Patrol for further investigation and potential prosecution. APA Response: In addition to the one of 40 payments tested with errors, five payments we reviewed noted possible indications of fraud. Once fraudulent payments have been made, the likelihood of recouping them is low. 2 CFR ? 200.516 (January 1, 2022) requires reporting known or likely fraud affecting a Federal award.
Section I - Summary of Auditor's Results Financial Statements Type of auditor's report issued: Unmodified Internal control over financial reporting: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Noncompliance material to financial statements noted? yes X no Federal Awards Internal control over major programs: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Type of auditor's report issued on compliance for major programs: Unmodified Any audit findings disclosed that are required to be reported in accordance with the 2 CFR 200.516(a)? X yes no Identification of major programs A s sCiFsDtaAn cNeu Lmisbteinr(gs )Number(s) Name of Federal Program or Cluster Various Student Financial Assistance Cluster Dollar threshold used to distinguish between type A and type B programs: $ 3,000,000 Auditee qualified as low-risk auditee? X yes no Section II - Financial Statement Findings No matters noted. Section III ? Federal Award Findings and Questioned Costs Finding 2022-001: Notification of Title IV disbursement not provided appropriately Federal Agency: Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: Various Award #: Various Award Year: 2021-2022 Criteria: 34 CFR 668.165, Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Questioned Costs: None. Condition: During the 2021-2022 award year, four out of twenty-five students tested in our sample of disbursements of Title IV funds were not provided notification prior to disbursement of funds as dictated by 34 CFR 668.165. Notification was provided subsequent to disbursement for three of these students; however, one student was not notified at all. Cause: The University?s internal controls over Title IV eligibility and disbursement include a manual review of each student?s account prior to disbursement. Upon completion of this review, the employee performing the review will manually flag the student?s account in the system which generates the required notification prior to disbursement. These four student accounts were not manually flagged for notification. Effect: The University did not provide timely notification to three students and did not provide notification at all for one student. Recommendation: We recommend the University reiterate to control owners the importance of manually flagging students? accounts when reviews are performed. Additionally, a review control to ensure notifications are provided prior to disbursement should be considered. Views of Responsible Officials/Management Response: See Management?s view and corrective action plan included at the end of this report.
Section I - Summary of Auditor's Results Financial Statements Type of auditor's report issued: Unmodified Internal control over financial reporting: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Noncompliance material to financial statements noted? yes X no Federal Awards Internal control over major programs: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Type of auditor's report issued on compliance for major programs: Unmodified Any audit findings disclosed that are required to be reported in accordance with the 2 CFR 200.516(a)? X yes no Identification of major programs A s sCiFsDtaAn cNeu Lmisbteinr(gs )Number(s) Name of Federal Program or Cluster Various Student Financial Assistance Cluster Dollar threshold used to distinguish between type A and type B programs: $ 3,000,000 Auditee qualified as low-risk auditee? X yes no Section II - Financial Statement Findings No matters noted. Section III ? Federal Award Findings and Questioned Costs Finding 2022-001: Notification of Title IV disbursement not provided appropriately Federal Agency: Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: Various Award #: Various Award Year: 2021-2022 Criteria: 34 CFR 668.165, Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Questioned Costs: None. Condition: During the 2021-2022 award year, four out of twenty-five students tested in our sample of disbursements of Title IV funds were not provided notification prior to disbursement of funds as dictated by 34 CFR 668.165. Notification was provided subsequent to disbursement for three of these students; however, one student was not notified at all. Cause: The University?s internal controls over Title IV eligibility and disbursement include a manual review of each student?s account prior to disbursement. Upon completion of this review, the employee performing the review will manually flag the student?s account in the system which generates the required notification prior to disbursement. These four student accounts were not manually flagged for notification. Effect: The University did not provide timely notification to three students and did not provide notification at all for one student. Recommendation: We recommend the University reiterate to control owners the importance of manually flagging students? accounts when reviews are performed. Additionally, a review control to ensure notifications are provided prior to disbursement should be considered. Views of Responsible Officials/Management Response: See Management?s view and corrective action plan included at the end of this report.
Section I - Summary of Auditor's Results Financial Statements Type of auditor's report issued: Unmodified Internal control over financial reporting: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Noncompliance material to financial statements noted? yes X no Federal Awards Internal control over major programs: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Type of auditor's report issued on compliance for major programs: Unmodified Any audit findings disclosed that are required to be reported in accordance with the 2 CFR 200.516(a)? X yes no Identification of major programs A s sCiFsDtaAn cNeu Lmisbteinr(gs )Number(s) Name of Federal Program or Cluster Various Student Financial Assistance Cluster Dollar threshold used to distinguish between type A and type B programs: $ 3,000,000 Auditee qualified as low-risk auditee? X yes no Section II - Financial Statement Findings No matters noted. Section III ? Federal Award Findings and Questioned Costs Finding 2022-001: Notification of Title IV disbursement not provided appropriately Federal Agency: Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: Various Award #: Various Award Year: 2021-2022 Criteria: 34 CFR 668.165, Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Questioned Costs: None. Condition: During the 2021-2022 award year, four out of twenty-five students tested in our sample of disbursements of Title IV funds were not provided notification prior to disbursement of funds as dictated by 34 CFR 668.165. Notification was provided subsequent to disbursement for three of these students; however, one student was not notified at all. Cause: The University?s internal controls over Title IV eligibility and disbursement include a manual review of each student?s account prior to disbursement. Upon completion of this review, the employee performing the review will manually flag the student?s account in the system which generates the required notification prior to disbursement. These four student accounts were not manually flagged for notification. Effect: The University did not provide timely notification to three students and did not provide notification at all for one student. Recommendation: We recommend the University reiterate to control owners the importance of manually flagging students? accounts when reviews are performed. Additionally, a review control to ensure notifications are provided prior to disbursement should be considered. Views of Responsible Officials/Management Response: See Management?s view and corrective action plan included at the end of this report.
Section I - Summary of Auditor's Results Financial Statements Type of auditor's report issued: Unmodified Internal control over financial reporting: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Noncompliance material to financial statements noted? yes X no Federal Awards Internal control over major programs: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Type of auditor's report issued on compliance for major programs: Unmodified Any audit findings disclosed that are required to be reported in accordance with the 2 CFR 200.516(a)? X yes no Identification of major programs A s sCiFsDtaAn cNeu Lmisbteinr(gs )Number(s) Name of Federal Program or Cluster Various Student Financial Assistance Cluster Dollar threshold used to distinguish between type A and type B programs: $ 3,000,000 Auditee qualified as low-risk auditee? X yes no Section II - Financial Statement Findings No matters noted. Section III ? Federal Award Findings and Questioned Costs Finding 2022-001: Notification of Title IV disbursement not provided appropriately Federal Agency: Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: Various Award #: Various Award Year: 2021-2022 Criteria: 34 CFR 668.165, Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Questioned Costs: None. Condition: During the 2021-2022 award year, four out of twenty-five students tested in our sample of disbursements of Title IV funds were not provided notification prior to disbursement of funds as dictated by 34 CFR 668.165. Notification was provided subsequent to disbursement for three of these students; however, one student was not notified at all. Cause: The University?s internal controls over Title IV eligibility and disbursement include a manual review of each student?s account prior to disbursement. Upon completion of this review, the employee performing the review will manually flag the student?s account in the system which generates the required notification prior to disbursement. These four student accounts were not manually flagged for notification. Effect: The University did not provide timely notification to three students and did not provide notification at all for one student. Recommendation: We recommend the University reiterate to control owners the importance of manually flagging students? accounts when reviews are performed. Additionally, a review control to ensure notifications are provided prior to disbursement should be considered. Views of Responsible Officials/Management Response: See Management?s view and corrective action plan included at the end of this report.
Section I - Summary of Auditor's Results Financial Statements Type of auditor's report issued: Unmodified Internal control over financial reporting: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Noncompliance material to financial statements noted? yes X no Federal Awards Internal control over major programs: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Type of auditor's report issued on compliance for major programs: Unmodified Any audit findings disclosed that are required to be reported in accordance with the 2 CFR 200.516(a)? X yes no Identification of major programs A s sCiFsDtaAn cNeu Lmisbteinr(gs )Number(s) Name of Federal Program or Cluster Various Student Financial Assistance Cluster Dollar threshold used to distinguish between type A and type B programs: $ 3,000,000 Auditee qualified as low-risk auditee? X yes no Section II - Financial Statement Findings No matters noted. Section III ? Federal Award Findings and Questioned Costs Finding 2022-001: Notification of Title IV disbursement not provided appropriately Federal Agency: Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: Various Award #: Various Award Year: 2021-2022 Criteria: 34 CFR 668.165, Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Questioned Costs: None. Condition: During the 2021-2022 award year, four out of twenty-five students tested in our sample of disbursements of Title IV funds were not provided notification prior to disbursement of funds as dictated by 34 CFR 668.165. Notification was provided subsequent to disbursement for three of these students; however, one student was not notified at all. Cause: The University?s internal controls over Title IV eligibility and disbursement include a manual review of each student?s account prior to disbursement. Upon completion of this review, the employee performing the review will manually flag the student?s account in the system which generates the required notification prior to disbursement. These four student accounts were not manually flagged for notification. Effect: The University did not provide timely notification to three students and did not provide notification at all for one student. Recommendation: We recommend the University reiterate to control owners the importance of manually flagging students? accounts when reviews are performed. Additionally, a review control to ensure notifications are provided prior to disbursement should be considered. Views of Responsible Officials/Management Response: See Management?s view and corrective action plan included at the end of this report.
Section I - Summary of Auditor's Results Financial Statements Type of auditor's report issued: Unmodified Internal control over financial reporting: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Noncompliance material to financial statements noted? yes X no Federal Awards Internal control over major programs: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Type of auditor's report issued on compliance for major programs: Unmodified Any audit findings disclosed that are required to be reported in accordance with the 2 CFR 200.516(a)? X yes no Identification of major programs A s sCiFsDtaAn cNeu Lmisbteinr(gs )Number(s) Name of Federal Program or Cluster Various Student Financial Assistance Cluster Dollar threshold used to distinguish between type A and type B programs: $ 3,000,000 Auditee qualified as low-risk auditee? X yes no Section II - Financial Statement Findings No matters noted. Section III ? Federal Award Findings and Questioned Costs Finding 2022-001: Notification of Title IV disbursement not provided appropriately Federal Agency: Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: Various Award #: Various Award Year: 2021-2022 Criteria: 34 CFR 668.165, Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Questioned Costs: None. Condition: During the 2021-2022 award year, four out of twenty-five students tested in our sample of disbursements of Title IV funds were not provided notification prior to disbursement of funds as dictated by 34 CFR 668.165. Notification was provided subsequent to disbursement for three of these students; however, one student was not notified at all. Cause: The University?s internal controls over Title IV eligibility and disbursement include a manual review of each student?s account prior to disbursement. Upon completion of this review, the employee performing the review will manually flag the student?s account in the system which generates the required notification prior to disbursement. These four student accounts were not manually flagged for notification. Effect: The University did not provide timely notification to three students and did not provide notification at all for one student. Recommendation: We recommend the University reiterate to control owners the importance of manually flagging students? accounts when reviews are performed. Additionally, a review control to ensure notifications are provided prior to disbursement should be considered. Views of Responsible Officials/Management Response: See Management?s view and corrective action plan included at the end of this report.
Section I - Summary of Auditor's Results Financial Statements Type of auditor's report issued: Unmodified Internal control over financial reporting: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Noncompliance material to financial statements noted? yes X no Federal Awards Internal control over major programs: Material weakness(es) identified? yes X no Significant deficiency(ies) identified that are not considered to be material weaknesses? yes X none reported Type of auditor's report issued on compliance for major programs: Unmodified Any audit findings disclosed that are required to be reported in accordance with the 2 CFR 200.516(a)? X yes no Identification of major programs A s sCiFsDtaAn cNeu Lmisbteinr(gs )Number(s) Name of Federal Program or Cluster Various Student Financial Assistance Cluster Dollar threshold used to distinguish between type A and type B programs: $ 3,000,000 Auditee qualified as low-risk auditee? X yes no Section II - Financial Statement Findings No matters noted. Section III ? Federal Award Findings and Questioned Costs Finding 2022-001: Notification of Title IV disbursement not provided appropriately Federal Agency: Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: Various Award #: Various Award Year: 2021-2022 Criteria: 34 CFR 668.165, Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Questioned Costs: None. Condition: During the 2021-2022 award year, four out of twenty-five students tested in our sample of disbursements of Title IV funds were not provided notification prior to disbursement of funds as dictated by 34 CFR 668.165. Notification was provided subsequent to disbursement for three of these students; however, one student was not notified at all. Cause: The University?s internal controls over Title IV eligibility and disbursement include a manual review of each student?s account prior to disbursement. Upon completion of this review, the employee performing the review will manually flag the student?s account in the system which generates the required notification prior to disbursement. These four student accounts were not manually flagged for notification. Effect: The University did not provide timely notification to three students and did not provide notification at all for one student. Recommendation: We recommend the University reiterate to control owners the importance of manually flagging students? accounts when reviews are performed. Additionally, a review control to ensure notifications are provided prior to disbursement should be considered. Views of Responsible Officials/Management Response: See Management?s view and corrective action plan included at the end of this report.
