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Feeley & Driscoll's OIG Update: July 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.
Please visit us at: www.fdcpa.com/healthcare.htm. This OIG Update is also accessible from the F&D website, by visiting www.fdcpa.com/oig.updates.htm
- Results of Limited Scope Review at Tri-Town Economic Opportunity Committee
- Health Resources and Services Administration's Bureau of Primary Health Care Facility Investment Program Grants - Internal Control Review of the Process for Awarding American Recovery and Reinvestment Act Funds
- Review of Cahaba Government Benefit Administrators, LLC, Medicare Payments to Providers Terminated Between January 1, 2003, and January 31, 2007
- Results of Limited Scope Review of West Caldwell Health Council, Inc. (NC)
- Results of Limited Scope Review of Sisseton-Wahpeton Oyate Head Start Program
- Results of Limited Scope Review at Open Cities Health Center, Inc.
- Results of Limited Scope Review at Acelero Learning Clark County's Head Start Program
Results of Limited Scope Review at Tri-Town Economic Opportunity Committee
Based on the OIG’s assessment, Tri-Town Opportunity Committee (Tri-Town) is currently financially viable. OIG found that Tri-Town's financial management system was able to adequately manage and account for Federal funds except that Tri-Town did not always (1) ensure that inventory records were reconciled and accurate and (2) obtain competitive bids before awarding contracts. During Federal fiscal year 2009, Tri-Town received three grants under the American Recovery and Reinvestment Act of 2009 totaling approximately $1.7 million.
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Health Resources and Services Administration's Bureau of Primary Health Care Facility Investment Program Grants - Internal Control Review of the Process for Awarding American Recovery and Reinvestment Act Funds
The OIG’s review found that the Health Resources and Services Administration's Bureau of Primary Health Care internal controls for awarding American Recovery and Reinvestment Act of 2009 funds to Facility Investment Program grantees, as described by Bureau management, are suitably designed to provide reasonable assurance that the specified control objectives would be achieved if the described controls were complied with satisfactorily and applied as designed.
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Review of Cahaba Government Benefit Administrators, LLC, Medicare Payments to Providers Terminated Between January 1, 2003, and January 31, 2007
OIG did not identify material Cahaba Government Benefit Administrator, LLC (Cahaba), overpayments that were subject to recovery at the start of their audit for 388 of the 389 terminated providers whose payments the OIG reviewed. For the one remaining provider, Cahaba did not recover $5,000 in overpayments because it was unaware that the payments were unallowable. Cahaba confirmed that the overpayments were subject to recovery.
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Results of Limited Scope Review of West Caldwell Health Council, Inc. (NC)
The OIG reviewed the financial condition of West Caldwell Health Council, Inc. (West Caldwell) as part of a nationwide series of reviews of community health centers that have received funding under the American Recovery Act of 2009 (Recovery Act).
West Caldwell is financially viable, and if it continues to make progress in implementing certain programmatic improvement recommendations, it will have the capacity to manage and account for Federal funds and to operate its health center in accordance with Federal regulations. In this regard, OIG noted weaknesses related to the Board of Directors, project execution, safeguarding of assets, compliance with Federal cost principles, financial systems, and the whistleblower process.
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Results of Limited Scope Review of Sisseton-Wahpeton Oyate Head Start Program
The OIG reviewed the financial conditions at Sisseton-Wahpeton Oyate (SWO) as part of a nationwide series of reviews requested by the Administration for Children and Families (ACF), Office of Head Start, as part of 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 SWO implemented adequate corrective actions with respect to 5 of the 13 concerns identified by ACF during its triennial review in December 2008. However, 6 of the 13 concerns remained uncorrected by the end of their fieldwork. (OIG did not review 2 of the 13 concerns ACF identified because ACF agreed to review these 2 concerns separately.)
The OIG recommended that ACF, in determining whether SWO should be awarded additional Head Start and Recovery Act grant funding, consider the information presented in this report. SWO did not directly agree or disagree with their findings.
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Results of Limited Scope Review at Open Cities Health Center, Inc.
Based on the OIG’s assessment, open cities Health Center, Inc. (Open Cities) is financially viable, but certain trends for net assets and debt may undermine the grantee's fiscal stability if not kept in check. Furthermore, Open Cities has the capacity to manage and account for Federal funds and the capacity to operate a community health center in accordance with Federal regulations. However, OIG noted weaknesses related to its fiscal status as well as a lack of written policies and procedures for accounting for property, Federal Deposit Insurance Corporation deposit limits, and Federal grant reporting. Under the American Recovery and Reinvestment Act of 2009, Open Cities had received approximately $1 million in Federal funding.
The OIG recommend that the Health Resources and Services Administration consider the information presented in this report in assessing Open Cities ability to operate a Community Health Center in accordance with Federal regulations.
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Results of Limited Scope Review at Acelero Learning Clark County's Head Start Program
The OIG reviewed the financial conditions at Acelero Learning Clark County (Acelero Learning) 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 were unable to determine whether Acelero Learning is a fiscally viable Head Start grantee because only limited audited financial data covering its startup operations for the year ended December 31, 2007, were available at the time of their review. The OIG found that Acelero Learning's financial management system did not adequately manage and account for Federal funds. Specifically, Acelero Learning's management affiliation agreement with Acelero Learning, Inc. (Acelero Inc.) was a sole-source agreement and a less-than-arms-length transaction that violated generally accepted sound business practices and created a conflict of interest or the appearance thereof. In addition, Acelero Learning overcharged the Head Start program for Acelero Inc.'s management fees and other costs and undercharged the Extended Day and Food programs for these costs. Acelero Learning also charged the Head Start program for unallowable and unsupported costs. Furthermore, Acelero Learning's systems and internal controls related to accounting, personnel, procurement, and property management had weaknesses.
The OIG recommended that ACF, in determining whether Acelero Learning should be awarded additional Head Start and Recovery Act grant funding, consider the information presented in this report in assessing Acelero Learning's financial condition and ability to manage and account for Federal funds. Acelero Learning generally disagreed with their findings.
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