Finding Text
Information Documentation and Verification Information of the Federal Programs Department of Education AL #84.181 - Special Education - Grants for Infants and Families ? Major Program Passed through State of Maine Department of Education July 1, 2021 - June 30, 2022 Department of Education Special Education Cluster (IDEA) AL #84.027 - Special Education ? Grants to States ? Major Program AL #84.173 - Special Education - Preschool Grants ? Major Program Passed through State of Maine Department of Education July 1, 2021 - June 30, 2022 Repeat Audit Finding: Audit Finding #2021-005 Significant Deficiency Criteria The consistency of the process of obtaining and inputting children?s financial information and the setting of the children?s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition The internal controls over compliance for allowable activities and allowable costs are substantially the same for AL #84.027, AL #84.173 and AL #84.181. In response to prior year findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the ?Authorization to Provide Services and Seek Payment? form and to use this form to verify the accuracy of payor information within children?s plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for the obtaining and updating of ?Authorization to Provide Services and Seek Payment? forms. However, the temporary employee left during the year and the pilot was discontinued. During of our testing, we still noted inconsistent treatment across the Regional Sites when an annual plan was written for a child and a new ?Authorization to Provide Services and Seek Payment? form was not returned to CDS: some instances resulted in the pay source for services under the new plan being carried over from the previous plan, and others resulted in the pay source for services under the new plan being changed to ?CDS pay.? Additionally, during our audit, we noted several instances in which payor information in CINC had not been input accurately when compared to the ?Authorization to Provide Services and Seek Payment? form in the child?s file. For these instances, we performed additional procedures to determine whether any payments subsequently were made in error. We also determined that the payor information in CINC could not be relied upon for the purpose of compliance testing over cash disbursements. As a result, we expanded our procedures to compare each cash disbursement tested to the ?Authorization to Provide Services and Seek Payment? form for the applicable child to determine who the payor of that service should have been. During our testing, we also noted the setting for the children?s services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. An annual plan is written for a child which indicates the ratio of children to service providers, respectively. The ratios can be 1:1 which is indicated as an individual setting in CINC or 2:1 which is indicated as group setting in CINC. We noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Cause Lack of clear and consistent communication within the CDS system for obtaining a child?s financial information caused the discrepancies in obtaining/updating the ?Authorization to Provide Services and Seek Payment? form and for identifying the service setting across the Regional Sites. The inaccurate payor data and setting in CINC was caused by a lack of input controls over data entry into CINC. Effect Payments are processed directly from CINC; therefore, inconsistent and inaccurate payor or setting data creates opportunities for CDS to pay for services or incorrect rates for service settings in error, resulting in unallowed costs. Context In our testing and review of children?s files for the accuracy of payor data in CINC as compared to the ?Authorization to Provide Services and Seek Payment? forms, the exception rate was 31.7%. The sample was not intended to be, and was not, a statistically valid sample. The additional procedures to determine whether any payments were subsequently made in error resulted in the detection of no unallowed costs. These procedures were performed incidentally to our control test. In the additional testing that compared cash disbursements back to the underlying ?Authorization to Provide Services and Seek Payment? forms, no exceptions were found in the expanded testing. The sample was not intended to be, and was not, a statistically valid sample. In our testing and review of children?s files for the accuracy of setting data in CINC as compared to the children?s written plan, the exception rate was 17%. The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the ?Authorization to Provide Services and Seek Payment? forms so that those plans can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child?s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Grantee Response Management agrees with the finding. See the Organization?s corrective action plan for management?s plans to address the internal control weaknesses noted in this finding. CDS will review the ?Authorization to Provide Services and Seek Payment? form and potentially change the authorization to only include private insurance and MaineCare. CDS will monitor the effectiveness of the corrective action plan to ensure the risks associated with financial reporting and noncompliance are mitigated.