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses and a Significant Deficiency were communicated to the Department of Health Care Policy and Financing (Department) in previous years and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-045 Payments for Non-Emergent Medical Transportation ClaimsPrior to July 2020, in 55 counties, the Department worked with various county offices to have them broker Non-Emergent Medical Transportation (NEMT) services for Medicaid recipients, including rides to and from Medicaid medical appointments, personal mileage reimbursement, and trip-related meals and lodging. For example, these counties arranged the rides with transportation providers, submitted the claims or had providers submit claims for reimbursement to the Department, and passed on reimbursements to providers as needed. For the remaining nine counties, the Department contracted with IntelliRide to serve as the NEMT broker for services in those areas. From July 1, 2020, to August 31, 2021, when the Department contracted with IntelliRide to be the statewide broker, most recipients throughout the state scheduled NEMT rides by contacting IntelliRide through its call center, website chat function, or smartphone applications. IntelliRide scheduled rides and assigned transportation providers to them, and had providers upload trip information into IntelliRide?s EcoLane transportation scheduling system. EcoLane maintains information related to recipients? requests for rides and provider trip information, such as the trip date and time, names of the recipient and driver, and scheduled pick-up and destination addresses. IntelliRide submitted claims through the Department?s interChange system (interChange) requesting payments for providers? NEMT services, paid providers for their services, and received reimbursement from the Department. In addition, the Department paid NEMT claims submitted directly by NEMT providers. In Fiscal Year 2021, from July 1, 2020, through February 28, 2021 (the audit period), the Department paid 362,110 claims for NEMT services totaling about $33.2 million, as shown in the following table. In September 2021, the Department plans to transition back to IntelliRide brokering services in nine counties, while the NEMT providers in the remaining counties will broker their own services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote What audit work was performed and how were the results measured? The purpose of the audit work was to determine whether the Department has ensured that NEMT claims adhere to the following federal and state requirements. ? NEMT trips were to be brokered through, and all claims submitted by, the statewide broker, Intelliride. According to state regulations and the Department?s NEMT Billing Manual, all NEMT trips during Fiscal Year 2021 had to be authorized by the statewide broker, IntelliRide [10 CCR 2505-10 8.014.7.A]. This means that each recipient?s NEMT ride request should have been sent to IntelliRide for approval or authorization before the trip, and any unauthorized trips should ?not be reimbursed or paid? [Billing Manual]. According to the Department, it allowed NEMT providers time to transition to working with IntelliRide because some providers were reluctant to join the statewide brokerage and the Department needed time to onboard providers. By Fall 2020, most providers should have been working with IntelliRide to schedule NEMT rides. The Department told us that six NEMT providers received its express permission to bypass IntelliRide to schedule rides and submit claims directly to the Department because the providers are unique, such as only serving recipients with disabilities or receiving federal grant funding to provide NEMT. To assess whether IntelliRide brokered most NEMT services in the State and submitted the related claims in line with regulations and its contract, we reviewed the Department?s aggregate data for the 128,998 NEMT claims paid from December 2020 through February 2021. ? The Department must pay claims based on accurate service rates and trip mileage. Non-taxi NEMT services, such as wheelchair and mobility vehicle services, have base rates and mileage rates set by the Department. IntelliRide tracks the mileage of each NEMT trip in EcoLane and submits mileage claims to the Department?s interChange system. The Public Utilities Commission (PUC) sets the rate for each permitted taxi provider, which generally includes a rate for the first trip mile and a different rate for each additional mile. According to the Department?s NEMT Billing Manual and NEMT Rate Schedule for Fiscal Year 2021, taxi claims should have been paid at the rate set by the PUC. For example, if a taxi company?s PUC rate was $4 for the first mile and $2 for each additional mile, the Department should have paid $6 for a two-mile NEMT trip claim. To verify that the Department paid NEMT claims based on the correct trip mileage and rates, we reviewed the trip mileage and rates for 362,110 NEMT claims paid from July 2020 through February 2021, and PUC documentation on the taxi rates for permitted taxi companies. ? Claims must be supported with accurate and complete documentation confirming the service provided. Both IntelliRide and providers that submit claims for NEMT services must keep and be able to furnish accurate, complete supporting documentation for all claims [42 USC 1396a(27), 42 CFR ?? 431.17 and 433.32, and 10 CCR 2505-10 8.014.3.C and 8.014.6.B]. For example, a claim must be supported by medical documentation showing that the type of vehicle was needed to transport the recipient, and documentation from the transportation provider showing the trip occurred and when the recipient was picked-up and dropped-off. IntelliRide should only submit a claim to the Department after IntelliRide confirms the trip has been completed and marks the status complete in EcoLane [IntelliRide Policies and Procedures]. If an NEMT provider does not show up for a trip, IntelliRide should mark the trip as ?cancelled? in EcoLane. Payments for Medicaid claims that lack supporting documentation for the services provided are unallowable, meaning they should not be paid. IntelliRide or the Department must maintain documentation from recipients? medical providers showing why certain NEMT services, like transportation in a wheelchair van or with an escort, are medically necessary [10 CCR 2505-10 8.014.7.B and 8.014.5.D.1; Billing Manual]. To verify that there was support for NEMT claims, we reviewed IntelliRide data in EcoLane for all 362,110 NEMT claims paid from July 2020 through February 2021, and Department documentation for a sample of 85 NEMT paid claims?75 selected randomly from the four NEMT service areas of the state, and 10 that were the highest paid NEMT claims. ? NEMT services must be medically necessary. NEMT services shall only be provided to recipients with no other means to attend medically necessary, non-emergency treatment covered by Medicaid [42 USC 1396a(70); 42 CFR 431.53; 10 CCR 2505-10 8.014.5.B]. To verify that NEMT claims were only paid for recipients to access medical care, we reviewed the Department?s data on paid medical claims to determine if the recipients related to 22 sampled NEMT claims paid in December 2020 had a corresponding medical appointment. For another 61 paid NEMT claims that involved IntelliRide scheduling and submitting claims for trips every day in December for two recipients, we reviewed whether the recipients had paid medical claims corresponding with the trips. ? Prior authorization is required for air ambulance. The Department must grant prior authorization for the use of an NEMT air ambulance before the trip occurs in order for the claim to be paid [10 CCR 2505-10 8.014.7.D.1.b]. To verify that the Department granted prior authorization for air ambulance trips, we reviewed the use of air ambulances in 11 paid claims from July 2020 to February 2021. ? Recipients are to receive the least-costly NEMT transportation option appropriate for their medical condition. For example, recipients should only ride in a vehicle for recipients with mobility needs when they have a mobility issue or if there is a lack of access to public transportation [10 CCR 2505-10 8.014.6.B, 42 USC 1396(a(70), and 42 CFR 440.170(a)(4)]. Higher-cost NEMT services, such as ambulance and wheelchair van services, must be supported with documentation of the recipient?s need for the specific higher-cost services [10 CCR 2505-10 8.014.5.B.1.b]. To determine whether recipients received the least costly NEMT services to meet their needs, we reviewed documentation submitted by medical or transportation providers to IntelliRide or the Department for the 85 sampled NEMT claims. ? Taxi providers must be permitted by the PUC to provide NEMT taxi rides. To provide NEMT rides by taxi and receive payment for them, the provider must maintain a common carrier permit issued by the PUC [10 CCR 2505-10 8.014.3.B.4.a]. To verify that the providers that were paid for taxi claims had been permitted to provide taxi services, we reviewed the 33,791 NEMT claims for taxi services from July 2020 to February 2021. What problems were identified? The Department paid $3.5 million directly to 66 NEMT providers for claims that were not brokered by Intelliride. From December 2020 through February 2021, 26,890 of the approximately 129,000 NEMT claims paid by the Department (21 percent), totaling about $3.5 million, were not brokered through IntelliRide, which violated state regulations requiring all NEMT services to be brokered through the statewide brokerage in effect at the time. The following chart shows the amounts the Department paid for claims submitted directly by NEMT providers compared to its payments for claims submitted by IntelliRide from July 2020 through February 2021. During these months, the number of claims that providers submitted directly to the Department decreased as providers transitioned to working with IntelliRide to broker NEMT rides; however, as of February 2021, the Department was still paying about $1 million in monthly claims that were submitted directly by providers. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote The Department paid 36,910 NEMT claims totaling $5.5 million, which either violated or may have violated federal and/or state regulations. The claims were for unallowable services or were overpaid, and resulted in $291,597 in known questioned costs and $5,180,962 in likely questioned costs for Medicaid. A questioned cost is a payment that ?resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds? or ?the costs, at the time of the audit, [that] are not supported by adequate documentation?? [2 CFR 200.84]. A known questioned cost reflects a violation that the auditor confirmed; a likely questioned cost is the auditor?s best estimate of a potential violation [2 CFR 200.516(a)(3)]. Known and likely questioned costs should be investigated by the Department and recovered, as appropriate, because Medicaid overpayments are recoverable regardless of whether they occurred due to an error by the Department, entity acting on behalf of the Department, or a provider [Section 25.5-4-301(2), C.R.S.]. We found the following problems resulting in $291,597 in known questioned costs: ? Claims paid with no support that services were provided. For 3,958 of the 362,110 NEMT claims (1 percent), which totaled $258,115 paid from July 2020 to February 2021, IntelliRide or providers submitted the claims without any documentation showing that recipients received the NEMT services from the providers listed in the claim. The $258,115 is known questioned costs and includes: o 3,323 claims totaling $163,985 submitted by IntelliRide with no documentation in EcoLane of a ride being scheduled or provided. o 619 claims totaling $61,431 submitted by IntelliRide for which EcoLane showed the scheduled ride was cancelled. o 16 sampled claims totaling $32,699 submitted by providers directly to the Department had no documentation that an NEMT service occurred because the providers did not send the Department documentation for their claims. Upon our request, the Department attempted to obtain supporting documentation from providers for these claims but was unable to obtain any. ? Overpayments due to incorrect mileage and taxi rates. For 466 of the 321,099 mileage and taxi claims (less than 1 percent), the Department overpaid IntelliRide. Specifically, for 50 of the 287,308 mileage claims (less than 1 percent), the mileage submitted by IntelliRide that the Department paid was more than the ride mileage that IntelliRide documented in EcoLane. For 416 of the 33,791 (1 percent) claims submitted by IntelliRide on behalf of providers that were permitted to operate as taxis, the Department paid a higher rate than the providers? set PUC rate. The following table breaks out the overpayments that we identified, which totaled $6,759 in known questioned costs. We did not find issues with the rate amounts that the Department paid for non-mileage and non-taxi services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Examples of these overpayments include: o An overpayment of $48 for a claim submitted by IntelliRide for a taxi provider that billed the wrong taxi rate. The Department paid $60 for a 4-mile trip, when it should have paid $12 based on the PUC rate of $3 per mile. o An overpayment of $79 for a claim submitted by IntelliRide on behalf of a provider because the claim showed the trip was 76 miles, but the EcoLane data showed the trip was 38 miles. The Department paid $157, when it should have paid $78. ? Unallowable rides, not for medical appointments. For 61 claims showing NEMT trips every day in December 2020 for two recipients, there were no medical claims corresponding to their trips, so it appears that either NEMT was used repeatedly to transport these recipients to unallowable destinations or the provider did not provide the trips claimed. The NEMT provider reported to IntelliRide that these trips were completed even though the recipients did not attend any medical appointments that month. IntelliRide submitted the 61 NEMT claims and its EcoLane data showed that the NEMT providers self-reported that the trips were completed. However, IntelliRide confirmed that these trips were not used to access medical care. The issues we identified resulted in $2,674 of known questioned costs. ? Air ambulance claims paid without prior authorization. None of the 11 air ambulance NEMT claims had supporting documentation that the provider requested or received prior authorization from the Department before the trip occurred. These 11 claims to three providers resulted in $23,122 in known questioned costs. ? Claims paid for trips that were not the least costly, medically necessary, and/or for approved escorts. For seven of the 85 sampled claims (8 percent), IntelliRide submitted the claims without having required documentation from medical providers. Specifically, four claims lacked documentation to support the medical necessity for the type of vehicle used (either mobility vehicle, taxi, or wheelchair van); the other three claims lacked documentation of the recipient?s need for an escort to support the associated cost, which indicates that the three sampled NEMT trips were provided to an escort ineligible to ride with the recipient. The issues we identified for the seven claims resulted in $927 of known questioned costs. In addition, we found the following problems resulting in $5,180,962 in likely questioned costs, which are estimated potential violations of federal requirements that we could not confirm due to a lack of documentation: ? $4.8 million paid for taxi claims without mileage. For 29,049 taxi claims totaling $4,763,071, the Department paid the claims without ensuring taxi providers were paid at their PUC per-mile rate. These claims were submitted directly to the Department by 10 permitted taxi providers. The Department required providers to submit claims showing only the number of one-way trips driven, not the number of miles driven. As a result, the Department could not ensure that these taxi claims were paid at the correct PUC rates, as required in its Billing Manual and Rate Schedule. The Department paid the full amount that each taxi provider requested, as long as the claim was not more than $1,000 per one-way trip. For example, the Department paid $4,000 to one taxi provider for a claim showing four one-way trips for a recipient on a single day. Based on the claim amount, the taxi provider would have had to have driven the recipient on four 400-mile, one-way trips that day to justify this amount, because the taxi provider?s PUC rate is $4 for the first mile and $2.50 for each additional mile. Since the Department did not obtain the miles driven for each one-way trip from taxi providers for these 29,049 claims, we could not determine whether the payments were accurate based on each provider?s PUC rate, as required. ? $409,575 paid for taxi claims for providers not permitted as taxis. For 3,284 NEMT claims for taxi services from eight providers, the providers were not permitted by the PUC to operate as taxis. For example, one provider was paid for an NEMT taxi claim for $5,875 for 12 trips, or $490 per trip. Since these providers were not permitted as taxis, they did not have PUC-set taxi rates, so we could not determine how much these providers should have been paid. ? $4,718 paid for trips that may not have been to attend medical services. As of April 2021, 13 of the 22 sampled NEMT claims (59 percent) for trips in December 2020 had no medical claims for dates corresponding to the NEMT trips. Department staff told us that Medicaid medical claims are typically submitted and paid within 3 months of the date of service, but that there is a possibility that medical providers had not yet submitted medical claims for the recipients since federal regulations technically allow providers up to 12 months to submit claims [42 CFR 447.45(d)(1)]. In addition, six of these 13 recipients had both Medicaid and other types of medical insurance, such as Medicare. According to the Department, it is possible that the six recipients used NEMT trips to access medical services but the Department did not have a Medicaid claim for the services because they were paid by the other types of insurance, which is allowed by state regulations [10 CCR 2505-10 8.014.5.B.2]. Therefore, we could not determine whether the NEMT trips associated with the 13 claims had been for recipients to attend medical services. ? $3,598 paid for trips that may not have been completed. For 61 of the 362,110 paid claims (less than 1 percent), the scheduled trips were not marked as complete in EcoLane, so we could not determine whether they had been completed. Why did these problems occur? The Department lacks effective internal controls over NEMT claims to ensure they are appropriate and consistently comply with federal and state requirements. According to federal regulations [2 CFR 200.303(a)], the Department, as a recipient of federal funds, must establish and maintain effective internal controls to provide reasonable assurance that federal funds are spent in compliance with federal requirements. We identified the following areas where Department controls are lacking for NEMT claims: Lack of Department information technology (IT) Controls in interChange ? No IT controls to prevent providers from bypassing broker. From December 2020 through February 2021, the Department paid NEMT providers directly for unsupported NEMT trips because the Department did not have IT controls in interChange to deny claims for trips that were not brokered through IntelliRide, as required at the time. As of September 1, 2021, the Department plans to require only the NEMT providers operating in nine metro-Denver counties to broker trips through IntelliRide, so the Department needs IT controls to ensure providers in these counties work with IntelliRide to schedule all trips and submit related claims. ? Lack of IT and other controls to ensure proper payments for NEMT taxi services. InterChange is programmed to pay each NEMT taxi claim based on one-way trips, but the Department has not implemented an IT or other control to ensure that NEMT taxi claims are paid at the providers? current PUC-approved per-mile rates, and that the Department only pays taxi rates when the provider is permitted by the PUC to operate as a taxi. Department staff stated that the only IT control the Department has built into interChange to help ensure proper payment of taxi claims is limiting payments for taxi claims to no more than $1,000 per one-way trip, and that this control is in accordance with the NEMT Billing Manual and Rate Schedule. However, Department staff also acknowledged that there is a conflict within the Billing Manual that requires taxi claims to be based on the number of one-way trips, but also paid based on per-mile PUC rates. By setting the limit based only on the number of one-way trips instead of providers? PUC per-mile rate, this Department IT control is not effective at ensuring taxi claims are paid properly. To ensure accurate payments for NEMT taxi claims, the Department will need methods, such as IT controls in interChange, and clarification in the Billing Manual and Rate Schedule, to ensure taxi providers are paid based on set rates, and ensure each taxi provider is permitted. ? No IT controls to ensure required prior authorizations. Air ambulance services were paid without the Department?s prior authorization for the services because the Department does not have IT controls to ensure prior authorization before payment. If the Department does not implement IT controls to ensure appropriate prior authorizations of NEMT services, the Department will need to develop manual processes to ensure that NEMT services receive required authorization prior to paying the related claims. Lack of Department Monitoring of NEMT Services and Claims ? Insufficient methods to ensure appropriate payment and collect necessary documentation from providers that bypass the statewide brokerage. Although the Department reviewed NEMT provider supporting documentation for NEMT services in 2019, the Department did not do so in 2020 or 2021, and had no process to require the providers that bypassed the statewide brokerage to submit documentation to support their NEMT claims before they were paid. According to the Department, in September 2021, it plans to require providers in nine counties covered by the IntelliRide brokerage contract to provide and submit claims through IntelliRide; however, NEMT providers in the remaining 55 counties will be submitting NEMT claims directly to the Department. Therefore, it is important that the Department develop a process to ensure that providers in these 55 counties maintain required documentation for each claim. ? Lack of monitoring to ensure Intelliride submits accurate mileage claims and collects necessary documentation. The Department does not conduct reviews of IntelliRide?s documentation in EcoLane to ensure it submits claims for accurate mileage and maintains support for claims submitted to or paid by the Department. For example, the Department does not reconcile its NEMT claims data from interChange and IntelliRide?s EcoLane system data to ensure each claim is supported. Furthermore, the Department has never completed a file review of IntelliRide?s supporting documentation for NEMT claims, such as when the Department contracted with IntelliRide to be a regional broker prior to becoming the statewide broker. ? No method to ensure NEMT service claims are for rides for medical treatment and the least costly. The Department does not conduct any reconciliation of its interChange data on NEMT trip claims to its interChange data on Medicaid medical claims to ensure NEMT claims are only paid for recipients to access medical care. The Department also does not require confirmation from medical providers that recipients used NEMT to access necessary medical care. For example, NEMT providers told us that before the start of the IntelliRide statewide brokerage contract, they either called medical providers to confirm that the recipients? NEMT trips were to access medical appointments or collected medical providers? signatures for each NEMT trip. In addition, the Department has no controls to ensure providers that submit claims directly to the Department are providing the least costly NEMT service appropriate to each recipient, such as public transportation when it is accessible and appropriate. For example, IntelliRide instructs its staff to attempt to schedule the lowest-cost NEMT service based on recipients? mobility needs and access to public transportation; however, the Department has no such method to ensure services are the least costly when NEMT providers schedule services for recipients. As of September 2021, the Department plans to have the recipients who live in the 55 counties not served by IntelliRide begin scheduling their rides directly with the NEMT providers of their choosing, yet the Department has not developed a method to ensure recipients in these areas receive the lowest-cost services appropriate for their needs. ? Potentially insufficient Department staffing to monitor NEMT claims effectively. For Fiscal Year 2021, the Department was appropriated three full-time equivalent (FTE) staff to oversee NEMT claims; however, the Department had two vacancies in these positions from July 2020 through May 2021 that it did not fill, so there was only one Department staff overseeing NEMT and the IntelliRide statewide contract during the audit time period. In June 2021, the Department added an additional FTE staff member to assist in administering the NEMT benefit. Why do these problems matter? Likely federal recovery of funds used for improper payments. Section 25.5-4-301(2), C.R.S., states that any overpayments of claims to providers are recoverable and ?are recoverable regardless of whether the overpayment is the result of an error by the state department? an entity acting on behalf of [the department], or the provider or any agent of the provider.? Our audit identified $291,597 in known questioned costs, of which about $145,797 is the federal portion of funds that the federal government may recover. We also identified $5,180,962 in likely questioned costs, of which $2,590,480 is the federal portion of funds that could be recovered if the payments are determined to have not been appropriate. The following table shows the questioned costs and federal portions for each problem we identified. