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Feeley & Driscoll's OIG Update: April 2010 The Department of Health and Human Services Office of the Inspector General (HHS-OIG) was established by Congress in 1976 to identify and eliminate fraud, abuse, and waste in HHS programs and to promote efficiency and economy in departmental operations. The OIG is responsible for conducting audits, evaluations, and both criminal and civil investigations for all HHS agencies. These functions are performed by the OIG's Office of Audit Services (OAS). Feeley & Driscoll's OIG Update is a compilation of the latest and greatest additions from the OIG's website, listed in approximate order of greatness rather than lateness. This update is a monthly publication from the Healthcare Group at Feeley & Driscoll, P.C.
1. Review of Medicaid Administrative Costs Claimed for the Massachusetts Department of Transitional Assistance Of the $48.4 million ($24.2 million Federal share) that the Massachusetts Executive Office of Health and Human Services (EOHHS), Office of Medicaid (the State agency) claimed in Medicaid administrative costs for EOHHS, Department of Transitional Assistance, during Federal fiscal years 2006 and 2007 based on the final results of a random moment time-study, $898,000 ($449,000 Federal share) was misallocated to the Medicaid program as a result of insufficient documentation. In addition, the OIG could not express an opinion on the allowability of the remaining $47.5 million ($23.8 million Federal share) in Medicaid administrative costs because the OIG could not quantify the effect of the State agency’s deviations from acceptable statistical sampling methods. > Click here to view the full report 2. Review of the Missouri Department of Social Services Claim for Title IV-E Training Costs for Long-Term Training for July 1, 2002, Through June 30, 2006 Of the $3 million (Federal share) in Title IV-E long-term training costs that Missouri claimed at the enhanced 75-percent Federal financial participation (FFP) rate from July 1, 2002, through June 30, 2006, $301,000 was unallowable. Federal regulations authorize the Administration for Children and Families (ACF) to pay an enhanced 75-percent FFP rate for certain State training costs related to Title IV-E foster care and adoption assistance. The unallowable costs claimed included indirect costs that were not authorized for reimbursement at the enhanced rate, inadequately documented costs, and indirect costs that were claimed on an incorrect cost base. In addition, $1 million was potentially unallowable because the costs were not properly allocated to all benefiting programs as required by Federal regulations. The remaining $1.7 million claimed was allowable. The OIG recommended that the State adjust its next quarterly claim to reduce Federal reimbursement claimed for Title IV-E training by $301,000 (Federal share), work with ACF to determine an appropriate methodology to allocate $1.5 million ($1 million Federal share) in long-term training costs and make appropriate financial adjustments and revisions to the cost allocation plan as necessary, and strengthen its policies and procedures to ensure that it claims Federal reimbursement for Title IV-E training in accordance with Federal requirements and contractual provisions. The State generally disagreed with the first two recommendations and agreed with the third. The OIG maintain that their findings and recommendations are valid. > Click here to view the full report 3. Review of the Pension Segmentation Requirements for the Salaried Qualified Pension Plan at Blue Cross Blue Shield United of Wisconsin, for the Period January 1, 1986, to December 31, 1998 Blue Cross Blue Shield United of Wisconsin, through its United Government Services business unit, a Centers for Medicare & Medicaid Services contractor, understated the Medicare segment pension assets by $13,145, and overstated total company pension assets by $145,604, as of December 31, 1998, in its salaried defined benefit pension plan. > Click here to view the full report 4. Review of the Pension Segmentation Requirements for the Hourly Qualified Pension Plan at Blue Cross Blue Shield United of Wisconsin, for the Period January 1, 1986, to December 31, 1998 Blue Cross Blue Shield United of Wisconsin, through its United Government Services business unit, a Centers for Medicare & Medicaid Services contractor, understated the Medicare segment pension assets by $5,844 in its hourly defined benefit pension plan. > Click here to view the full report 5. Results of Limited Scope Review at Brooklyn, NY's Metropolitan Child Services, Inc.'s, Head Start Program The OIG reviewed the financial conditions at Metropolitan Child Services, Inc. (Metropolitan), as part of a nationwide series of reviews requested by the Administration for Children and Families (ACF), Office of Head Start, for use in its overall assessment of Head Start grantees that have applied for additional funding under the American Recovery and Reinvestment Act of 2009 (Recovery Act). The OIG found that Metropolitan used Head Start funds to pay non-Head Start expenditures. In addition, Metropolitan charged unallowable expenditures to its Head Start grant, did not properly allocate shared costs to all benefiting programs, and did not accurately report the financial status of its Head Start grant to ACF. Lastly, Metropolitan complied with Federal regulations related to program governance. The OIG recommended that ACF, in determining whether Metropolitan should be awarded additional Head Start and Recovery Act grant funding, consider the information presented in this report in assessing Metropolitan's capacity to manage and account for Federal funds. > Click here to view the full report 6. Results of Limited Scope Review at the Confederated Tribes and Bands of the Yakama Nation's Head Start Program The OIG reviewed the financial conditions at the Confederated Tribes and Bands of the Yakama Nation (the Yakama Nation) as part of a nationwide series of reviews requested by the Administration for Children and Families, Office of Head Start, for use in its overall assessment of Head Start grantees that have applied for additional funding under the American Recovery and Reinvestment Act of 2009. The Yakama Nation is fiscally viable. In addition, the Yakama Nation's financial management system adequately managed and accounted for Federal funds. However, the OIG noted weaknesses related to procedures for (1) submission of indirect cost rate proposals, (2) the administrative cost limit, and (3) property management. > Click here to view the full report 7. Review of Medicaid Services to Incarcerated Juveniles in the State of Georgia for Federal Fiscal Years 2003 and 2004 For Federal fiscal years (FY) 2003 and 2004, the Medicaid agency inappropriately claimed $3.8 million ($2.3 million Federal share) in costs relating to non-inpatient medical services provided to juvenile inmates of public institutions because neither the Georgia Department of Juvenile Justice (DJJ) nor the Medicaid agency had adequate controls to ensure that those services were excluded from Federal financial participation. The OIG recommended that the Medicaid agency refund the $2.3 million overpayment, identify and refund subsequent overpayments, and establish monitoring procedures to ensure the accuracy of Medicaid eligibility status codes. In written comments on the draft report, the Medicaid agency requested the OIG delay the release of their report until April 6, 2009, to give it "the opportunity to review each claim considered 'erroneously reimbursed.'" The OIG delayed issuance of their report; however, neither DJJ nor the Medicaid agency provided additional support for their assertion that juveniles voluntarily residing at the institutions were included in their overpayment calculation. > Click here to view the full report |
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