10/16/15: Ohio Medicaid School Program Audits

The Ohio Medicaid School Program is subject to various types of audits, with each one being somewhat different in scope and nature. The various audits also differ in the severity of the penalty assessed for audit findings. One type of audit may penalize you for just a single claim, while other types of audits extrapolate their finding and spread the penalty over multiple periods.

If and when your district is going through any type of Medicaid audit, please inform your billing vendor, so that they can assist you with gathering the required information, review information before it is given to auditors, and assist in interpreting the MSP rules.

Below is a description of various types of audits affecting the Ohio Medicaid School Program.

  • Agreed Upon Procedure (AUP) Audit – This is the annual audit that each MSP participating district must have performed by a CPA. This audit verifies costs reported on the Cost Report and also tests Paid Claims. Cost findings result in a cost adjustment, and claim errors result in a payback of only the individual claim amount received. The cost of this audit is a reimbursable expense on the Cost Report and is reimbursed at 50%.
  • Ohio Department of Medicaid (ODM) Desk Audit – The final Cost Report, along with the AUP Audit is filed with ODM and they review the Cost Report for reasonableness and outliers. Outlier Districts may be asked to submit additional data to support the Cost Report. After final adjustments are made, ODM computes each district’s Final Cost Settlement amount and adjudicates the order.
  • Ohio Auditor of State (OAS) Compliance Audit – There are around eight school districts that are currently undergoing an OAS audit, and two school districts with completed OAS audits. While these audits are somewhat similar to the AUP audits, the penalty for audit findings are much more costly. Any audit findings under this audit are extrapolated over the entire audit period.
  • Office of the Inspector General (OIG) Audit – OIG’s Director of Medicaid audits did a 1 ½ hour presentation at the NAME Conference on the states that are currently going through an OIG audit. The Ohio Medicaid School Program is now in its seventh year, so chances are high that OIG will be visiting our state soon. Their audit findings are also extrapolated and can be costly.
  • Centers for Medicaid and Medicare Service (CMS) Audit – Any Medicaid School Program expansion would require Ohio to open up its State Plan Amendment (SPA), which would certainly trigger a CMS audit of the entire program. That is why the timing of any program expansion is important, as we must get our program in order before CMS starts their audit.
  • CMS Claim Review – Periodically, CMS will want to review documentation related to an individual student. This type of audit reviews a specific date range of billed services on a particular student, and traces the service back to the IEP and ETR.

Below is a sample of common audit findings related to the Ohio Medicaid School Program.

IEP not signed by the therapist that recommended the service.

  • Services documented on days that the school attendance records show the student was absent.
  • Services documented were not properly listed on the student’s IEP.
  • OTA or PTA not properly supervised by the OT or PT.
  • Criminal Records Check not completed on a therapist.
  • Therapist was not included in the Random Moment Time Study (RMTS).
  • Therapist costs were paid using Federal Funds. (IDEA Title VI-B)

Once again, if you are selected for any type of MSP audit, make sure that your billing vendor is aware of the audit so that they can assist you.