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote When providers bypass broker controls, service quality is not monitored. When the Department allows some NEMT providers to bypass the IntelliRide broker, and does not obtain documentation to support their claims, the Department is unable to monitor the services of these providers. Additionally, when the Department does not monitor providers that bypass the statewide broker, the Department is applying different and possibly inadequate standards for the providers that bypass compared to the providers that work with IntelliRide. Although the Department plans for IntelliRide to no longer be the statewide NEMT broker for all 64 counties beginning September 2021, IntelliRide will continue to administer NEMT trips for nine Front Range counties that account for the majority of NEMT trips. It is important that all NEMT trips in these counties be brokered through IntelliRide so that the Department can monitor the quality of the trips and IntelliRide?s oversight of them. Risk of fraud, waste, and abuse. When the Department pays NEMT claims that are not supported by documentation of the service, medical documentation showing NEMT was for medical treatment, or the required prior authorizations, there is a significant risk of misappropriation of federal and state funds by providers and/or recipients. In addition, the eight providers not permitted as taxis that submitted taxi claims appear to have set their own rates of payment at a significantly higher rate, since the PUC did not permit or set rates for these providers. While we did not identify confirmed fraud by recipients or providers due to a lack of supporting documentation for claims, the problems identified demonstrate waste of public funds and potential abuse of the Medicaid program. When the Department overpays Medicaid funds and pays for unallowable services, there are fewer funds available to service the recipients who need them. In addition, there is no federal or state limit on payments for NEMT services, so it is important that the Department ensure Medicaid recipients receive appropriate transportation to medical treatment, while also ensuring the Department is acting as a good steward of federal and state funds. See Schedule of Findings and Questioned Costs for chart/table Character Limit Exceeded See Statewide Single Audit Report
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses and a Significant Deficiency were communicated to the Department of Health Care Policy and Financing (Department) in previous years and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-045 Payments for Non-Emergent Medical Transportation ClaimsPrior to July 2020, in 55 counties, the Department worked with various county offices to have them broker Non-Emergent Medical Transportation (NEMT) services for Medicaid recipients, including rides to and from Medicaid medical appointments, personal mileage reimbursement, and trip-related meals and lodging. For example, these counties arranged the rides with transportation providers, submitted the claims or had providers submit claims for reimbursement to the Department, and passed on reimbursements to providers as needed. For the remaining nine counties, the Department contracted with IntelliRide to serve as the NEMT broker for services in those areas. From July 1, 2020, to August 31, 2021, when the Department contracted with IntelliRide to be the statewide broker, most recipients throughout the state scheduled NEMT rides by contacting IntelliRide through its call center, website chat function, or smartphone applications. IntelliRide scheduled rides and assigned transportation providers to them, and had providers upload trip information into IntelliRide?s EcoLane transportation scheduling system. EcoLane maintains information related to recipients? requests for rides and provider trip information, such as the trip date and time, names of the recipient and driver, and scheduled pick-up and destination addresses. IntelliRide submitted claims through the Department?s interChange system (interChange) requesting payments for providers? NEMT services, paid providers for their services, and received reimbursement from the Department. In addition, the Department paid NEMT claims submitted directly by NEMT providers. In Fiscal Year 2021, from July 1, 2020, through February 28, 2021 (the audit period), the Department paid 362,110 claims for NEMT services totaling about $33.2 million, as shown in the following table. In September 2021, the Department plans to transition back to IntelliRide brokering services in nine counties, while the NEMT providers in the remaining counties will broker their own services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote What audit work was performed and how were the results measured? The purpose of the audit work was to determine whether the Department has ensured that NEMT claims adhere to the following federal and state requirements. ? NEMT trips were to be brokered through, and all claims submitted by, the statewide broker, Intelliride. According to state regulations and the Department?s NEMT Billing Manual, all NEMT trips during Fiscal Year 2021 had to be authorized by the statewide broker, IntelliRide [10 CCR 2505-10 8.014.7.A]. This means that each recipient?s NEMT ride request should have been sent to IntelliRide for approval or authorization before the trip, and any unauthorized trips should ?not be reimbursed or paid? [Billing Manual]. According to the Department, it allowed NEMT providers time to transition to working with IntelliRide because some providers were reluctant to join the statewide brokerage and the Department needed time to onboard providers. By Fall 2020, most providers should have been working with IntelliRide to schedule NEMT rides. The Department told us that six NEMT providers received its express permission to bypass IntelliRide to schedule rides and submit claims directly to the Department because the providers are unique, such as only serving recipients with disabilities or receiving federal grant funding to provide NEMT. To assess whether IntelliRide brokered most NEMT services in the State and submitted the related claims in line with regulations and its contract, we reviewed the Department?s aggregate data for the 128,998 NEMT claims paid from December 2020 through February 2021. ? The Department must pay claims based on accurate service rates and trip mileage. Non-taxi NEMT services, such as wheelchair and mobility vehicle services, have base rates and mileage rates set by the Department. IntelliRide tracks the mileage of each NEMT trip in EcoLane and submits mileage claims to the Department?s interChange system. The Public Utilities Commission (PUC) sets the rate for each permitted taxi provider, which generally includes a rate for the first trip mile and a different rate for each additional mile. According to the Department?s NEMT Billing Manual and NEMT Rate Schedule for Fiscal Year 2021, taxi claims should have been paid at the rate set by the PUC. For example, if a taxi company?s PUC rate was $4 for the first mile and $2 for each additional mile, the Department should have paid $6 for a two-mile NEMT trip claim. To verify that the Department paid NEMT claims based on the correct trip mileage and rates, we reviewed the trip mileage and rates for 362,110 NEMT claims paid from July 2020 through February 2021, and PUC documentation on the taxi rates for permitted taxi companies. ? Claims must be supported with accurate and complete documentation confirming the service provided. Both IntelliRide and providers that submit claims for NEMT services must keep and be able to furnish accurate, complete supporting documentation for all claims [42 USC 1396a(27), 42 CFR ?? 431.17 and 433.32, and 10 CCR 2505-10 8.014.3.C and 8.014.6.B]. For example, a claim must be supported by medical documentation showing that the type of vehicle was needed to transport the recipient, and documentation from the transportation provider showing the trip occurred and when the recipient was picked-up and dropped-off. IntelliRide should only submit a claim to the Department after IntelliRide confirms the trip has been completed and marks the status complete in EcoLane [IntelliRide Policies and Procedures]. If an NEMT provider does not show up for a trip, IntelliRide should mark the trip as ?cancelled? in EcoLane. Payments for Medicaid claims that lack supporting documentation for the services provided are unallowable, meaning they should not be paid. IntelliRide or the Department must maintain documentation from recipients? medical providers showing why certain NEMT services, like transportation in a wheelchair van or with an escort, are medically necessary [10 CCR 2505-10 8.014.7.B and 8.014.5.D.1; Billing Manual]. To verify that there was support for NEMT claims, we reviewed IntelliRide data in EcoLane for all 362,110 NEMT claims paid from July 2020 through February 2021, and Department documentation for a sample of 85 NEMT paid claims?75 selected randomly from the four NEMT service areas of the state, and 10 that were the highest paid NEMT claims. ? NEMT services must be medically necessary. NEMT services shall only be provided to recipients with no other means to attend medically necessary, non-emergency treatment covered by Medicaid [42 USC 1396a(70); 42 CFR 431.53; 10 CCR 2505-10 8.014.5.B]. To verify that NEMT claims were only paid for recipients to access medical care, we reviewed the Department?s data on paid medical claims to determine if the recipients related to 22 sampled NEMT claims paid in December 2020 had a corresponding medical appointment. For another 61 paid NEMT claims that involved IntelliRide scheduling and submitting claims for trips every day in December for two recipients, we reviewed whether the recipients had paid medical claims corresponding with the trips. ? Prior authorization is required for air ambulance. The Department must grant prior authorization for the use of an NEMT air ambulance before the trip occurs in order for the claim to be paid [10 CCR 2505-10 8.014.7.D.1.b]. To verify that the Department granted prior authorization for air ambulance trips, we reviewed the use of air ambulances in 11 paid claims from July 2020 to February 2021. ? Recipients are to receive the least-costly NEMT transportation option appropriate for their medical condition. For example, recipients should only ride in a vehicle for recipients with mobility needs when they have a mobility issue or if there is a lack of access to public transportation [10 CCR 2505-10 8.014.6.B, 42 USC 1396(a(70), and 42 CFR 440.170(a)(4)]. Higher-cost NEMT services, such as ambulance and wheelchair van services, must be supported with documentation of the recipient?s need for the specific higher-cost services [10 CCR 2505-10 8.014.5.B.1.b]. To determine whether recipients received the least costly NEMT services to meet their needs, we reviewed documentation submitted by medical or transportation providers to IntelliRide or the Department for the 85 sampled NEMT claims. ? Taxi providers must be permitted by the PUC to provide NEMT taxi rides. To provide NEMT rides by taxi and receive payment for them, the provider must maintain a common carrier permit issued by the PUC [10 CCR 2505-10 8.014.3.B.4.a]. To verify that the providers that were paid for taxi claims had been permitted to provide taxi services, we reviewed the 33,791 NEMT claims for taxi services from July 2020 to February 2021. What problems were identified? The Department paid $3.5 million directly to 66 NEMT providers for claims that were not brokered by Intelliride. From December 2020 through February 2021, 26,890 of the approximately 129,000 NEMT claims paid by the Department (21 percent), totaling about $3.5 million, were not brokered through IntelliRide, which violated state regulations requiring all NEMT services to be brokered through the statewide brokerage in effect at the time. The following chart shows the amounts the Department paid for claims submitted directly by NEMT providers compared to its payments for claims submitted by IntelliRide from July 2020 through February 2021. During these months, the number of claims that providers submitted directly to the Department decreased as providers transitioned to working with IntelliRide to broker NEMT rides; however, as of February 2021, the Department was still paying about $1 million in monthly claims that were submitted directly by providers. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote The Department paid 36,910 NEMT claims totaling $5.5 million, which either violated or may have violated federal and/or state regulations. The claims were for unallowable services or were overpaid, and resulted in $291,597 in known questioned costs and $5,180,962 in likely questioned costs for Medicaid. A questioned cost is a payment that ?resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds? or ?the costs, at the time of the audit, [that] are not supported by adequate documentation?? [2 CFR 200.84]. A known questioned cost reflects a violation that the auditor confirmed; a likely questioned cost is the auditor?s best estimate of a potential violation [2 CFR 200.516(a)(3)]. Known and likely questioned costs should be investigated by the Department and recovered, as appropriate, because Medicaid overpayments are recoverable regardless of whether they occurred due to an error by the Department, entity acting on behalf of the Department, or a provider [Section 25.5-4-301(2), C.R.S.]. We found the following problems resulting in $291,597 in known questioned costs: ? Claims paid with no support that services were provided. For 3,958 of the 362,110 NEMT claims (1 percent), which totaled $258,115 paid from July 2020 to February 2021, IntelliRide or providers submitted the claims without any documentation showing that recipients received the NEMT services from the providers listed in the claim. The $258,115 is known questioned costs and includes: o 3,323 claims totaling $163,985 submitted by IntelliRide with no documentation in EcoLane of a ride being scheduled or provided. o 619 claims totaling $61,431 submitted by IntelliRide for which EcoLane showed the scheduled ride was cancelled. o 16 sampled claims totaling $32,699 submitted by providers directly to the Department had no documentation that an NEMT service occurred because the providers did not send the Department documentation for their claims. Upon our request, the Department attempted to obtain supporting documentation from providers for these claims but was unable to obtain any. ? Overpayments due to incorrect mileage and taxi rates. For 466 of the 321,099 mileage and taxi claims (less than 1 percent), the Department overpaid IntelliRide. Specifically, for 50 of the 287,308 mileage claims (less than 1 percent), the mileage submitted by IntelliRide that the Department paid was more than the ride mileage that IntelliRide documented in EcoLane. For 416 of the 33,791 (1 percent) claims submitted by IntelliRide on behalf of providers that were permitted to operate as taxis, the Department paid a higher rate than the providers? set PUC rate. The following table breaks out the overpayments that we identified, which totaled $6,759 in known questioned costs. We did not find issues with the rate amounts that the Department paid for non-mileage and non-taxi services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Examples of these overpayments include: o An overpayment of $48 for a claim submitted by IntelliRide for a taxi provider that billed the wrong taxi rate. The Department paid $60 for a 4-mile trip, when it should have paid $12 based on the PUC rate of $3 per mile. o An overpayment of $79 for a claim submitted by IntelliRide on behalf of a provider because the claim showed the trip was 76 miles, but the EcoLane data showed the trip was 38 miles. The Department paid $157, when it should have paid $78. ? Unallowable rides, not for medical appointments. For 61 claims showing NEMT trips every day in December 2020 for two recipients, there were no medical claims corresponding to their trips, so it appears that either NEMT was used repeatedly to transport these recipients to unallowable destinations or the provider did not provide the trips claimed. The NEMT provider reported to IntelliRide that these trips were completed even though the recipients did not attend any medical appointments that month. IntelliRide submitted the 61 NEMT claims and its EcoLane data showed that the NEMT providers self-reported that the trips were completed. However, IntelliRide confirmed that these trips were not used to access medical care. The issues we identified resulted in $2,674 of known questioned costs. ? Air ambulance claims paid without prior authorization. None of the 11 air ambulance NEMT claims had supporting documentation that the provider requested or received prior authorization from the Department before the trip occurred. These 11 claims to three providers resulted in $23,122 in known questioned costs. ? Claims paid for trips that were not the least costly, medically necessary, and/or for approved escorts. For seven of the 85 sampled claims (8 percent), IntelliRide submitted the claims without having required documentation from medical providers. Specifically, four claims lacked documentation to support the medical necessity for the type of vehicle used (either mobility vehicle, taxi, or wheelchair van); the other three claims lacked documentation of the recipient?s need for an escort to support the associated cost, which indicates that the three sampled NEMT trips were provided to an escort ineligible to ride with the recipient. The issues we identified for the seven claims resulted in $927 of known questioned costs. In addition, we found the following problems resulting in $5,180,962 in likely questioned costs, which are estimated potential violations of federal requirements that we could not confirm due to a lack of documentation: ? $4.8 million paid for taxi claims without mileage. For 29,049 taxi claims totaling $4,763,071, the Department paid the claims without ensuring taxi providers were paid at their PUC per-mile rate. These claims were submitted directly to the Department by 10 permitted taxi providers. The Department required providers to submit claims showing only the number of one-way trips driven, not the number of miles driven. As a result, the Department could not ensure that these taxi claims were paid at the correct PUC rates, as required in its Billing Manual and Rate Schedule. The Department paid the full amount that each taxi provider requested, as long as the claim was not more than $1,000 per one-way trip. For example, the Department paid $4,000 to one taxi provider for a claim showing four one-way trips for a recipient on a single day. Based on the claim amount, the taxi provider would have had to have driven the recipient on four 400-mile, one-way trips that day to justify this amount, because the taxi provider?s PUC rate is $4 for the first mile and $2.50 for each additional mile. Since the Department did not obtain the miles driven for each one-way trip from taxi providers for these 29,049 claims, we could not determine whether the payments were accurate based on each provider?s PUC rate, as required. ? $409,575 paid for taxi claims for providers not permitted as taxis. For 3,284 NEMT claims for taxi services from eight providers, the providers were not permitted by the PUC to operate as taxis. For example, one provider was paid for an NEMT taxi claim for $5,875 for 12 trips, or $490 per trip. Since these providers were not permitted as taxis, they did not have PUC-set taxi rates, so we could not determine how much these providers should have been paid. ? $4,718 paid for trips that may not have been to attend medical services. As of April 2021, 13 of the 22 sampled NEMT claims (59 percent) for trips in December 2020 had no medical claims for dates corresponding to the NEMT trips. Department staff told us that Medicaid medical claims are typically submitted and paid within 3 months of the date of service, but that there is a possibility that medical providers had not yet submitted medical claims for the recipients since federal regulations technically allow providers up to 12 months to submit claims [42 CFR 447.45(d)(1)]. In addition, six of these 13 recipients had both Medicaid and other types of medical insurance, such as Medicare. According to the Department, it is possible that the six recipients used NEMT trips to access medical services but the Department did not have a Medicaid claim for the services because they were paid by the other types of insurance, which is allowed by state regulations [10 CCR 2505-10 8.014.5.B.2]. Therefore, we could not determine whether the NEMT trips associated with the 13 claims had been for recipients to attend medical services. ? $3,598 paid for trips that may not have been completed. For 61 of the 362,110 paid claims (less than 1 percent), the scheduled trips were not marked as complete in EcoLane, so we could not determine whether they had been completed. Why did these problems occur? The Department lacks effective internal controls over NEMT claims to ensure they are appropriate and consistently comply with federal and state requirements. According to federal regulations [2 CFR 200.303(a)], the Department, as a recipient of federal funds, must establish and maintain effective internal controls to provide reasonable assurance that federal funds are spent in compliance with federal requirements. We identified the following areas where Department controls are lacking for NEMT claims: Lack of Department information technology (IT) Controls in interChange ? No IT controls to prevent providers from bypassing broker. From December 2020 through February 2021, the Department paid NEMT providers directly for unsupported NEMT trips because the Department did not have IT controls in interChange to deny claims for trips that were not brokered through IntelliRide, as required at the time. As of September 1, 2021, the Department plans to require only the NEMT providers operating in nine metro-Denver counties to broker trips through IntelliRide, so the Department needs IT controls to ensure providers in these counties work with IntelliRide to schedule all trips and submit related claims. ? Lack of IT and other controls to ensure proper payments for NEMT taxi services. InterChange is programmed to pay each NEMT taxi claim based on one-way trips, but the Department has not implemented an IT or other control to ensure that NEMT taxi claims are paid at the providers? current PUC-approved per-mile rates, and that the Department only pays taxi rates when the provider is permitted by the PUC to operate as a taxi. Department staff stated that the only IT control the Department has built into interChange to help ensure proper payment of taxi claims is limiting payments for taxi claims to no more than $1,000 per one-way trip, and that this control is in accordance with the