Probably the single most important issue currently with the Ohio Medicaid School Program is audits. I talked briefly about this issue several weeks ago, but this issue is so important that is deserves further explanation. There are four main types of audits currently being done right now with MSP.
AUP Audits – Annual “Agreed Upon Procedures” audits done by CPA firms.
ODM Desk Audits – Cost Report review done prior to issuing “MSP Final Settlement Payments”.
OAS Audits – Random Program Audits being done by the Ohio Auditor of State.
CMS PERM Audits – Random Claim Audits being done by the “Centers for Medicaid and Medicare Services”.
Agreed Upon Procedures (CPA) Audits – There have been changes made to the AUP Audit for each of the next three years (13/14, 14/15, and 15/16). I would also expect more changes to be made based on the AOS audits.
Ohio Department of Medicaid Desk Audits – The Ohio Department of Medicaid is expecting Interim Claiming to increase. Low Interim Claiming and high Final Settlements will result in more scrutiny during the desk review process. This additional scrutiny will slow the settlement process down for all districts. Adjudication letters for the 11/12 Final Settlements should be coming out soon.
Ohio Auditor of State Audits – These audits were ordered by the Ohio Department of Medicaid and they are not going well. I would expect that these audits of 10 random districts will be expanded to include more school districts. Findings in this audit will result in additional testing being added to the AUP Audit.
CMS Perm Audits – These audits test all paid claims for a specific student. Findings under these audits could result in a full CMS Audit of the entire district.
The two main areas tested in an MSP Audit are Paid Claims and Costs.
Paid Claim testing include:
- Were all the required elements documented by the therapist?
- Were the services properly listed on an IEP?
- Was a proper ETR completed for the student?
- Was the student present on the day of service?
- Did the providing therapist have the proper credentials?
- Was signed Parental Consent obtained for the student?
- Was proper progress documented for the student?
- Was proper supervision documented for therapy assistants?
Testing of Costs include:
- Were MSP Procurement requirements met?
- Was the service paid with non-Federal Funds?
- Is there proper invoices supporting the Costs?
- Were the Costs paid in the proper period? (Cash Basis)
- Were employed therapists properly reported on RMTS?
- Did the therapist provide service to IEP students? (Nursing)
- Were the Costs allowed per MSP rules? (Salary, Benefits, Contracted Therapy Costs)
Audit Findings – Many of the current MSP audit findings are a result of IDEA compliance issues. The majority of the current audit findings relate to:
- The IEP was not signed by the Related Services Therapist.
- The Related Service Therapist did not have a criminal records check.
- The OTA/PTA did not have proper supervision.
- Services billed were not listed on the IEP.
- Student was absent on the service date.
- IEP or Attendance Records were unavailable.
- Improper procurement of contracted services.
As more audits are completed, I will provide updates on additional findings. Contract Procurement, also an important MSP issue, will be covered in a future “MSP Topic of the Week”.
In closing, please remember that if your district goes through any MSP audit, contact your billing agent so that they can assist you with the process.