Mark’s Opening Remarks September 2017
Dear Friends of ACT:
In January, the Missouri Medicaid Audit and Compliance (MMAC) Unit paid ACT a visit. They arrived with little advanced notice and asked for an enormous amount of documentation related to being a provider under a Medicaid Home and Community Based Services Waiver.
This audit, and the others I describe below, are routine. They are not triggered by problems at ACT. Other providers like ACT are subject to the same audits and reviews.
After that visit, we caught a brief break that gave us time to prepare for CARF accreditation. That survey in May occurs every three years. We invite them to come in.
We were accredited once again just like we have since 1987. We have always received the maximum three-year award. We’re proud of our CARF accreditation. It’s important.
Approved providers of Vocational Rehabilitation services must be accredited by CARF. Missouri Rehabilitation Services for the Blind also requires CARF accreditation.
Next we received notice that the Central Missouri Regional Office would come by in June for a fiscal review. They are a part of the Department of Mental Health, Division of Developmental Disabilities.
Melody Troesser, our Director of Financial Operations, sent a note out in May saying the review was going to “…affect more than just accounting!”
It did. They looked at attendance records, monthly notes, daily progress notes, and details about our direct care staff. They looked at the personal funds of some people we support in our individualized supported living homes. It was an extensive review.
Next came an audit of our retirement plans. Brian Tveitnes, Director of Human Resources, was the main contact for this review, which also occurred in June. An annual audit is required of employers who have 100 or more eligible participants in retirement plans like ours. An independent auditor, in this case the local firm Williams-Keepers, performs the audit.
If you’ve been through an audit, you know there’s a lag between the on-site evaluation and the final report of findings and conclusions. The auditors arrive and review records and ask questions. Then they go away to analyze what they’ve found. We often don’t know the results until months later. We hope to have a draft of this audit report soon.
Our friends from Williams-Keepers (same firm, different people) came back to see us in August, this time, for our annual fiscal audit. Melody Troesser, our DFO was again called upon to prepare for their visit. A ton of work goes into getting ready for this audit prior to their visit. Thankfully, this year we had our new Fund Accounting Software in place. It proved to be invaluable. And, it should only get better in the future.
This is a rigorous review, as it should be, with about $8.5 million dollars received during the previous fiscal year.
Our goal is to have these audit results ready to present to our Board of Directors on October 18th.
In August, the Regional Office folks came back again, this time to do a Provider Relations Review.
We had to provide documentation showing:
- staff are qualified and trained to meet people’s needs,
- a system is in place to ensure that individuals’ documentation contain required components,
- required policies and procedures are in place that support compliance with the Medicaid Home and Community Based Services Rule,
- a system is in place to ensure that staff support is provided as contracted, and
- our adherence to contract-specific requirements.
For accredited providers like ACT, this review occurs every three years.
All of these audits/reviews take place in addition to routine monitoring by the State or County that occurs either monthly or quarterly on a continuous basis.
Last year, ACT and other provider organizations that belong to the Missouri Association of Rehabilitation Facilities (MARF) asked MARF to send a letter to the Director of the Division of Developmental Disabilities questioning the redundancy of the PR Review for accredited organizations, since accredited organizations have deemed status. These audits and reviews cost money and use staff time. Costs could be reduced if we didn’t have to repeat certain parts of them.
Division Director Valerie Huhn responded that the provider review process is utilized to meet Waiver requirements, as required by Federal law. Further, when a provider signs a contract with the Department of Mental Health, the Department is allowed to access information to assure the Centers for Medicare and Medicaid Services (CMS) that providers meet requirements.
Director Huhn said that without a side-by-side comparison of accreditation requirements against Missouri-specific Waiver requirements, they can’t know whether CARF requirements are sufficient to meet Missouri’s.
Provider reviews will continue.
I don’t question the need for oversight of public funds that are used to purchase services. But I am questioning the redundancy that exists across the regulatory bodies to which we are accountable.
There are requirements in each that already exist in at least one other review. Perhaps it is an expensive undertaking, but I believe funds could be made available to support an effort to explore these overlaps. Eliminating a review step that is duplicated in another required review process could save significant money and time.
Even the Governor has recognized and acknowledged that some of the work required in State regulations is unnecessary, too costly, overly burdensome, or repetitive. In Executive Order 17-03, signed by Governor Greitens on January 10, 2017, he called for all State agencies to undertake a thorough process, including public comments and hearings, to identify rules whose costs outweigh the benefits or are adversely affecting Missouri citizens. State agencies are required to take action to repeal these regulations no later than June 30, 2018.
We are partners with these agencies and credentialing bodies in this effort to provide services and responsibly spend public funds. Let’s seek new approaches that allow us to complement each other, while promoting productive solutions that result in accountable and efficient outcomes.
Until next month,
P.S. The eclipse on August 21st was awesome. After the two and a half minutes of totality, Heath, an individual in our Day Program, looked over at us with a broad smile on his face and exclaimed, “Wicked.”