NEMT Billing Manual and Rate Schedule. However, Department staff also acknowledged that there is a conflict within the Billing Manual that requires taxi claims to be based on the number of one-way trips, but also paid based on per-mile PUC rates. By setting the limit based only on the number of one-way trips instead of providers? PUC per-mile rate, this Department IT control is not effective at ensuring taxi claims are paid properly. To ensure accurate payments for NEMT taxi claims, the Department will need methods, such as IT controls in interChange, and clarification in the Billing Manual and Rate Schedule, to ensure taxi providers are paid based on set rates, and ensure each taxi provider is permitted. ? No IT controls to ensure required prior authorizations. Air ambulance services were paid without the Department?s prior authorization for the services because the Department does not have IT controls to ensure prior authorization before payment. If the Department does not implement IT controls to ensure appropriate prior authorizations of NEMT services, the Department will need to develop manual processes to ensure that NEMT services receive required authorization prior to paying the related claims. Lack of Department Monitoring of NEMT Services and Claims ? Insufficient methods to ensure appropriate payment and collect necessary documentation from providers that bypass the statewide brokerage. Although the Department reviewed NEMT provider supporting documentation for NEMT services in 2019, the Department did not do so in 2020 or 2021, and had no process to require the providers that bypassed the statewide brokerage to submit documentation to support their NEMT claims before they were paid. According to the Department, in September 2021, it plans to require providers in nine counties covered by the IntelliRide brokerage contract to provide and submit claims through IntelliRide; however, NEMT providers in the remaining 55 counties will be submitting NEMT claims directly to the Department. Therefore, it is important that the Department develop a process to ensure that providers in these 55 counties maintain required documentation for each claim. ? Lack of monitoring to ensure Intelliride submits accurate mileage claims and collects necessary documentation. The Department does not conduct reviews of IntelliRide?s documentation in EcoLane to ensure it submits claims for accurate mileage and maintains support for claims submitted to or paid by the Department. For example, the Department does not reconcile its NEMT claims data from interChange and IntelliRide?s EcoLane system data to ensure each claim is supported. Furthermore, the Department has never completed a file review of IntelliRide?s supporting documentation for NEMT claims, such as when the Department contracted with IntelliRide to be a regional broker prior to becoming the statewide broker. ? No method to ensure NEMT service claims are for rides for medical treatment and the least costly. The Department does not conduct any reconciliation of its interChange data on NEMT trip claims to its interChange data on Medicaid medical claims to ensure NEMT claims are only paid for recipients to access medical care. The Department also does not require confirmation from medical providers that recipients used NEMT to access necessary medical care. For example, NEMT providers told us that before the start of the IntelliRide statewide brokerage contract, they either called medical providers to confirm that the recipients? NEMT trips were to access medical appointments or collected medical providers? signatures for each NEMT trip. In addition, the Department has no controls to ensure providers that submit claims directly to the Department are providing the least costly NEMT service appropriate to each recipient, such as public transportation when it is accessible and appropriate. For example, IntelliRide instructs its staff to attempt to schedule the lowest-cost NEMT service based on recipients? mobility needs and access to public transportation; however, the Department has no such method to ensure services are the least costly when NEMT providers schedule services for recipients. As of September 2021, the Department plans to have the recipients who live in the 55 counties not served by IntelliRide begin scheduling their rides directly with the NEMT providers of their choosing, yet the Department has not developed a method to ensure recipients in these areas receive the lowest-cost services appropriate for their needs. ? Potentially insufficient Department staffing to monitor NEMT claims effectively. For Fiscal Year 2021, the Department was appropriated three full-time equivalent (FTE) staff to oversee NEMT claims; however, the Department had two vacancies in these positions from July 2020 through May 2021 that it did not fill, so there was only one Department staff overseeing NEMT and the IntelliRide statewide contract during the audit time period. In June 2021, the Department added an additional FTE staff member to assist in administering the NEMT benefit. Why do these problems matter? Likely federal recovery of funds used for improper payments. Section 25.5-4-301(2), C.R.S., states that any overpayments of claims to providers are recoverable and ?are recoverable regardless of whether the overpayment is the result of an error by the state department? an entity acting on behalf of [the department], or the provider or any agent of the provider.? Our audit identified $291,597 in known questioned costs, of which about $145,797 is the federal portion of funds that the federal government may recover. We also identified $5,180,962 in likely questioned costs, of which $2,590,480 is the federal portion of funds that could be recovered if the payments are determined to have not been appropriate. The following table shows the questioned costs and federal portions for each problem we identified. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote When providers bypass broker controls, service quality is not monitored. When the Department allows some NEMT providers to bypass the IntelliRide broker, and does not obtain documentation to support their claims, the Department is unable to monitor the services of these providers. Additionally, when the Department does not monitor providers that bypass the statewide broker, the Department is applying different and possibly inadequate standards for the providers that bypass compared to the providers that work with IntelliRide. Although the Department plans for IntelliRide to no longer be the statewide NEMT broker for all 64 counties beginning September 2021, IntelliRide will continue to administer NEMT trips for nine Front Range counties that account for the majority of NEMT trips. It is important that all NEMT trips in these counties be brokered through IntelliRide so that the Department can monitor the quality of the trips and IntelliRide?s oversight of them. Risk of fraud, waste, and abuse. When the Department pays NEMT claims that are not supported by documentation of the service, medical documentation showing NEMT was for medical treatment, or the required prior authorizations, there is a significant risk of misappropriation of federal and state funds by providers and/or recipients. In addition, the eight providers not permitted as taxis that submitted taxi claims appear to have set their own rates of payment at a significantly higher rate, since the PUC did not permit or set rates for these providers. While we did not identify confirmed fraud by recipients or providers due to a lack of supporting documentation for claims, the problems identified demonstrate waste of public funds and potential abuse of the Medicaid program. When the Department overpays Medicaid funds and pays for unallowable services, there are fewer funds available to service the recipients who need them. In addition, there is no federal or state limit on payments for NEMT services, so it is important that the Department ensure Medicaid recipients receive appropriate transportation to medical treatment, while also ensuring the Department is acting as a good steward of federal and state funds. See Schedule of Findings and Questioned Costs for chart/table Character Limit Exceeded See Statewide Single Audit Report
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses and a Significant Deficiency were communicated to the Department of Health Care Policy and Financing (Department) in previous years and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-045 Payments for Non-Emergent Medical Transportation ClaimsPrior to July 2020, in 55 counties, the Department worked with various county offices to have them broker Non-Emergent Medical Transportation (NEMT) services for Medicaid recipients, including rides to and from Medicaid medical appointments, personal mileage reimbursement, and trip-related meals and lodging. For example, these counties arranged the rides with transportation providers, submitted the claims or had providers submit claims for reimbursement to the Department, and passed on reimbursements to providers as needed. For the remaining nine counties, the Department contracted with IntelliRide to serve as the NEMT broker for services in those areas. From July 1, 2020, to August 31, 2021, when the Department contracted with IntelliRide to be the statewide broker, most recipients throughout the state scheduled NEMT rides by contacting IntelliRide through its call center, website chat function, or smartphone applications. IntelliRide scheduled rides and assigned transportation providers to them, and had providers upload trip information into IntelliRide?s EcoLane transportation scheduling system. EcoLane maintains information related to recipients? requests for rides and provider trip information, such as the trip date and time, names of the recipient and driver, and scheduled pick-up and destination addresses. IntelliRide submitted claims through the Department?s interChange system (interChange) requesting payments for providers? NEMT services, paid providers for their services, and received reimbursement from the Department. In addition, the Department paid NEMT claims submitted directly by NEMT providers. In Fiscal Year 2021, from July 1, 2020, through February 28, 2021 (the audit period), the Department paid 362,110 claims for NEMT services totaling about $33.2 million, as shown in the following table. In September 2021, the Department plans to transition back to IntelliRide brokering services in nine counties, while the NEMT providers in the remaining counties will broker their own services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote What audit work was performed and how were the results measured? The purpose of the audit work was to determine whether the Department has ensured that NEMT claims adhere to the following federal and state requirements. ? NEMT trips were to be brokered through, and all claims submitted by, the statewide broker, Intelliride. According to state regulations and the Department?s NEMT Billing Manual, all NEMT trips during Fiscal Year 2021 had to be authorized by the statewide broker, IntelliRide [10 CCR 2505-10 8.014.7.A]. This means that each recipient?s NEMT ride request should have been sent to IntelliRide for approval or authorization before the trip, and any unauthorized trips should ?not be reimbursed or paid? [Billing Manual]. According to the Department, it allowed NEMT providers time to transition to working with IntelliRide because some providers were reluctant to join the statewide brokerage and the Department needed time to onboard providers. By Fall 2020, most providers should have been working with IntelliRide to schedule NEMT rides. The Department told us that six NEMT providers received its express permission to bypass IntelliRide to schedule rides and submit claims directly to the Department because the providers are unique, such as only serving recipients with disabilities or receiving federal grant funding to provide NEMT. To assess whether IntelliRide brokered most NEMT services in the State and submitted the related claims in line with regulations and its contract, we reviewed the Department?s aggregate data for the 128,998 NEMT claims paid from December 2020 through February 2021. ? The Department must pay claims based on accurate service rates and trip mileage. Non-taxi NEMT services, such as wheelchair and mobility vehicle services, have base rates and mileage rates set by the Department. IntelliRide tracks the mileage of each NEMT trip in EcoLane and submits mileage claims to the Department?s interChange system. The Public Utilities Commission (PUC) sets the rate for each permitted taxi provider, which generally includes a rate for the first trip mile and a different rate for each additional mile. According to the Department?s NEMT Billing Manual and NEMT Rate Schedule for Fiscal Year 2021, taxi claims should have been paid at the rate set by the PUC. For example, if a taxi company?s PUC rate was $4 for the first mile and $2 for each additional mile, the Department should have paid $6 for a two-mile NEMT trip claim. To verify that the Department paid NEMT claims based on the correct trip mileage and rates, we reviewed the trip mileage and rates for 362,110 NEMT claims paid from July 2020 through February 2021, and PUC documentation on the taxi rates for permitted taxi companies. ? Claims must be supported with accurate and complete documentation confirming the service provided. Both IntelliRide and providers that submit claims for NEMT services must keep and be able to furnish accurate, complete supporting documentation for all claims [42 USC 1396a(27), 42 CFR ?? 431.17 and 433.32, and 10 CCR 2505-10 8.014.3.C and 8.014.6.B]. For example, a claim must be supported by medical documentation showing that the type of vehicle was needed to transport the recipient, and documentation from the transportation provider showing the trip occurred and when the recipient was picked-up and dropped-off. IntelliRide should only submit a claim to the Department after IntelliRide confirms the trip has been completed and marks the status complete in EcoLane [IntelliRide Policies and Procedures]. If an NEMT provider does not show up for a trip, IntelliRide should mark the trip as ?cancelled? in EcoLane. Payments for Medicaid claims that lack supporting documentation for the services provided are unallowable, meaning they should not be paid. IntelliRide or the Department must maintain documentation from recipients? medical providers showing why certain NEMT services, like transportation in a wheelchair van or with an escort, are medically necessary [10 CCR 2505-10 8.014.7.B and 8.014.5.D.1; Billing Manual]. To verify that there was support for NEMT claims, we reviewed IntelliRide data in EcoLane for all 362,110 NEMT claims paid from July 2020 through February 2021, and Department documentation for a sample of 85 NEMT paid claims?75 selected randomly from the four NEMT service areas of the state, and 10 that were the highest paid NEMT claims. ? NEMT services must be medically necessary. NEMT services shall only be provided to recipients with no other means to attend medically necessary, non-emergency treatment covered by Medicaid [42 USC 1396a(70); 42 CFR 431.53; 10 CCR 2505-10 8.014.5.B]. To verify that NEMT claims were only paid for recipients to access medical care, we reviewed the Department?s data on paid medical claims to determine if the recipients related to 22 sampled NEMT claims paid in December 2020 had a corresponding medical appointment. For another 61 paid NEMT claims that involved IntelliRide scheduling and submitting claims for trips every day in December for two recipients, we reviewed whether the recipients had paid medical claims corresponding with the trips. ? Prior authorization is required for air ambulance. The Department must grant prior authorization for the use of an NEMT air ambulance before the trip occurs in order for the claim to be paid [10 CCR 2505-10 8.014.7.D.1.b]. To verify that the Department granted prior authorization for air ambulance trips, we reviewed the use of air ambulances in 11 paid claims from July 2020 to February 2021. ? Recipients are to receive the least-costly NEMT transportation option appropriate for their medical condition. For example, recipients should only ride in a vehicle for recipients with mobility needs when they have a mobility issue or if there is a lack of access to public transportation [10 CCR 2505-10 8.014.6.B, 42 USC 1396(a(70), and 42 CFR 440.170(a)(4)]. Higher-cost NEMT services, such as ambulance and wheelchair van services, must be supported with documentation of the recipient?s need for the specific higher-cost services [10 CCR 2505-10 8.014.5.B.1.b]. To determine whether recipients received the least costly NEMT services to meet their needs, we reviewed documentation submitted by medical or transportation providers to IntelliRide or the Department for the 85 sampled NEMT claims. ? Taxi providers must be permitted by the PUC to provide NEMT taxi rides. To provide NEMT rides by taxi and receive payment for them, the provider must maintain a common carrier permit issued by the PUC [10 CCR 2505-10 8.014.3.B.4.a]. To verify that the providers that were paid for taxi claims had been permitted to provide taxi services, we reviewed the 33,791 NEMT claims for taxi services from July 2020 to February 2021. What problems were identified? The Department paid $3.5 million directly to 66 NEMT providers for claims that were not brokered by Intelliride. From December 2020 through February 2021, 26,890 of the approximately 129,000 NEMT claims paid by the Department (21 percent), totaling about $3.5 million, were not brokered through IntelliRide, which violated state regulations requiring all NEMT services to be brokered through the statewide brokerage in effect at the time. The following chart shows the amounts the Department paid for claims submitted directly by NEMT providers compared to its payments for claims submitted by IntelliRide from July 2020 through February 2021. During these months, the number of claims that providers submitted directly to the Department decreased as providers transitioned to working with IntelliRide to broker NEMT rides; however, as of February 2021, the Department was still paying about $1 million in monthly claims that were submitted directly by providers. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote The Department paid 36,910 NEMT claims totaling $5.5 million, which either violated or may have violated federal and/or state regulations. The claims were for unallowable services or were overpaid, and resulted in $291,597 in known questioned costs and $5,180,962 in likely questioned costs for Medicaid. A questioned cost is a payment that ?resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds? or ?the costs, at the time of the audit, [that] are not supported by adequate documentation?? [2 CFR 200.84]. A known questioned cost reflects a violation that the auditor confirmed; a likely questioned cost is the auditor?s best estimate of a potential violation [2 CFR 200.516(a)(3)]. Known and likely questioned costs should be investigated by the Department and recovered, as appropriate, because Medicaid overpayments are recoverable regardless of whether they occurred due to an error by the Department, entity acting on behalf of the Department, or a provider [Section 25.5-4-301(2), C.R.S.]. We found the following problems resulting in $291,597 in known questioned costs: ? Claims paid with no support that services were provided. For 3,958 of the 362,110 NEMT claims (1 percent), which totaled $258,115 paid from July 2020 to February 2021, IntelliRide or providers submitted the claims without any documentation showing that recipients received the NEMT services from the providers listed in the claim. The $258,115 is known questioned costs and includes: o 3,323 claims totaling $163,985 submitted by IntelliRide with no documentation in EcoLane of a ride being scheduled or provided. o 619 claims totaling $61,431 submitted by IntelliRide for which EcoLane showed the scheduled ride was cancelled. o 16 sampled claims totaling $32,699 submitted by providers directly to the Department had no documentation that an NEMT service occurred because the providers did not send the Department documentation for their claims. Upon our request, the Department attempted to obtain supporting documentation from providers for these claims but was unable to obtain any. ? Overpayments due to incorrect mileage and taxi rates. For 466 of the 321,099 mileage and taxi claims (less than 1 percent), the Department overpaid IntelliRide. Specifically, for 50 of the 287,308 mileage claims (less than 1 percent), the mileage submitted by IntelliRide that the Department paid was more than the ride mileage that IntelliRide documented in EcoLane. For 416 of the 33,791 (1 percent) claims submitted by IntelliRide on behalf of providers that were permitted to operate as taxis, the Department paid a higher rate than the providers? set PUC rate. The following table breaks out the overpayments that we identified, which totaled $6,759 in known questioned costs. We did not find issues with the rate amounts that the Department paid for non-mileage and non-taxi services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Examples of these overpayments include: o An overpayment of $48 for a claim submitted by IntelliRide for a taxi provider that billed the wrong taxi rate. The Department paid $60 for a 4-mile trip, when it should have paid $12 based on the PUC rate of $3 per mile. o An overpayment of $79 for a claim submitted by IntelliRide on behalf of a provider because the claim showed the trip was 76 miles, but the EcoLane data showed the trip was 38 miles. The Department paid $157, when it should have paid $78. ? Unallowable rides, not for medical appointments. For 61 claims showing NEMT trips every day in December 2020 for two recipients, there were no medical claims corresponding to their trips, so it appears that either NEMT was used repeatedly to transport these recipients to unallowable destinations or the provider did not provide the trips claimed. The NEMT provider reported to IntelliRide that these trips were completed even though the recipients did not attend any medical appointments that month. IntelliRide submitted the 61 NEMT claims and its EcoLane data showed that the NEMT providers self-reported that the trips were completed. However, IntelliRide confirmed that these trips were not used to access medical care. The issues we identified resulted in $2,674 of known questioned costs. ? Air ambulance claims paid without prior authorization. None of the 11 air ambulance NEMT claims had supporting documentation that the provider requested or received prior authorization from the Department before the trip occurred. These 11 claims to three providers resulted in $23,122 in known questioned costs. ? Claims paid for trips that were not the least costly, medically necessary, and/or for approved escorts. For seven of the 85 sampled claims (8 percent), IntelliRide submitted the claims without having required documentation from medical providers. Specifically, four claims lacked documentation to support the medical necessity for the type of vehicle used (either mobility vehicle, taxi, or wheelchair van); the other three claims lacked documentation of the recipient?s need for an escort to support the associated cost, which indicates that the three sampled NEMT trips were provided to an escort ineligible to ride with the recipient. The issues we identified for the seven claims resulted in $927 of known questioned costs. In addition, we found the following problems resulting in $5,180,962 in likely questioned costs, which are estimated potential violations of federal requirements that we could not confirm due to a lack of documentation: ? $4.8 million paid for taxi claims without mileage. For 29,049 taxi claims totaling $4,763,071, the Department paid the claims without ensuring taxi providers were paid at their PUC per-mile rate. These claims were submitted directly to the Department by 10 permitted taxi providers. The Department required providers to submit claims showing only the number of one-way trips driven, not the number of miles driven. As a result, the Department could not ensure that these taxi claims were paid at the correct PUC rates, as required in its Billing Manual and Rate Schedule. The Department paid the full amount that each taxi provider requested, as long as the claim was not more than $1,000 per one-way trip. For example, the Department paid $4,000 to one taxi provider for a claim showing four one-way trips for a recipient on a single day. Based on the claim amount, the taxi provider would have had to have driven