Finding 370163 (2023-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-02-22
Audit: 291697
Auditor: Marcum LLP

AI Summary

  • Core Issue: CMHA claimed reimbursement for services provided by an ineligible employee.
  • Impacted Requirements: Compliance with the U.S. Department of Health and Human Services guidelines regarding sanctioned providers.
  • Recommended Follow-Up: Strengthen internal controls in the hiring process to verify eligibility of employees for billing services.

Finding Text

Grantor: U.S. Department of Health and Human Services Program Name: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.243 Criteria: The Organization is not allowed to claim reimbursement for costs associated with entities or individuals who are on the national sanctioned providers listing. Condition: During the audit of this program, CMHA disclosed that there was an employee who was not eligible to be reimbursed for services under the program. Context: The former employee was originally issued a State of CT license had begun to bill under the program. Once the former employee’s license required renewal, it came to CMHA’s attention that this individual was listed as not being able to participate on the OIG website. Effect: CMHA was not in compliance with the terms and conditions of the program. Cause: The internal control procedures for the CMHA did not function properly as there was not a proper control to verify that employment candidates were eligible to bill for services. Recommendation: We recommend the strengthening of internal controls procedures over the hiring process to ensure individuals hired are eligible to properly bill for services.

Corrective Action Plan

CMHA has revised its Selection and Hiring Policy to include certain mandatory alerts and action items whenever an OIG exclusion inquiry shows an individual has been excluded. In addition, the policy has been updated to explicitly referenceOIG exclusion inquiries as part of the screening process and requires regular inquires to be performed on the entire staff of active employees, interns, vendors, and independent contractors every 60 days. CMHA is also in the process of contracting with a vendor to perform these regular OIG exclusion inquiries. CMHA maintains the good faith belief that the corrective actions described above will mitigate the risk of hiring or retaining an individual who has been excluded from participating in Medicare, Medicaid, or any other Federal health care program going forward.

Categories

Cash Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 946605 2023-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance for Needy Families $1.46M
93.493 Congressional Directives $1.20M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $482,413
16.575 Crime Victim Assistance $429,059
93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services $424,456
93.669 Child Abuse and Neglect State Grants $325,000
21.027 Coronavirus State and Local Fiscal Recovery Funds $176,134
93.556 Promoting Safe and Stable Families $128,560
93.958 Block Grants for Community Mental Health Services $118,551
14.267 Continuum of Care Program $81,926
93.788 Opioid Str $50,000
84.425 Education Stabilization Fund $13,481
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $12,050