Finding 60658 (2022-003)

FINDING 2022-003 Information on the Federal Program: Federal Agencies: U.S Department of Health and Human Services Federal Programs: 93.778 Medical Assistance Program (Medicaid; Title XIX) Pass-Through Entity: Illinois Department of Healthcare and Family Services (HFS) Pass-Through Entity Award Numbers: 95-4900-00 Criteria: A. Per the Illinois Guide for School-Based Health Services Administrative Claiming Guide Section 740: "Payment will not be made to any entity in which a terminated or suspended or barred individual is serving as an employee, administrator, operator or in any other capacity for any services, including administrative and management services furnished, ordered or prescribed on or after the effective date of the sanction or voluntary withdrawal" and "In addition, no claim may be made for payments made for items or services provided by an individual or entity that has been barred or suspended or who has voluntarily withdrawn from the program" Furthermore, the Guide states that it is the responsibility of the LEA to assure that all claims for federal funds meet the requirement. B. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? Condition/Context: We tested a sample of twenty-five licensed medical professionals participating in medical services. For all twentyfive licensed medical professionals, documentation demonstrating that debarment and suspension searches were performed could not be provided by Chicago Public Schools. Our samples were not statistically valid. Cause: Chicago Public Schools? medical assistance policies do not include processes pertaining to conducting, monitoring, reviewing and documenting debarment and suspension checks for any licensed medical professional serving as an employee, operator or in any other capacity for any [Medicaid-related] service. Questioned Costs: Questioned costs, if any, are unable to be determined, however, actual expenditures that did not comply with debarment and suspension check requirement totaled $122,257. Effect: Chicago Public Schools is not in compliance with the Illinois Guide for School-Based Health Services Administrative Claiming Guide as it relates to debarment and suspension. Additionally, the effect of noncompliance can result in questioned costs. Recommendation: We recommend for Chicago Public Schools? Medical Assistance Program policies to include processes pertaining to conducting, monitoring, reviewing and documenting debarment and suspension checks in order to comply with the Illinois Guide for School-Based Health Services Administrative Claiming Guide. Ensure proper communication is delivered to relevant employees regarding any changes to policies and procedures. Views of Responsible Officials: CPS will implement a policy to verify practitioner credential records twice a year with the IL HFS and Federal Healthcare and Human Services (HHS) OIG websites as outlined in the LEA handbook. The Medicaid team will document the verification and obtain review and approval from the Medicaid Director. CPS will start the verification process in April, 2023 after the policy and procedure are finalized.