the recipient on four 400-mile, one-way trips that day to justify this amount, because the taxi provider?s PUC rate is $4 for the first mile and $2.50 for each additional mile. Since the Department did not obtain the miles driven for each one-way trip from taxi providers for these 29,049 claims, we could not determine whether the payments were accurate based on each provider?s PUC rate, as required. ? $409,575 paid for taxi claims for providers not permitted as taxis. For 3,284 NEMT claims for taxi services from eight providers, the providers were not permitted by the PUC to operate as taxis. For example, one provider was paid for an NEMT taxi claim for $5,875 for 12 trips, or $490 per trip. Since these providers were not permitted as taxis, they did not have PUC-set taxi rates, so we could not determine how much these providers should have been paid. ? $4,718 paid for trips that may not have been to attend medical services. As of April 2021, 13 of the 22 sampled NEMT claims (59 percent) for trips in December 2020 had no medical claims for dates corresponding to the NEMT trips. Department staff told us that Medicaid medical claims are typically submitted and paid within 3 months of the date of service, but that there is a possibility that medical providers had not yet submitted medical claims for the recipients since federal regulations technically allow providers up to 12 months to submit claims [42 CFR 447.45(d)(1)]. In addition, six of these 13 recipients had both Medicaid and other types of medical insurance, such as Medicare. According to the Department, it is possible that the six recipients used NEMT trips to access medical services but the Department did not have a Medicaid claim for the services because they were paid by the other types of insurance, which is allowed by state regulations [10 CCR 2505-10 8.014.5.B.2]. Therefore, we could not determine whether the NEMT trips associated with the 13 claims had been for recipients to attend medical services. ? $3,598 paid for trips that may not have been completed. For 61 of the 362,110 paid claims (less than 1 percent), the scheduled trips were not marked as complete in EcoLane, so we could not determine whether they had been completed. Why did these problems occur? The Department lacks effective internal controls over NEMT claims to ensure they are appropriate and consistently comply with federal and state requirements. According to federal regulations [2 CFR 200.303(a)], the Department, as a recipient of federal funds, must establish and maintain effective internal controls to provide reasonable assurance that federal funds are spent in compliance with federal requirements. We identified the following areas where Department controls are lacking for NEMT claims: Lack of Department information technology (IT) Controls in interChange ? No IT controls to prevent providers from bypassing broker. From December 2020 through February 2021, the Department paid NEMT providers directly for unsupported NEMT trips because the Department did not have IT controls in interChange to deny claims for trips that were not brokered through IntelliRide, as required at the time. As of September 1, 2021, the Department plans to require only the NEMT providers operating in nine metro-Denver counties to broker trips through IntelliRide, so the Department needs IT controls to ensure providers in these counties work with IntelliRide to schedule all trips and submit related claims. ? Lack of IT and other controls to ensure proper payments for NEMT taxi services. InterChange is programmed to pay each NEMT taxi claim based on one-way trips, but the Department has not implemented an IT or other control to ensure that NEMT taxi claims are paid at the providers? current PUC-approved per-mile rates, and that the Department only pays taxi rates when the provider is permitted by the PUC to operate as a taxi. Department staff stated that the only IT control the Department has built into interChange to help ensure proper payment of taxi claims is limiting payments for taxi claims to no more than $1,000 per one-way trip, and that this control is in accordance with the NEMT Billing Manual and Rate Schedule. However, Department staff also acknowledged that there is a conflict within the Billing Manual that requires taxi claims to be based on the number of one-way trips, but also paid based on per-mile PUC rates. By setting the limit based only on the number of one-way trips instead of providers? PUC per-mile rate, this Department IT control is not effective at ensuring taxi claims are paid properly. To ensure accurate payments for NEMT taxi claims, the Department will need methods, such as IT controls in interChange, and clarification in the Billing Manual and Rate Schedule, to ensure taxi providers are paid based on set rates, and ensure each taxi provider is permitted. ? No IT controls to ensure required prior authorizations. Air ambulance services were paid without the Department?s prior authorization for the services because the Department does not have IT controls to ensure prior authorization before payment. If the Department does not implement IT controls to ensure appropriate prior authorizations of NEMT services, the Department will need to develop manual processes to ensure that NEMT services receive required authorization prior to paying the related claims. Lack of Department Monitoring of NEMT Services and Claims ? Insufficient methods to ensure appropriate payment and collect necessary documentation from providers that bypass the statewide brokerage. Although the Department reviewed NEMT provider supporting documentation for NEMT services in 2019, the Department did not do so in 2020 or 2021, and had no process to require the providers that bypassed the statewide brokerage to submit documentation to support their NEMT claims before they were paid. According to the Department, in September 2021, it plans to require providers in nine counties covered by the IntelliRide brokerage contract to provide and submit claims through IntelliRide; however, NEMT providers in the remaining 55 counties will be submitting NEMT claims directly to the Department. Therefore, it is important that the Department develop a process to ensure that providers in these 55 counties maintain required documentation for each claim. ? Lack of monitoring to ensure Intelliride submits accurate mileage claims and collects necessary documentation. The Department does not conduct reviews of IntelliRide?s documentation in EcoLane to ensure it submits claims for accurate mileage and maintains support for claims submitted to or paid by the Department. For example, the Department does not reconcile its NEMT claims data from interChange and IntelliRide?s EcoLane system data to ensure each claim is supported. Furthermore, the Department has never completed a file review of IntelliRide?s supporting documentation for NEMT claims, such as when the Department contracted with IntelliRide to be a regional broker prior to becoming the statewide broker. ? No method to ensure NEMT service claims are for rides for medical treatment and the least costly. The Department does not conduct any reconciliation of its interChange data on NEMT trip claims to its interChange data on Medicaid medical claims to ensure NEMT claims are only paid for recipients to access medical care. The Department also does not require confirmation from medical providers that recipients used NEMT to access necessary medical care. For example, NEMT providers told us that before the start of the IntelliRide statewide brokerage contract, they either called medical providers to confirm that the recipients? NEMT trips were to access medical appointments or collected medical providers? signatures for each NEMT trip. In addition, the Department has no controls to ensure providers that submit claims directly to the Department are providing the least costly NEMT service appropriate to each recipient, such as public transportation when it is accessible and appropriate. For example, IntelliRide instructs its staff to attempt to schedule the lowest-cost NEMT service based on recipients? mobility needs and access to public transportation; however, the Department has no such method to ensure services are the least costly when NEMT providers schedule services for recipients. As of September 2021, the Department plans to have the recipients who live in the 55 counties not served by IntelliRide begin scheduling their rides directly with the NEMT providers of their choosing, yet the Department has not developed a method to ensure recipients in these areas receive the lowest-cost services appropriate for their needs. ? Potentially insufficient Department staffing to monitor NEMT claims effectively. For Fiscal Year 2021, the Department was appropriated three full-time equivalent (FTE) staff to oversee NEMT claims; however, the Department had two vacancies in these positions from July 2020 through May 2021 that it did not fill, so there was only one Department staff overseeing NEMT and the IntelliRide statewide contract during the audit time period. In June 2021, the Department added an additional FTE staff member to assist in administering the NEMT benefit. Why do these problems matter? Likely federal recovery of funds used for improper payments. Section 25.5-4-301(2), C.R.S., states that any overpayments of claims to providers are recoverable and ?are recoverable regardless of whether the overpayment is the result of an error by the state department? an entity acting on behalf of [the department], or the provider or any agent of the provider.? Our audit identified $291,597 in known questioned costs, of which about $145,797 is the federal portion of funds that the federal government may recover. We also identified $5,180,962 in likely questioned costs, of which $2,590,480 is the federal portion of funds that could be recovered if the payments are determined to have not been appropriate. The following table shows the questioned costs and federal portions for each problem we identified. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote When providers bypass broker controls, service quality is not monitored. When the Department allows some NEMT providers to bypass the IntelliRide broker, and does not obtain documentation to support their claims, the Department is unable to monitor the services of these providers. Additionally, when the Department does not monitor providers that bypass the statewide broker, the Department is applying different and possibly inadequate standards for the providers that bypass compared to the providers that work with IntelliRide. Although the Department plans for IntelliRide to no longer be the statewide NEMT broker for all 64 counties beginning September 2021, IntelliRide will continue to administer NEMT trips for nine Front Range counties that account for the majority of NEMT trips. It is important that all NEMT trips in these counties be brokered through IntelliRide so that the Department can monitor the quality of the trips and IntelliRide?s oversight of them. Risk of fraud, waste, and abuse. When the Department pays NEMT claims that are not supported by documentation of the service, medical documentation showing NEMT was for medical treatment, or the required prior authorizations, there is a significant risk of misappropriation of federal and state funds by providers and/or recipients. In addition, the eight providers not permitted as taxis that submitted taxi claims appear to have set their own rates of payment at a significantly higher rate, since the PUC did not permit or set rates for these providers. While we did not identify confirmed fraud by recipients or providers due to a lack of supporting documentation for claims, the problems identified demonstrate waste of public funds and potential abuse of the Medicaid program. When the Department overpays Medicaid funds and pays for unallowable services, there are fewer funds available to service the recipients who need them. In addition, there is no federal or state limit on payments for NEMT services, so it is important that the Department ensure Medicaid recipients receive appropriate transportation to medical treatment, while also ensuring the Department is acting as a good steward of federal and state funds. See Schedule of Findings and Questioned Costs for chart/table Character Limit Exceeded See Statewide Single Audit Report
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses and a Significant Deficiency were communicated to the Department of Health Care Policy and Financing (Department) in previous years and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-045 Payments for Non-Emergent Medical Transportation ClaimsPrior to July 2020, in 55 counties, the Department worked with various county offices to have them broker Non-Emergent Medical Transportation (NEMT) services for Medicaid recipients, including rides to and from Medicaid medical appointments, personal mileage reimbursement, and trip-related meals and lodging. For example, these counties arranged the rides with transportation providers, submitted the claims or had providers submit claims for reimbursement to the Department, and passed on reimbursements to providers as needed. For the remaining nine counties, the Department contracted with IntelliRide to serve as the NEMT broker for services in those areas. From July 1, 2020, to August 31, 2021, when the Department contracted with IntelliRide to be the statewide broker, most recipients throughout the state scheduled NEMT rides by contacting IntelliRide through its call center, website chat function, or smartphone applications. IntelliRide scheduled rides and assigned transportation providers to them, and had providers upload trip information into IntelliRide?s EcoLane transportation scheduling system. EcoLane maintains information related to recipients? requests for rides and provider trip information, such as the trip date and time, names of the recipient and driver, and scheduled pick-up and destination addresses. IntelliRide submitted claims through the Department?s interChange system (interChange) requesting payments for providers? NEMT services, paid providers for their services, and received reimbursement from the Department. In addition, the Department paid NEMT claims submitted directly by NEMT providers. In Fiscal Year 2021, from July 1, 2020, through February 28, 2021 (the audit period), the Department paid 362,110 claims for NEMT services totaling about $33.2 million, as shown in the following table. In September 2021, the Department plans to transition back to IntelliRide brokering services in nine counties, while the NEMT providers in the remaining counties will broker their own services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote What audit work was performed and how were the results measured? The purpose of the audit work was to determine whether the Department has ensured that NEMT claims adhere to the following federal and state requirements. ? NEMT trips were to be brokered through, and all claims submitted by, the statewide broker, Intelliride. According to state regulations and the Department?s NEMT Billing Manual, all NEMT trips during Fiscal Year 2021 had to be authorized by the statewide broker, IntelliRide [10 CCR 2505-10 8.014.7.A]. This means that each recipient?s NEMT ride request should have been sent to IntelliRide for approval or authorization before the trip, and any unauthorized trips should ?not be reimbursed or paid? [Billing Manual]. According to the Department, it allowed NEMT providers time to transition to working with IntelliRide because some providers were reluctant to join the statewide brokerage and the Department needed time to onboard providers. By Fall 2020, most providers should have been working with IntelliRide to schedule NEMT rides. The Department told us that six NEMT providers received its express permission to bypass IntelliRide to schedule rides and submit claims directly to the Department because the providers are unique, such as only serving recipients with disabilities or receiving federal grant funding to provide NEMT. To assess whether IntelliRide brokered most NEMT services in the State and submitted the related claims in line with regulations and its contract, we reviewed the Department?s aggregate data for the 128,998 NEMT claims paid from December 2020 through February 2021. ? The Department must pay claims based on accurate service rates and trip mileage. Non-taxi NEMT services, such as wheelchair and mobility vehicle services, have base rates and mileage rates set by the Department. IntelliRide tracks the mileage of each NEMT trip in EcoLane and submits mileage claims to the Department?s interChange system. The Public Utilities Commission (PUC) sets the rate for each permitted taxi provider, which generally includes a rate for the first trip mile and a different rate for each additional mile. According to the Department?s NEMT Billing Manual and NEMT Rate Schedule for Fiscal Year 2021, taxi claims should have been paid at the rate set by the PUC. For example, if a taxi company?s PUC rate was $4 for the first mile and $2 for each additional mile, the Department should have paid $6 for a two-mile NEMT trip claim. To verify that the Department paid NEMT claims based on the correct trip mileage and rates, we reviewed the trip mileage and rates for 362,110 NEMT claims paid from July 2020 through February 2021, and PUC documentation on the taxi rates for permitted taxi companies. ? Claims must be supported with accurate and complete documentation confirming the service provided. Both IntelliRide and providers that submit claims for NEMT services must keep and be able to furnish accurate, complete supporting documentation for all claims [42 USC 1396a(27), 42 CFR ?? 431.17 and 433.32, and 10 CCR 2505-10 8.014.3.C and 8.014.6.B]. For example, a claim must be supported by medical documentation showing that the type of vehicle was needed to transport the recipient, and documentation from the transportation provider showing the trip occurred and when the recipient was picked-up and dropped-off. IntelliRide should only submit a claim to the Department after IntelliRide confirms the trip has been completed and marks the status complete in EcoLane [IntelliRide Policies and Procedures]. If an NEMT provider does not show up for a trip, IntelliRide should mark the trip as ?cancelled? in EcoLane. Payments for Medicaid claims that lack supporting documentation for the services provided are unallowable, meaning they should not be paid. IntelliRide or the Department must maintain documentation from recipients? medical providers showing why certain NEMT services, like transportation in a wheelchair van or with an escort, are medically necessary [10 CCR 2505-10 8.014.7.B and 8.014.5.D.1; Billing Manual]. To verify that there was support for NEMT claims, we reviewed IntelliRide data in EcoLane for all 362,110 NEMT claims paid from July 2020 through February 2021, and Department documentation for a sample of 85 NEMT paid claims?75 selected randomly from the four NEMT service areas of the state, and 10 that were the highest paid NEMT claims. ? NEMT services must be medically necessary. NEMT services shall only be provided to recipients with no other means to attend medically necessary, non-emergency treatment covered by Medicaid [42 USC 1396a(70); 42 CFR 431.53; 10 CCR 2505-10 8.014.5.B]. To verify that NEMT claims were only paid for recipients to access medical care, we reviewed the Department?s data on paid medical claims to determine if the recipients related to 22 sampled NEMT claims paid in December 2020 had a corresponding medical appointment. For another 61 paid NEMT claims that involved IntelliRide scheduling and submitting claims for trips every day in December for two recipients, we reviewed whether the recipients had paid medical claims corresponding with the trips. ? Prior authorization is required for air ambulance. The Department must grant prior authorization for the use of an NEMT air ambulance before the trip occurs in order for the claim to be paid [10 CCR 2505-10 8.014.7.D.1.b]. To verify that the Department granted prior authorization for air ambulance trips, we reviewed the use of air ambulances in 11 paid claims from July 2020 to February 2021. ? Recipients are to receive the least-costly NEMT transportation option appropriate for their medical condition. For example, recipients should only ride in a vehicle for recipients with mobility needs when they have a mobility issue or if there is a lack of access to public transportation [10 CCR 2505-10 8.014.6.B, 42 USC 1396(a(70), and 42 CFR 440.170(a)(4)]. Higher-cost NEMT services, such as ambulance and wheelchair van services, must be supported with documentation of the recipient?s need for the specific higher-cost services [10 CCR 2505-10 8.014.5.B.1.b]. To determine whether recipients received the least costly NEMT services to meet their needs, we reviewed documentation submitted by medical or transportation providers to IntelliRide or the Department for the 85 sampled NEMT claims. ? Taxi providers must be permitted by the PUC to provide NEMT taxi rides. To provide NEMT rides by taxi and receive payment for them, the provider must maintain a common carrier permit issued by the PUC [10 CCR 2505-10 8.014.3.B.4.a]. To verify that the providers that were paid for taxi claims had been permitted to provide taxi services, we reviewed the 33,791 NEMT claims for taxi services from July 2020 to February 2021. What problems were identified? The Department paid $3.5 million directly to 66 NEMT providers for claims that were not brokered by Intelliride. From December 2020 through February 2021, 26,890 of the approximately 129,000 NEMT claims paid by the Department (21 percent), totaling about $3.5 million, were not brokered through IntelliRide, which violated state regulations requiring all NEMT services to be brokered through the statewide brokerage in effect at the time. The following chart shows the amounts the Department paid for claims submitted directly by NEMT providers compared to its payments for claims submitted by IntelliRide from July 2020 through February 2021. During these months, the number of claims that providers submitted directly to the Department decreased as providers transitioned to working with IntelliRide to broker NEMT rides; however, as of February 2021, the Department was still paying about $1 million in monthly claims that were submitted directly by providers. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote The Department paid 36,910 NEMT claims totaling $5.5 million, which either violated or may have violated federal and/or state regulations. The claims were for unallowable services or were overpaid, and resulted in $291,597 in known questioned costs and $5,180,962 in likely questioned costs for Medicaid. A questioned cost is a payment that ?resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds? or ?the costs, at the time of the audit, [that] are not supported by adequate documentation?? [2 CFR 200.84]. A known questioned cost reflects a violation that the auditor confirmed; a likely questioned cost is the auditor?s best estimate of a potential violation [2 CFR 200.516(a)(3)]. Known and likely questioned costs should be investigated by the Department and recovered, as appropriate, because Medicaid overpayments are recoverable regardless of whether they occurred due to an error by the Department, entity acting on behalf of the Department, or a provider [Section 25.5-4-301(2), C.R.S.]