Finding Text
Condition: During our review of the Wisconsin Medicaid School-Based Services Program, the School District was unable to provide adequate supporting documentation for quarterly payroll costs reported to Medicaid. Additionally, the District could not provide a complete and reliable population of payroll transactions attributable to the Medicaid program to support payroll sampling procedures. Criteria: Wisconsin Medicaid School-Based Services claiming requirements require school districts to maintain complete, accurate, and auditable records to support payroll costs claimed for Medicaid reimbursement. This includes maintaining documentation sufficient to support quarterly payroll reports and providing a defined and accurate population for audit sampling purposes, in accordance with Medicaid record retention and documentation standards. Cause: The District did not have adequate internal controls or recordkeeping procedures in place to ensure payroll records attributable to Medicaid activities were properly accumulated, retained, and readily available for reporting and audit purposes. Management oversight over payroll reporting and documentation related to the Medicaid program was insufficient. Effect: As supporting documentation and a complete payroll population were not available, we were unable to verify the accuracy and allowability of payroll costs reported to the Medicaid program. As a result, there is an increased risk that unallowable or unsupported payroll costs may have been claimed, potentially leading to questioned costs or repayment to the Wisconsin Medicaid program. Questioned Costs: $4,488,717 Recommendation: We recommend the School District strengthen its internal controls over payroll reporting for the Medicaid School-Based Services Program by: establishing and maintaining detailed supporting documentation for all payroll costs claimed; developing procedures to ensure a complete and auditable payroll population can be generated for each reporting period; and providing training to staff responsible for Medicaid payroll reporting and documentation. Management should implement corrective actions to ensure future Medicaid payroll claims are fully supported and compliant with program requirements. Corrective Action Plan: The District acknowledges the finding and will review its procedures over Medicaid payroll.