. We found the following problems resulting in $291,597 in known questioned costs: ? Claims paid with no support that services were provided. For 3,958 of the 362,110 NEMT claims (1 percent), which totaled $258,115 paid from July 2020 to February 2021, IntelliRide or providers submitted the claims without any documentation showing that recipients received the NEMT services from the providers listed in the claim. The $258,115 is known questioned costs and includes: o 3,323 claims totaling $163,985 submitted by IntelliRide with no documentation in EcoLane of a ride being scheduled or provided. o 619 claims totaling $61,431 submitted by IntelliRide for which EcoLane showed the scheduled ride was cancelled. o 16 sampled claims totaling $32,699 submitted by providers directly to the Department had no documentation that an NEMT service occurred because the providers did not send the Department documentation for their claims. Upon our request, the Department attempted to obtain supporting documentation from providers for these claims but was unable to obtain any. ? Overpayments due to incorrect mileage and taxi rates. For 466 of the 321,099 mileage and taxi claims (less than 1 percent), the Department overpaid IntelliRide. Specifically, for 50 of the 287,308 mileage claims (less than 1 percent), the mileage submitted by IntelliRide that the Department paid was more than the ride mileage that IntelliRide documented in EcoLane. For 416 of the 33,791 (1 percent) claims submitted by IntelliRide on behalf of providers that were permitted to operate as taxis, the Department paid a higher rate than the providers? set PUC rate. The following table breaks out the overpayments that we identified, which totaled $6,759 in known questioned costs. We did not find issues with the rate amounts that the Department paid for non-mileage and non-taxi services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Examples of these overpayments include: o An overpayment of $48 for a claim submitted by IntelliRide for a taxi provider that billed the wrong taxi rate. The Department paid $60 for a 4-mile trip, when it should have paid $12 based on the PUC rate of $3 per mile. o An overpayment of $79 for a claim submitted by IntelliRide on behalf of a provider because the claim showed the trip was 76 miles, but the EcoLane data showed the trip was 38 miles. The Department paid $157, when it should have paid $78. ? Unallowable rides, not for medical appointments. For 61 claims showing NEMT trips every day in December 2020 for two recipients, there were no medical claims corresponding to their trips, so it appears that either NEMT was used repeatedly to transport these recipients to unallowable destinations or the provider did not provide the trips claimed. The NEMT provider reported to IntelliRide that these trips were completed even though the recipients did not attend any medical appointments that month. IntelliRide submitted the 61 NEMT claims and its EcoLane data showed that the NEMT providers self-reported that the trips were completed. However, IntelliRide confirmed that these trips were not used to access medical care. The issues we identified resulted in $2,674 of known questioned costs. ? Air ambulance claims paid without prior authorization. None of the 11 air ambulance NEMT claims had supporting documentation that the provider requested or received prior authorization from the Department before the trip occurred. These 11 claims to three providers resulted in $23,122 in known questioned costs. ? Claims paid for trips that were not the least costly, medically necessary, and/or for approved escorts. For seven of the 85 sampled claims (8 percent), IntelliRide submitted the claims without having required documentation from medical providers. Specifically, four claims lacked documentation to support the medical necessity for the type of vehicle used (either mobility vehicle, taxi, or wheelchair van); the other three claims lacked documentation of the recipient?s need for an escort to support the associated cost, which indicates that the three sampled NEMT trips were provided to an escort ineligible to ride with the recipient. The issues we identified for the seven claims resulted in $927 of known questioned costs. In addition, we found the following problems resulting in $5,180,962 in likely questioned costs, which are estimated potential violations of federal requirements that we could not confirm due to a lack of documentation: ? $4.8 million paid for taxi claims without mileage. For 29,049 taxi claims totaling $4,763,071, the Department paid the claims without ensuring taxi providers were paid at their PUC per-mile rate. These claims were submitted directly to the Department by 10 permitted taxi providers. The Department required providers to submit claims showing only the number of one-way trips driven, not the number of miles driven. As a result, the Department could not ensure that these taxi claims were paid at the correct PUC rates, as required in its Billing Manual and Rate Schedule. The Department paid the full amount that each taxi provider requested, as long as the claim was not more than $1,000 per one-way trip. For example, the Department paid $4,000 to one taxi provider for a claim showing four one-way trips for a recipient on a single day. Based on the claim amount, the taxi provider would have had to have driven the recipient on four 400-mile, one-way trips that day to justify this amount, because the taxi provider?s PUC rate is $4 for the first mile and $2.50 for each additional mile. Since the Department did not obtain the miles driven for each one-way trip from taxi providers for these 29,049 claims, we could not determine whether the payments were accurate based on each provider?s PUC rate, as required. ? $409,575 paid for taxi claims for providers not permitted as taxis. For 3,284 NEMT claims for taxi services from eight providers, the providers were not permitted by the PUC to operate as taxis. For example, one provider was paid for an NEMT taxi claim for $5,875 for 12 trips, or $490 per trip. Since these providers were not permitted as taxis, they did not have PUC-set taxi rates, so we could not determine how much these providers should have been paid. ? $4,718 paid for trips that may not have been to attend medical services. As of April 2021, 13 of the 22 sampled NEMT claims (59 percent) for trips in December 2020 had no medical claims for dates corresponding to the NEMT trips. Department staff told us that Medicaid medical claims are typically submitted and paid within 3 months of the date of service, but that there is a possibility that medical providers had not yet submitted medical claims for the recipients since federal regulations technically allow providers up to 12 months to submit claims [42 CFR 447.45(d)(1)]. In addition, six of these 13 recipients had both Medicaid and other types of medical insurance, such as Medicare. According to the Department, it is possible that the six recipients used NEMT trips to access medical services but the Department did not have a Medicaid claim for the services because they were paid by the other types of insurance, which is allowed by state regulations [10 CCR 2505-10 8.014.5.B.2]. Therefore, we could not determine whether the NEMT trips associated with the 13 claims had been for recipients to attend medical services. ? $3,598 paid for trips that may not have been completed. For 61 of the 362,110 paid claims (less than 1 percent), the scheduled trips were not marked as complete in EcoLane, so we could not determine whether they had been completed. Why did these problems occur? The Department lacks effective internal controls over NEMT claims to ensure they are appropriate and consistently comply with federal and state requirements. According to federal regulations [2 CFR 200.303(a)], the Department, as a recipient of federal funds, must establish and maintain effective internal controls to provide reasonable assurance that federal funds are spent in compliance with federal requirements. We identified the following areas where Department controls are lacking for NEMT claims: Lack of Department information technology (IT) Controls in interChange ? No IT controls to prevent providers from bypassing broker. From December 2020 through February 2021, the Department paid NEMT providers directly for unsupported NEMT trips because the Department did not have IT controls in interChange to deny claims for trips that were not brokered through IntelliRide, as required at the time. As of September 1, 2021, the Department plans to require only the NEMT providers operating in nine metro-Denver counties to broker trips through IntelliRide, so the Department needs IT controls to ensure providers in these counties work with IntelliRide to schedule all trips and submit related claims. ? Lack of IT and other controls to ensure proper payments for NEMT taxi services. InterChange is programmed to pay each NEMT taxi claim based on one-way trips, but the Department has not implemented an IT or other control to ensure that NEMT taxi claims are paid at the providers? current PUC-approved per-mile rates, and that the Department only pays taxi rates when the provider is permitted by the PUC to operate as a taxi. Department staff stated that the only IT control the Department has built into interChange to help ensure proper payment of taxi claims is limiting payments for taxi claims to no more than $1,000 per one-way trip, and that this control is in accordance with the NEMT Billing Manual and Rate Schedule. However, Department staff also acknowledged that there is a conflict within the Billing Manual that requires taxi claims to be based on the number of one-way trips, but also paid based on per-mile PUC rates. By setting the limit based only on the number of one-way trips instead of providers? PUC per-mile rate, this Department IT control is not effective at ensuring taxi claims are paid properly. To ensure accurate payments for NEMT taxi claims, the Department will need methods, such as IT controls in interChange, and clarification in the Billing Manual and Rate Schedule, to ensure taxi providers are paid based on set rates, and ensure each taxi provider is permitted. ? No IT controls to ensure required prior authorizations. Air ambulance services were paid without the Department?s prior authorization for the services because the Department does not have IT controls to ensure prior authorization before payment. If the Department does not implement IT controls to ensure appropriate prior authorizations of NEMT services, the Department will need to develop manual processes to ensure that NEMT services receive required authorization prior to paying the related claims. Lack of Department Monitoring of NEMT Services and Claims ? Insufficient methods to ensure appropriate payment and collect necessary documentation from providers that bypass the statewide brokerage. Although the Department reviewed NEMT provider supporting documentation for NEMT services in 2019, the Department did not do so in 2020 or 2021, and had no process to require the providers that bypassed the statewide brokerage to submit documentation to support their NEMT claims before they were paid. According to the Department, in September 2021, it plans to require providers in nine counties covered by the IntelliRide brokerage contract to provide and submit claims through IntelliRide; however, NEMT providers in the remaining 55 counties will be submitting NEMT claims directly to the Department. Therefore, it is important that the Department develop a process to ensure that providers in these 55 counties maintain required documentation for each claim. ? Lack of monitoring to ensure Intelliride submits accurate mileage claims and collects necessary documentation. The Department does not conduct reviews of IntelliRide?s documentation in EcoLane to ensure it submits claims for accurate mileage and maintains support for claims submitted to or paid by the Department. For example, the Department does not reconcile its NEMT claims data from interChange and IntelliRide?s EcoLane system data to ensure each claim is supported. Furthermore, the Department has never completed a file review of IntelliRide?s supporting documentation for NEMT claims, such as when the Department contracted with IntelliRide to be a regional broker prior to becoming the statewide broker. ? No method to ensure NEMT service claims are for rides for medical treatment and the least costly. The Department does not conduct any reconciliation of its interChange data on NEMT trip claims to its interChange data on Medicaid medical claims to ensure NEMT claims are only paid for recipients to access medical care. The Department also does not require confirmation from medical providers that recipients used NEMT to access necessary medical care. For example, NEMT providers told us that before the start of the IntelliRide statewide brokerage contract, they either called medical providers to confirm that the recipients? NEMT trips were to access medical appointments or collected medical providers? signatures for each NEMT trip. In addition, the Department has no controls to ensure providers that submit claims directly to the Department are providing the least costly NEMT service appropriate to each recipient, such as public transportation when it is accessible and appropriate. For example, IntelliRide instructs its staff to attempt to schedule the lowest-cost NEMT service based on recipients? mobility needs and access to public transportation; however, the Department has no such method to ensure services are the least costly when NEMT providers schedule services for recipients. As of September 2021, the Department plans to have the recipients who live in the 55 counties not served by IntelliRide begin scheduling their rides directly with the NEMT providers of their choosing, yet the Department has not developed a method to ensure recipients in these areas receive the lowest-cost services appropriate for their needs. ? Potentially insufficient Department staffing to monitor NEMT claims effectively. For Fiscal Year 2021, the Department was appropriated three full-time equivalent (FTE) staff to oversee NEMT claims; however, the Department had two vacancies in these positions from July 2020 through May 2021 that it did not fill, so there was only one Department staff overseeing NEMT and the IntelliRide statewide contract during the audit time period. In June 2021, the Department added an additional FTE staff member to assist in administering the NEMT benefit. Why do these problems matter? Likely federal recovery of funds used for improper payments. Section 25.5-4-301(2), C.R.S., states that any overpayments of claims to providers are recoverable and ?are recoverable regardless of whether the overpayment is the result of an error by the state department? an entity acting on behalf of [the department], or the provider or any agent of the provider.? Our audit identified $291,597 in known questioned costs, of which about $145,797 is the federal portion of funds that the federal government may recover. We also identified $5,180,962 in likely questioned costs, of which $2,590,480 is the federal portion of funds that could be recovered if the payments are determined to have not been appropriate. The following table shows the questioned costs and federal portions for each problem we identified. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote When providers bypass broker controls, service quality is not monitored. When the Department allows some NEMT providers to bypass the IntelliRide broker, and does not obtain documentation to support their claims, the Department is unable to monitor the services of these providers. Additionally, when the Department does not monitor providers that bypass the statewide broker, the Department is applying different and possibly inadequate standards for the providers that bypass compared to the providers that work with IntelliRide. Although the Department plans for IntelliRide to no longer be the statewide NEMT broker for all 64 counties beginning September 2021, IntelliRide will continue to administer NEMT trips for nine Front Range counties that account for the majority of NEMT trips. It is important that all NEMT trips in these counties be brokered through IntelliRide so that the Department can monitor the quality of the trips and IntelliRide?s oversight of them. Risk of fraud, waste, and abuse. When the Department pays NEMT claims that are not supported by documentation of the service, medical documentation showing NEMT was for medical treatment, or the required prior authorizations, there is a significant risk of misappropriation of federal and state funds by providers and/or recipients. In addition, the eight providers not permitted as taxis that submitted taxi claims appear to have set their own rates of payment at a significantly higher rate, since the PUC did not permit or set rates for these providers. While we did not identify confirmed fraud by recipients or providers due to a lack of supporting documentation for claims, the problems identified demonstrate waste of public funds and potential abuse of the Medicaid program. When the Department overpays Medicaid funds and pays for unallowable services, there are fewer funds available to service the recipients who need them. In addition, there is no federal or state limit on payments for NEMT services, so it is important that the Department ensure Medicaid recipients receive appropriate transportation to medical treatment, while also ensuring the Department is acting as a good steward of federal and state funds. See Schedule of Findings and Questioned Costs for chart/table Character Limit Exceeded See Statewide Single Audit Report
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses and a Significant Deficiency were communicated to the Department of Health Care Policy and Financing (Department) in previous years and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-045 Payments for Non-Emergent Medical Transportation ClaimsPrior to July 2020, in 55 counties, the Department worked with various county offices to have them broker Non-Emergent Medical Transportation (NEMT) services for Medicaid recipients, including rides to and from Medicaid medical appointments, personal mileage reimbursement, and trip-related meals and lodging. For example, these counties arranged the rides with transportation providers, submitted the claims or had providers submit claims for reimbursement to the Department, and passed on reimbursements to providers as needed. For the remaining nine counties, the Department contracted with IntelliRide to serve as the NEMT broker for services in those areas. From July 1, 2020, to August 31, 2021, when the Department contracted with IntelliRide to be the statewide broker, most recipients throughout the state scheduled NEMT rides by contacting IntelliRide through its call center, website chat function, or smartphone applications. IntelliRide scheduled rides and assigned transportation providers to them, and had providers upload trip information into IntelliRide?s EcoLane transportation scheduling system. EcoLane maintains information related to recipients? requests for rides and provider trip information, such as the trip date and time, names of the recipient and driver, and scheduled pick-up and destination addresses. IntelliRide submitted claims through the Department?s interChange system (interChange) requesting payments for providers? NEMT services, paid providers for their services, and received reimbursement from the Department. In addition, the Department paid NEMT claims submitted directly by NEMT providers. In Fiscal Year 2021, from July 1, 2020, through February 28, 2021 (the audit period), the Department paid 362,110 claims for NEMT services totaling about $33.2 million, as shown in the following table. In September 2021, the Department plans to transition back to IntelliRide brokering services in nine counties, while the NEMT providers in the remaining counties will broker their own services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote What audit work was performed and how were the results measured? The purpose of the audit work was to determine whether the Department has ensured that NEMT claims adhere to the following federal and state requirements. ? NEMT trips were to be brokered through, and all claims submitted by, the statewide broker, Intelliride. According to state regulations and the Department?s NEMT Billing Manual, all NEMT trips during Fiscal Year 2021 had to be authorized by the statewide broker, IntelliRide [10 CCR 2505-10 8.014.7.A]. This means that each recipient?s NEMT ride request should have been sent to IntelliRide for approval or authorization before the trip, and any unauthorized trips should ?not be reimbursed or paid? [Billing Manual]. According to the Department, it allowed NEMT providers time to transition to working with IntelliRide because some providers were reluctant to join the statewide brokerage and the Department needed time to onboard providers. By Fall 2020, most providers should have been working with IntelliRide to schedule NEMT rides. The Department told us that six NEMT providers received its express permission to bypass IntelliRide to schedule rides and submit claims directly to the Department because the providers are unique, such as only serving recipients with disabilities or receiving federal grant funding to provide NEMT. To assess whether IntelliRide brokered most NEMT services in the State and submitted the related claims in line with regulations and its contract, we reviewed the Department?s aggregate data for the 128,998 NEMT claims paid from December 2020 through February 2021. ? The Department must pay claims based on accurate service rates and trip mileage. Non-taxi NEMT services, such as wheelchair and mobility vehicle services, have base rates and mileage rates set by the Department. IntelliRide tracks the mileage of each NEMT trip in EcoLane and submits mileage claims to the Department?s interChange system. The Public Utilities Commission (PUC) sets the rate for each permitted taxi provider, which generally includes a rate for the first trip mile and a different rate for each additional mile. According to the Department?s NEMT Billing Manual and NEMT Rate Schedule for Fiscal Year 2021, taxi claims should have been paid at the rate set by the PUC. For example, if a taxi company?s PUC rate was $4 for the first mile and $2 for each additional mile, the Department should have paid $6 for a two-mile NEMT trip claim. To verify that the Department paid NEMT claims based on the correct trip mileage and rates, we reviewed the trip mileage and rates for 362,110 NEMT claims paid from July 2020 through February 2021, and PUC documentation on the taxi rates for permitted taxi companies. ? Claims must be supported with accurate and complete documentation confirming the service provided. Both IntelliRide and providers that submit claims for NEMT services must keep and be able to furnish accurate, complete supporting documentation for all claims [42 USC 1396a(27), 42 CFR ?? 431.17 and 433.32, and 10 CCR 2505-10 8.014.3.C and 8.014.6.B]. For example, a claim must be supported by medical documentation showing that the type of vehicle was needed to transport the recipient, and documentation from the transportation provider showing the trip occurred and when the recipient was picked-up and dropped-off. IntelliRide should only submit a claim to the Department after IntelliRide confirms the trip has been completed and marks the status complete in EcoLane [IntelliRide Policies and Procedures]. If an NEMT provider does not show up for a trip, IntelliRide should mark the trip as ?cancelled? in EcoLane. Payments for Medicaid claims that lack supporting documentation for the services provided are unallowable, meaning they should not be paid. IntelliRide or the Department must maintain documentation from recipients? medical providers showing why certain NEMT services, like transportation in a wheelchair van or with an escort, are medically necessary [10 CCR 2505-10 8.014.7.B and 8.014.5.D.1; Billing Manual]. To verify that there was support for NEMT claims, we reviewed IntelliRide data in EcoLane for all 362,110 NEMT claims paid from July 2020 through February 2021, and Department documentation for a sample of 85 NEMT paid claims?75 selected randomly from the four NEMT service areas of the state, and 10 that were the highest paid NEMT claims. ? NEMT services must be medically necessary. NEMT services shall only be provided to recipients with no other means to attend medically necessary, non-emergency treatment covered by Medicaid [42 USC 1396a(70); 42 CFR 431.53; 10 CCR 2505-10 8.014.5.B]. To verify that NEMT claims were only paid for recipients to access medical care, we reviewed the Department?s data on paid medical claims to determine if the recipients related to 22 sampled NEMT claims paid in December 2020 had a corresponding medical appointment. For another 61 paid NEMT claims that involved IntelliRide scheduling and submitting claims for trips every day in December for two recipients, we reviewed whether the recipients had paid medical claims corresponding with the trips. ? Prior authorization is required for air ambulance. The Department must grant prior authorization for the use of an NEMT air ambulance before the trip occurs in order for the claim to be paid [10 CCR 2505-10 8.014.7.D.1.b]. To verify that the Department granted prior authorization for air ambulance trips, we reviewed the use of air ambulances in 11 paid claims from July 2020 to February 2021. ? Recipients are to receive the least-costly NEMT transportation option appropriate for their medical condition. For example, recipients should only ride in a vehicle for recipients with mobility needs when they have a mobility issue or if there is a lack of access to public transportation [10 CCR 2505-10 8.014.6.B, 42 USC 1396(a(70), and 42 CFR 440.170(a)(4)]. Higher-cost NEMT services, such as ambulance and wheelchair van services, must be supported with documentation of the recipient?s need for the specific higher-cost services [10 CCR 2505-10 8.014.5.B.1.b]. To determine whether recipients received the least costly NEMT services to meet their needs, we reviewed documentation submitted by medical or transportation providers to IntelliRide or the Department for the 85 sampled NEMT claims. ? Taxi providers must be permitted by the PUC to provide NEMT taxi rides. To provide NEMT rides by taxi and receive payment for them, the provider must maintain a common carrier permit issued by the PUC [10 CCR 2505-10 8.014.3.B.4.a]. To verify that the providers that were paid for taxi claims had been permitted to provide taxi services, we reviewed the 33,791 NEMT claims for taxi services from July 2020 to February 2021. What problems were identified? The Department paid $3.5 million directly to 66 NEMT providers for claims that were not brokered by Intelliride. From December 2020 through February 2021, 26,890 of the approximately 129,000 NEMT claims paid by the Department (21 percent), totaling about $3.5 million, were not brokered through IntelliRide, which violated state regulations requiring all NEMT services to be brokered through the statewide brokerage in effect at the time. The following chart shows the amounts the Department paid for claims submitted directly by NEMT providers compared to its payments for claims submitted by IntelliRide from July 2020 through February 2021. During these months, the number of claims that providers submitted directly to the Department decreased as providers transitioned to working with IntelliRide to broker NEMT rides; however, as of February 2021, the Department was still paying about $1 million in monthly claims that were submitted directly by providers. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote The Department paid 36,910 NEMT claims totaling $5.5 million, which either violated or may have violated federal and/or state regulations. The claims were for unallowable services or were overpaid, and resulted in $291,597 in known questioned costs and $5,180,962 in likely questioned costs for Medicaid. A questioned cost is a payment that ?resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds? or ?the costs, at the time of the audit, [that] are not supported by adequate documentation?? [2 CFR 200.84]. A known questioned cost reflects a violation that the auditor confirmed; a likely questioned cost is the auditor?s best estimate of a potential violation [2 CFR 200.516(a)(3)]. Known and likely questioned costs should be investigated by the Department and recovered, as appropriate, because Medicaid overpayments are recoverable regardless of whether they occurred due to an error by the Department, entity acting on behalf of the Department, or a provider [Section 25.5-4-301(2), C.R.S.]. We found the following problems resulting in $291,597 in known questioned costs: ? Claims paid with no support that services were provided. For 3,958 of the 362,110 NEMT claims (1 percent), which totaled $258,115 paid from July 2020 to February 2021, IntelliRide or providers submitted the claims without any documentation showing that recipients received the NEMT services from the providers listed in the claim. The $258,115 is known questioned costs and includes: o 3,323 claims totaling $163,985 submitted by IntelliRide with no documentation in EcoLane of a ride being scheduled or provided. o 619 claims totaling $61,431 submitted by IntelliRide for which EcoLane showed the scheduled ride was cancelled. o 16 sampled claims totaling $32,699 submitted by providers directly to the Department had no documentation that an NEMT service occurred because the providers did not send the Department documentation for their claims. Upon our request, the Department attempted to obtain supporting documentation from providers for these claims but was unable to obtain any. ? Overpayments due to incorrect mileage and taxi rates. For 466 of the 321,099 mileage and taxi claims (less than 1 percent), the Department overpaid IntelliRide. Specifically, for 50 of the 287,308 mileage claims (less than 1 percent), the mileage submitted by IntelliRide that the Department paid was more than the ride mileage that IntelliRide documented in EcoLane. For 416 of the 33,791 (1 percent) claims submitted by IntelliRide on behalf of providers that were permitted to operate as taxis, the Department paid a higher rate than the providers? set PUC rate. The following table breaks out the overpayments that we identified, which totaled $6,759 in known questioned costs. We did not find issues with the rate amounts that the Department paid for non-mileage and non-taxi services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Examples of these overpayments include: o An overpayment of $48 for a claim submitted by IntelliRide for a taxi provider that billed the wrong taxi rate. The Department paid $60 for a 4-mile trip, when it should have paid $12 based on the PUC rate of $3 per mile. o An overpayment of $79 for a claim submitted by IntelliRide on behalf of a provider because the claim showed the trip was 76 miles, but the EcoLane data showed the trip was 38 miles. The Department paid $157, when it should have paid $78. ? Unallowable rides, not for medical appointments. For 61 claims showing NEMT trips every day in December 2020 for two recipients, there were no medical claims corresponding to their trips, so it appears that either NEMT was used repeatedly to transport these recipients to unallowable destinations or the provider did not provide the trips claimed. The NEMT provider reported to IntelliRide that these trips were completed even though the recipients did not attend any medical appointments that month. IntelliRide submitted the 61 NEMT claims and its EcoLane data showed that the NEMT providers self-reported that the trips were completed. However, IntelliRide confirmed that these trips were not used to access medical care. The issues we identified resulted in $2,674 of known questioned costs. ? Air ambulance claims paid without prior authorization. None of the 11 air ambulance NEMT claims had supporting documentation that the provider requested or received prior authorization from the Department before the trip occurred. These 11 claims to three providers resulted in $23,122 in known questioned costs. ? Claims paid for trips that were not the least costly, medically necessary, and/or for approved escorts. For seven of the 85 sampled claims (8 percent), IntelliRide submitted the claims without having required documentation from medical providers. Specifically, four claims lacked documentation to support the medical necessity for the type of vehicle used (either mobility vehicle, taxi, or wheelchair van); the other three claims lacked documentation of the recipient?s need for an escort to support the associated cost, which indicates that the three sampled NEMT trips were provided to an escort ineligible to ride with the recipient. The issues we identified for the seven claims resulted in $927 of known questioned costs. In addition, we found the following problems resulting in $5,180,962 in likely questioned costs, which are estimated potential violations of federal requirements that we could not confirm due to a lack of documentation: ? $4.8 million paid for taxi claims without mileage. For 29,049 taxi claims totaling $4,763,071, the Department paid the claims without ensuring taxi providers were paid at their PUC per-mile rate. These claims were submitted directly to the Department by 10 permitted taxi providers. The Department required providers to submit claims showing only the number of one-way trips driven, not the number of miles driven. As a result, the Department could not ensure that these taxi claims were paid at the correct PUC rates, as required in its Billing Manual and Rate Schedule. The Department paid the full amount that each taxi provider requested, as long as the claim was not more than $1,000 per one-way trip. For example, the Department paid $4,000 to one taxi provider for a claim showing four one-way trips for a recipient on a single day. Based on the claim amount, the taxi provider would have had to have driven the recipient on four 400-mile, one-way trips that day to justify this amount, because the taxi provider?s PUC rate is $4 for the first mile and $2.50 for each additional mile. Since the Department did not obtain the miles driven for each one-way trip from taxi providers for these 29,049 claims, we could not determine whether the payments were accurate based on each provider?s PUC rate, as required. ? $409,575 paid for taxi claims for providers not permitted as taxis. For 3,284 NEMT claims for taxi services from eight providers, the providers were not permitted by the PUC to operate as taxis. For example, one provider was paid for an NEMT taxi claim for $5,875 for 12 trips, or $490 per trip. Since these providers were not permitted as taxis, they did not have PUC-set taxi rates, so we could not determine how much these providers should have been paid. ? $4,718 paid for trips that may not have been to attend medical services. As of April 2021, 13 of the 22 sampled NEMT claims (59 percent) for trips in December 2020 had no medical claims for dates corresponding to the NEMT trips. Department staff told us that Medicaid medical claims are typically submitted and paid within 3 months of the date of service, but that there is a possibility that medical providers had not yet submitted medical claims for the recipients since federal regulations technically allow providers up to 12 months to submit claims [42 CFR 447.45(d)(1)]. In addition, six of these 13 recipients had both Medicaid and other types of medical insurance, such as Medicare. According to the Department, it is possible that the six recipients used NEMT trips to access medical services but the Department did not have a Medicaid claim for the services because they were paid by the other types of insurance, which is allowed by state regulations [10 CCR 2505-10 8.014.5.B.2]. Therefore, we could not determine whether the NEMT trips associated with the 13 claims had been for recipients to attend medical services. ? $3,598 paid for trips that may not have been completed. For 61 of the 362,110 paid claims (less than 1 percent), the scheduled trips were not marked as complete in EcoLane, so we could not determine whether they had been completed. Why did these problems occur? The Department lacks effective internal controls over NEMT claims to ensure they are appropriate and consistently comply with federal and state requirements. According to federal regulations [2 CFR 200.303(a)], the Department, as a recipient of federal funds, must establish and maintain effective internal controls to provide reasonable assurance that federal funds are spent in compliance with federal requirements. We identified the following areas where Department controls are lacking for NEMT claims: Lack of Department information technology (IT) Controls in interChange ? No IT controls to prevent providers from bypassing broker. From December 2020 through February 2021, the Department paid NEMT providers directly for unsupported NEMT trips because the Department did not have IT controls in interChange to deny claims for trips that were not brokered through IntelliRide, as required at the time. As of September 1, 2021, the Department plans to require only the NEMT providers operating in nine metro-Denver counties to broker trips through IntelliRide, so the Department needs IT controls to ensure providers in these counties work with IntelliRide to schedule all trips and submit related claims. ? Lack of IT and other controls to ensure proper payments for NEMT taxi services. InterChange is programmed to pay each NEMT taxi claim based on one-way trips, but the Department has not implemented an IT or other control to ensure that NEMT taxi claims are paid at the providers? current PUC-approved per-mile rates, and that the Department only pays taxi rates when the provider is permitted by the PUC to operate as a taxi. Department staff stated that the only IT control the Department has built into interChange to help ensure proper payment of taxi claims is limiting payments for taxi claims to no more than $1,000 per one-way trip, and that this control is in accordance with the NEMT Billing Manual and Rate Schedule. However, Department staff also acknowledged that there is a conflict within the Billing Manual that requires taxi claims to be based on the number of one-way trips, but also paid based on per-mile PUC rates. By setting the limit based only on the number of one-way trips instead of providers? PUC per-mile rate, this Department IT control is not effective at ensuring taxi claims are paid properly. To ensure accurate payments for NEMT taxi claims, the Department will need methods, such as IT controls in interChange, and clarification in the Billing Manual and Rate Schedule, to ensure taxi providers are paid based on set rates, and ensure each taxi provider is permitted. ? No IT controls to ensure required prior authorizations. Air ambulance services were paid without the Department?s prior authorization for the services because the Department does not have IT controls to ensure prior authorization before payment. If the Department does not implement IT controls to ensure appropriate prior authorizations of NEMT services, the Department will need to develop manual processes to ensure that NEMT services receive required authorization prior to paying the related claims. Lack of Department Monitoring of NEMT Services and Claims ? Insufficient methods to ensure appropriate payment and collect necessary documentation from providers that bypass the statewide brokerage. Although the Department reviewed NEMT provider supporting documentation for NEMT services in 2019, the Department did not do so in 2020 or 2021, and had no process to require the providers that bypassed the statewide brokerage to submit documentation to support their NEMT claims before they were paid. According to the Department, in September 2021, it plans to require providers in nine counties covered by the IntelliRide brokerage contract to provide and submit claims through IntelliRide; however, NEMT providers in the remaining 55 counties will be submitting NEMT claims directly to the Department. Therefore, it is important that the Department develop a process to ensure that providers in these 55 counties maintain required documentation for each claim. ? Lack of monitoring to ensure Intelliride submits accurate mileage claims and collects necessary documentation. The Department does not conduct reviews of IntelliRide?s documentation in EcoLane to ensure it submits claims for accurate mileage and maintains support for claims submitted to or paid by the Department. For example, the Department does not reconcile its NEMT claims data from interChange and IntelliRide?s EcoLane system data to ensure each claim is supported. Furthermore, the Department has never completed a file review of IntelliRide?s supporting documentation for NEMT claims, such as when the Department contracted with IntelliRide to be a regional broker prior to becoming the statewide broker. ? No method to ensure NEMT service claims are for rides for medical treatment and the least costly. The Department does not conduct any reconciliation of its interChange data on NEMT trip claims to its interChange data on Medicaid medical claims to ensure NEMT claims are only paid for recipients to access medical care. The Department also does not require confirmation from medical providers that recipients used NEMT to access necessary medical care. For example, NEMT providers told us that before the start of the IntelliRide statewide brokerage contract, they either called medical providers to confirm that the recipients? NEMT trips were to access medical appointments or collected medical providers? signatures for each NEMT trip. In addition, the Department has no controls to ensure providers that submit claims directly to the Department are providing the least costly NEMT service appropriate to each recipient, such as public transportation when it is accessible and appropriate. For example, IntelliRide instructs its staff to attempt to schedule the lowest-cost NEMT service based on recipients? mobility needs and access to public transportation; however, the Department has no such method to ensure services are the least costly when NEMT providers schedule services for recipients. As of September 2021, the Department plans to have the recipients who live in the 55 counties not served by IntelliRide begin scheduling their rides directly with the NEMT providers of their choosing, yet the Department has not developed a method to ensure recipients in these areas receive the lowest-cost services appropriate for their needs. ? Potentially insufficient Department staffing to monitor NEMT claims effectively. For Fiscal Year 2021, the Department was appropriated three full-time equivalent (FTE) staff to oversee NEMT claims; however, the Department had two vacancies in these positions from July 2020 through May 2021 that it did not fill, so there was only one Department staff overseeing NEMT and the IntelliRide statewide contract during the audit time period. In June 2021, the Department added an additional FTE staff member to assist in administering the NEMT benefit. Why do these problems matter? Likely federal recovery of funds used for improper payments. Section 25.5-4-301(2), C.R.S., states that any overpayments of claims to providers are recoverable and ?are recoverable regardless of whether the overpayment is the result of an error by the state department? an entity acting on behalf of [the department], or the provider or any agent of the provider.? Our audit identified $291,597 in known questioned costs, of which about $145,797 is the federal portion of funds that the federal government may recover. We also identified $5,180,962 in likely questioned costs, of which $2,590,480 is the federal portion of funds that could be recovered if the payments are determined to have not been appropriate. The following table shows the questioned costs and federal portions for each problem we identified. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote When providers bypass broker controls, service quality is not monitored. When the Department allows some NEMT providers to bypass the IntelliRide broker, and does not obtain documentation to support their claims, the Department is unable to monitor the services of these providers. Additionally, when the Department does not monitor providers that bypass the statewide broker, the Department is applying different and possibly inadequate standards for the providers that bypass compared to the providers that work with IntelliRide. Although the Department plans for IntelliRide to no longer be the statewide NEMT broker for all 64 counties beginning September 2021, IntelliRide will continue to administer NEMT trips for nine Front Range counties that account for the majority of NEMT trips. It is important that all NEMT trips in these counties be brokered through IntelliRide so that the Department can monitor the quality of the trips and IntelliRide?s oversight of them. Risk of fraud, waste, and abuse. When the Department pays NEMT claims that are not supported by documentation of the service, medical documentation showing NEMT was for medical treatment, or the required prior authorizations, there is a significant risk of misappropriation of federal and state funds by providers and/or recipients. In addition, the eight providers not permitted as taxis that submitted taxi claims appear to have set their own rates of payment at a significantly higher rate, since the PUC did not permit or set rates for these providers. While we did not identify confirmed fraud by recipients or providers due to a lack of supporting documentation for claims, the problems identified demonstrate waste of public funds and potential abuse of the Medicaid program. When the Department overpays Medicaid funds and pays for unallowable services, there are fewer funds available to service the recipients who need them. In addition, there is no federal or state limit on payments for NEMT services, so it is important that the Department ensure Medicaid recipients receive appropriate transportation to medical treatment, while also ensuring the Department is acting as a good steward of federal and state funds. See Schedule of Findings and Questioned Costs for chart/table Character Limit Exceeded See Statewide Single Audit Report
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses and a Significant Deficiency were communicated to the Department of Health Care Policy and Financing (Department) in previous years and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-045 Payments for Non-Emergent Medical Transportation ClaimsPrior to July 2020, in 55 counties, the Department worked with various county offices to have them broker Non-Emergent Medical Transportation (NEMT) services for Medicaid recipients, including rides to and from Medicaid medical appointments, personal mileage reimbursement, and trip-related meals and lodging. For example, these counties arranged the rides with transportation providers, submitted the claims or had providers submit claims for reimbursement to the Department, and passed on reimbursements to providers as needed. For the remaining nine counties, the Department contracted with IntelliRide to serve as the NEMT broker for services in those areas. From July 1, 2020, to August 31, 2021, when the Department contracted with IntelliRide to be the statewide broker, most recipients throughout the state scheduled NEMT rides by contacting IntelliRide through its call center, website chat function, or smartphone applications. IntelliRide scheduled rides and assigned transportation providers to them, and had providers upload trip information into IntelliRide?s EcoLane transportation scheduling system. EcoLane maintains information related to recipients? requests for rides and provider trip information, such as the trip date and time, names of the recipient and driver, and scheduled pick-up and destination addresses. IntelliRide submitted claims through the Department?s interChange system (interChange) requesting payments for providers? NEMT services, paid providers for their services, and received reimbursement from the Department. In addition, the Department paid NEMT claims submitted directly by NEMT providers. In Fiscal Year 2021, from July 1, 2020, through February 28, 2021 (the audit period), the Department paid 362,110 claims for NEMT services totaling about $33.2 million, as shown in the following table. In September 2021, the Department plans to transition back to IntelliRide brokering services in nine counties, while the NEMT providers in the remaining counties will broker their own services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote What audit work was performed and how were the results measured? The purpose of the audit work was to determine whether the Department has ensured that NEMT claims adhere to the following federal and state requirements. ? NEMT trips were to be brokered through, and all claims submitted by, the statewide broker, Intelliride. According to state regulations and the Department?s NEMT Billing Manual, all NEMT trips during Fiscal Year 2021 had to be authorized by the statewide broker, IntelliRide [10 CCR 2505-10 8.014.7.A]. This means that each recipient?s NEMT ride request should have been sent to IntelliRide for approval or authorization before the trip, and any unauthorized trips should ?not be reimbursed or paid? [Billing Manual]. According to the Department, it allowed NEMT providers time to transition to working with IntelliRide because some providers were reluctant to join the statewide brokerage and the Department needed time to onboard providers. By Fall 2020, most providers should have been working with IntelliRide to schedule NEMT rides. The Department told us that six NEMT providers received its express permission to bypass IntelliRide to schedule rides and submit claims directly to the Department because the providers are unique, such as only serving recipients with disabilities or receiving federal grant funding to provide NEMT. To assess whether IntelliRide brokered most NEMT services in the State and submitted the related claims in line with regulations and its contract, we reviewed the Department?s aggregate data for the 128,998 NEMT claims paid from December 2020 through February 2021. ? The Department must pay claims based on accurate service rates and trip mileage. Non-taxi NEMT services, such as wheelchair and mobility vehicle services, have base rates and mileage rates set by the Department. IntelliRide tracks the mileage of each NEMT trip in EcoLane and submits mileage claims to the Department?s interChange system. The Public Utilities Commission (PUC) sets the rate for each permitted taxi provider, which generally includes a rate for the first trip mile and a different rate for each additional mile. According to the Department?s NEMT Billing Manual and NEMT Rate Schedule for Fiscal Year 2021, taxi claims should have been paid at the rate set by the PUC. For example, if a taxi company?s PUC rate was $4 for the first mile and $2 for each additional mile, the Department should have paid $6 for a two-mile NEMT trip claim. To verify that the Department paid NEMT claims based on the correct trip mileage and rates, we reviewed the trip mileage and rates for 362,110 NEMT claims paid from July 2020 through February 2021, and PUC documentation on the taxi rates for permitted taxi companies. ? Claims must be supported with accurate and complete documentation confirming the service provided. Both IntelliRide and providers that submit claims for NEMT services must keep and be able to furnish accurate, complete supporting documentation for all claims [42 USC 1396a(27), 42 CFR ?? 431.17 and 433.32, and 10 CCR 2505-10 8.014.3.C and 8.014.6.B]. For example, a claim must be supported by medical documentation showing that the type of vehicle was needed to transport the recipient, and documentation from the transportation provider showing the trip occurred and when the recipient was picked-up and dropped-off. IntelliRide should only submit a claim to the Department after IntelliRide confirms the trip has been completed and marks the status complete in EcoLane [IntelliRide Policies and Procedures]. If an NEMT provider does not show up for a trip, IntelliRide should mark the trip as ?cancelled? in EcoLane. Payments for Medicaid claims that lack supporting documentation for the services provided are unallowable, meaning they should not be paid. IntelliRide or the Department must maintain documentation from recipients? medical providers showing why certain NEMT services, like transportation in a wheelchair van or with an escort, are medically necessary [10 CCR 2505-10 8.014.7.B and 8.014.5.D.1; Billing Manual]. To verify that there was support for NEMT claims, we reviewed IntelliRide data in EcoLane for all 362,110 NEMT claims paid from July 2020 through February 2021, and Department documentation for a sample of 85 NEMT paid claims?75 selected randomly from the four NEMT service areas of the state, and 10 that were the highest paid NEMT claims. ? NEMT services must be medically necessary. NEMT services shall only be provided to recipients with no other means to attend medically necessary, non-emergency treatment covered by Medicaid [42 USC 1396a(70); 42 CFR 431.53; 10 CCR 2505-10 8.014.5.B]. To verify that NEMT claims were only paid for recipients to access medical care, we reviewed the Department?s data on paid medical claims to determine if the recipients related to 22 sampled NEMT claims paid in December 2020 had a corresponding medical appointment. For another 61 paid NEMT claims that involved IntelliRide scheduling and submitting claims for trips every day in December for two recipients, we reviewed whether the recipients had paid medical claims corresponding with the trips. ? Prior authorization is required for air ambulance. The Department must grant prior authorization for the use of an NEMT air ambulance before the trip occurs in order for the claim to be paid [10 CCR 2505-10 8.014.7.D.1.b]. To verify that the Department granted prior authorization for air ambulance trips, we reviewed the use of air ambulances in 11 paid claims from July 2020 to February 2021. ? Recipients are to receive the least-costly NEMT transportation option appropriate for their medical condition. For example, recipients should only ride in a vehicle for recipients with mobility needs when they have a mobility issue or if there is a lack of access to public transportation [10 CCR 2505-10 8.014.6.B, 42 USC 1396(a(70), and 42 CFR 440.170(a)(4)]. Higher-cost NEMT services, such as ambulance and wheelchair van services, must be supported with documentation of the recipient?s need for the specific higher-cost services [10 CCR 2505-10 8.014.5.B.1.b]. To determine whether recipients received the least costly NEMT services to meet their needs, we reviewed documentation submitted by medical or transportation providers to IntelliRide or the Department for the 85 sampled NEMT claims. ? Taxi providers must be permitted by the PUC to provide NEMT taxi rides. To provide NEMT rides by taxi and receive payment for them, the provider must maintain a common carrier permit issued by the PUC [10 CCR 2505-10 8.014.3.B.4.a]. To verify that the providers that were paid for taxi claims had been permitted to provide taxi services, we reviewed the 33,791 NEMT claims for taxi services from July 2020 to February 2021. What problems were identified? The Department paid $3.5 million directly to 66 NEMT providers for claims that were not brokered by Intelliride. From December 2020 through February 2021, 26,890 of the approximately 129,000 NEMT claims paid by the Department (21 percent), totaling about $3.5 million, were not brokered through IntelliRide, which violated state regulations requiring all NEMT services to be brokered through the statewide brokerage in effect at the time. The following chart shows the amounts the Department paid for claims submitted directly by NEMT providers compared to its payments for claims submitted by IntelliRide from July 2020 through February 2021. During these months, the number of claims that providers submitted directly to the Department decreased as providers transitioned to working with IntelliRide to broker NEMT rides; however, as of February 2021, the Department was still paying about $1 million in monthly claims that were submitted directly by providers. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote The Department paid 36,910 NEMT claims totaling $5.5 million, which either violated or may have violated federal and/or state regulations. The claims were for unallowable services or were overpaid, and resulted in $291,597 in known questioned costs and $5,180,962 in likely questioned costs for Medicaid. A questioned cost is a payment that ?resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds? or ?the costs, at the time of the audit, [that] are not supported by adequate documentation?? [2 CFR 200.84]. A known questioned cost reflects a violation that the auditor confirmed; a likely questioned cost is the auditor?s best estimate of a potential violation [2 CFR 200.516(a)(3)]. Known and likely questioned costs should be investigated by the Department and recovered, as appropriate, because Medicaid overpayments are recoverable regardless of whether they occurred due to an error by the Department, entity acting on behalf of the Department, or a provider [Section 25.5-4-301(2), C.R.S.]. We found the following problems resulting in $291,597 in known questioned costs: ? Claims paid with no support that services were provided. For 3,958 of the 362,110 NEMT claims (1 percent), which totaled $258,115 paid from July 2020 to February 2021, IntelliRide or providers submitted the claims without any documentation showing that recipients received the NEMT services from the providers listed in the claim. The $258,115 is known questioned costs and includes: o 3,323 claims totaling $163,985 submitted by IntelliRide with no documentation in EcoLane of a ride being scheduled or provided. o 619 claims totaling $61,431 submitted by IntelliRide for which EcoLane showed the scheduled ride was cancelled. o 16 sampled claims totaling $32,699 submitted by providers directly to the Department had no documentation that an NEMT service occurred because the providers did not send the Department documentation for their claims. Upon our request, the Department attempted to obtain supporting documentation from providers for these claims but was unable to obtain any. ? Overpayments due to incorrect mileage and taxi rates. For 466 of the 321,099 mileage and taxi claims (less than 1 percent), the Department overpaid IntelliRide. Specifically, for 50 of the 287,308 mileage claims (less than 1 percent), the mileage submitted by IntelliRide that the Department paid was more than the ride mileage that IntelliRide documented in EcoLane. For 416 of the 33,791 (1 percent) claims submitted by IntelliRide on behalf of providers that were permitted to operate as taxis, the Department paid a higher rate than the providers? set PUC rate. The following table breaks out the overpayments that we identified, which totaled $6,759 in known questioned costs. We did not find issues with the rate amounts that the Department paid for non-mileage and non-taxi services. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Examples of these overpayments include: o An overpayment of $48 for a claim submitted by IntelliRide for a taxi provider that billed the wrong taxi rate. The Department paid $60 for a 4-mile trip, when it should have paid $12 based on the PUC rate of $3 per mile. o An overpayment of $79 for a claim submitted by IntelliRide on behalf of a provider because the claim showed the trip was 76 miles, but the EcoLane data showed the trip was 38 miles. The Department paid $157, when it should have paid $78. ? Unallowable rides, not for medical appointments. For 61 claims showing NEMT trips every day in December 2020 for two recipients, there were no medical claims corresponding to their trips, so it appears that either NEMT was used repeatedly to transport these recipients to unallowable destinations or the provider did not provide the trips claimed. The NEMT provider reported to IntelliRide that these trips were completed even though the recipients did not attend any medical appointments that month. IntelliRide submitted the 61 NEMT claims and its EcoLane data showed that the NEMT providers self-reported that the trips were completed. However, IntelliRide confirmed that these trips were not used to access medical care. The issues we identified resulted in $2,674 of known questioned costs. ? Air ambulance claims paid without prior authorization. None of the 11 air ambulance NEMT claims had supporting documentation that the provider requested or received prior authorization from the Department before the trip occurred. These 11 claims to three providers resulted in $23,122 in known questioned costs. ? Claims paid for trips that were not the least costly, medically necessary, and/or for approved escorts. For seven of the 85 sampled claims (8 percent), IntelliRide submitted the claims without having required documentation from medical providers. Specifically, four claims lacked documentation to support the medical necessity for the type of vehicle used (either mobility vehicle, taxi, or wheelchair van); the other three claims lacked documentation of the recipient?s need for an escort to support the associated cost, which indicates that the three sampled NEMT trips were provided to an escort ineligible to ride with the recipient. The issues we identified for the seven claims resulted in $927 of known questioned costs. In addition, we found the following problems resulting in $5,180,962 in likely questioned costs, which are estimated potential violations of federal requirements that we could not confirm due to a lack of documentation: ? $4.8 million paid for taxi claims without mileage. For 29,049 taxi claims totaling $4,763,071, the Department paid the claims without ensuring taxi providers were paid at their PUC per-mile rate. These claims were submitted directly to the Department by 10 permitted taxi providers. The Department required providers to submit claims showing only the number of one-way trips driven, not the number of miles driven. As a result, the Department could not ensure that these taxi claims were paid at the correct PUC rates, as required in its Billing Manual and Rate Schedule. The Department paid the full amount that each taxi provider requested, as long as the claim was not more than $1,000 per one-way trip. For example, the Department paid $4,000 to one taxi provider for a claim showing four one-way trips for a recipient on a single day. Based on the claim amount, the taxi provider would have had to have driven the recipient on four 400-mile, one-way trips that day to justify this amount, because the taxi provider?s PUC rate is $4 for the first mile and $2.50 for each additional mile. Since the Department did not obtain the miles driven for each one-way trip from taxi providers for these 29,049 claims, we could not determine whether the payments were accurate based on each provider?s PUC rate, as required. ? $409,575 paid for taxi claims for providers not permitted as taxis. For 3,284 NEMT claims for taxi services from eight providers, the providers were not permitted by the PUC to operate as taxis. For example, one provider was paid for an NEMT taxi claim for $5,875 for 12 trips, or $490 per trip. Since these providers were not permitted as taxis, they did not have PUC-set taxi rates, so we could not determine how much these providers should have been paid. ? $4,718 paid for trips that may not have been to attend medical services. As of April 2021, 13 of the 22 sampled NEMT claims (59 percent) for trips in December 2020 had no medical claims for dates corresponding to the NEMT trips. Department staff told us that Medicaid medical claims are typically submitted and paid within 3 months of the date of service, but that there is a possibility that medical providers had not yet submitted medical claims for the recipients since federal regulations technically allow providers up to 12 months to submit claims [42 CFR 447.45(d)(1)]. In addition, six of these 13 recipients had both Medicaid and other types of medical insurance, such as Medicare. According to the Department, it is possible that the six recipients used NEMT trips to access medical services but the Department did not have a Medicaid claim for the services because they were paid by the other types of insurance, which is allowed by state regulations [10 CCR 2505-10 8.014.5.B.2]. Therefore, we could not determine whether the NEMT trips associated with the 13 claims had been for recipients to attend medical services. ? $3,598 paid for trips that may not have been completed. For 61 of the 362,110 paid claims (less than 1 percent), the scheduled trips were not marked as complete in EcoLane, so we could not determine whether they had been completed. Why did these problems occur? The Department lacks effective internal controls over NEMT claims to ensure they are appropriate and consistently comply with federal and state requirements. According to federal regulations [2 CFR 200.303(a)], the Department, as a recipient of federal funds, must establish and maintain effective internal controls to provide reasonable assurance that federal funds are spent in compliance with federal requirements. We identified the following areas where Department controls are lacking for NEMT claims: Lack of Department information technology (IT) Controls in interChange ? No IT controls to prevent providers from bypassing broker. From December 2020 through February 2021, the Department paid NEMT providers directly for unsupported NEMT trips because the Department did not have IT controls in interChange to deny claims for trips that were not brokered through IntelliRide, as required at the time. As of September 1, 2021, the Department plans to require only the NEMT providers operating in nine metro-Denver counties to broker trips through IntelliRide, so the Department needs IT controls to ensure providers in these counties work with IntelliRide to schedule all trips and submit related claims. ? Lack of IT and other controls to ensure proper payments for NEMT taxi services. InterChange is programmed to pay each NEMT taxi claim based on one-way trips, but the Department has not implemented an IT or other control to ensure that NEMT taxi claims are paid at the providers? current PUC-approved per-mile rates, and that the Department only pays taxi rates when the provider is permitted by the PUC to operate as a taxi. Department staff stated that the only IT control the Department has built into interChange to help ensure proper payment of taxi claims is limiting payments for taxi claims to no more than $1,000 per one-way trip, and that this control is in accordance with the NEMT Billing Manual and Rate Schedule. However, Department staff also acknowledged that there is a conflict within the Billing Manual that requires taxi claims to be based on the number of one-way trips, but also paid based on per-mile PUC rates. By setting the limit based only on the number of one-way trips instead of providers? PUC per-mile rate, this Department IT control is not effective at ensuring taxi claims are paid properly. To ensure accurate payments for NEMT taxi claims, the Department will need methods, such as IT controls in interChange, and clarification in the Billing Manual and Rate Schedule, to ensure taxi providers are paid based on set rates, and ensure each taxi provider is permitted. ? No IT controls to ensure required prior authorizations. Air ambulance services were paid without the Department?s prior authorization for the services because the Department does not have IT controls to ensure prior authorization before payment. If the Department does not implement IT controls to ensure appropriate prior authorizations of NEMT services, the Department will need to develop manual processes to ensure that NEMT services receive required authorization prior to paying the related claims. Lack of Department Monitoring of NEMT Services and Claims ? Insufficient methods to ensure appropriate payment and collect necessary documentation from providers that bypass the statewide brokerage. Although the Department reviewed NEMT provider supporting documentation for NEMT services in 2019, the Department did not do so in 2020 or 2021, and had no process to require the providers that bypassed the statewide brokerage to submit documentation to support their NEMT claims before they were paid. According to the Department, in September 2021, it plans to require providers in nine counties covered by the IntelliRide brokerage contract to provide and submit claims through IntelliRide; however, NEMT providers in the remaining 55 counties will be submitting NEMT claims directly to the Department. Therefore, it is important that the Department develop a process to ensure that providers in these 55 counties maintain required documentation for each claim. ? Lack of monitoring to ensure Intelliride submits accurate mileage claims and collects necessary documentation. The Department does not conduct reviews of IntelliRide?s documentation in EcoLane to ensure it submits claims for accurate mileage and maintains support for claims submitted to or paid by the Department. For example, the Department does not reconcile its NEMT claims data from interChange and IntelliRide?s EcoLane system data to ensure each claim is supported. Furthermore, the Department has never completed a file review of IntelliRide?s supporting documentation for NEMT claims, such as when the Department contracted with IntelliRide to be a regional broker prior to becoming the statewide broker. ? No method to ensure NEMT service claims are for rides for medical treatment and the least costly. The Department does not conduct any reconciliation of its interChange data on NEMT trip claims to its interChange data on Medicaid medical claims to ensure NEMT claims are only paid for recipients to access medical care. The Department also does not require confirmation from medical providers that recipients used NEMT to access necessary medical care. For example, NEMT providers told us that before the start of the IntelliRide statewide brokerage contract, they either called medical providers to confirm that the recipients? NEMT trips were to access medical appointments or collected medical providers? signatures for each NEMT trip. In addition, the Department has no controls to ensure providers that submit claims directly to the Department are providing the least costly NEMT service appropriate to each recipient, such as public transportation when it is accessible and appropriate. For example, IntelliRide instructs its staff to attempt to schedule the lowest-cost NEMT service based on recipients? mobility needs and access to public transportation; however, the Department has no such method to ensure services are the least costly when NEMT providers schedule services for recipients. As of September 2021, the Department plans to have the recipients who live in the 55 counties not served by IntelliRide begin scheduling their rides directly with the NEMT providers of their choosing, yet the Department has not developed a method to ensure recipients in these areas receive the lowest-cost services appropriate for their needs. ? Potentially insufficient Department staffing to monitor NEMT claims effectively. For Fiscal Year 2021, the Department was appropriated three full-time equivalent (FTE) staff to oversee NEMT claims; however, the Department had two vacancies in these positions from July 2020 through May 2021 that it did not fill, so there was only one Department staff overseeing NEMT and the IntelliRide statewide contract during the audit time period. In June 2021, the Department added an additional FTE staff member to assist in administering the NEMT benefit. Why do these problems matter? Likely federal recovery of funds used for improper payments. Section 25.5-4-301(2), C.R.S., states that any overpayments of claims to providers are recoverable and ?are recoverable regardless of whether the overpayment is the result of an error by the state department? an entity acting on behalf of [the department], or the provider or any agent of the provider.? Our audit identified $291,597 in known questioned costs, of which about $145,797 is the federal portion of funds that the federal government may recover. We also identified $5,180,962 in likely questioned costs, of which $2,590,480 is the federal portion of funds that could be recovered if the payments are determined to have not been appropriate. The following table shows the questioned costs and federal portions for each problem we identified. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote When providers bypass broker controls, service quality is not monitored. When the Department allows some NEMT providers to bypass the IntelliRide broker, and does not obtain documentation to support their claims, the Department is unable to monitor the services of these providers. Additionally, when the Department does not monitor providers that bypass the statewide broker, the Department is applying different and possibly inadequate standards for the providers that bypass compared to the providers that work with IntelliRide. Although the Department plans for IntelliRide to no longer be the statewide NEMT broker for all 64 counties beginning September 2021, IntelliRide will continue to administer NEMT trips for nine Front Range counties that account for the majority of NEMT trips. It is important that all NEMT trips in these counties be brokered through IntelliRide so that the Department can monitor the quality of the trips and IntelliRide?s oversight of them. Risk of fraud, waste, and abuse. When the Department pays NEMT claims that are not supported by documentation of the service, medical documentation showing NEMT was for medical treatment, or the required prior authorizations, there is a significant risk of misappropriation of federal and state funds by providers and/or recipients. In addition, the eight providers not permitted as taxis that submitted taxi claims appear to have set their own rates of payment at a significantly higher rate, since the PUC did not permit or set rates for these providers. While we did not identify confirmed fraud by recipients or providers due to a lack of supporting documentation for claims, the problems identified demonstrate waste of public funds and potential abuse of the Medicaid program. When the Department overpays Medicaid funds and pays for unallowable services, there are fewer funds available to service the recipients who need them. In addition, there is no federal or state limit on payments for NEMT services, so it is important that the Department ensure Medicaid recipients receive appropriate transportation to medical treatment, while also ensuring the Department is acting as a good steward of federal and state funds. See Schedule of Findings and Questioned Costs for chart/table Character Limit Exceeded See Statewide Single Audit Report