REPORT DIGEST

ILLINOIS DEPARTMENT OF HUMAN SERVICES

COMPLIANCE EXAMINATION
FOR THE TWO YEARS ENDED JUNE 30, 2017

Release Date:  June 14, 2018

FINDINGS THIS AUDIT:  42

CATEGORY:  NEW -- REPEAT -- TOTAL
Category 1:  15 -- 8 -- 23
Category 2:  7 -- 12 -- 19
Category 3:  0 -- 0 -- 0
TOTAL:  22 -- 20 -- 42

FINDINGS LAST AUDIT: 33

Category 1: Findings that are material
weaknesses in internal control and/or a
qualification on compliance with State laws
and regulations (material noncompliance).
Category 2: Findings that are significant
deficiencies in internal control and
noncompliance with State laws and
regulations.
Category 3: Findings that have no internal
control issues but are in noncompliance with
State laws and regulations.

State of Illinois, Office of the Auditor
General
FRANK J. MAUTINO, AUDITOR GENERAL

To obtain a copy of the Report contact:
Office of the Auditor General, Iles Park
Plaza, 740 E. Ash Street, Springfield, IL
62703
(217) 782-6046 or TTY (888) 261-2887

This Report Digest and Full Report are also
available on the worldwide web at
www.auditor.illinois.gov

INTRODUCTION

Because of the significance and pervasiveness
of the findings described within the report,
we expressed an adverse opinion on the
Department’s compliance with the assertions
which comprise a State compliance
examination. The Codification of Statements
on Standards for Attestation Engagements (AT-
C § 205.72) states a practitioner “should
express an adverse opinion when the
practitioner, having obtained sufficient
appropriate evidence, concludes that
misstatements, individually or in the
aggregate, are both material and pervasive to
the subject matter.”

Further, the digest covers our Compliance
Examination of the Department for the two
years ended June 30, 2017. A separate
Financial Audit as of and for the year ended
June 30, 2017, was previously released on
March 20, 2018. In total, this report
contains 42 findings, 11 of which were
reported in the Financial Audit.

SYNOPSIS

• (17-12) The Department of Human Services
and the Department of Healthcare and Family
Services did not have adequate controls to
ensure the social security information of
applicants for human services programs was
sufficiently supported.

• (17-14) The Department failed to finalize
and implement certain CILA rules and to
adequately monitor CILA providers during the
examination period.

INTRODUCTION

This report presents our Department-wide
compliance attestation examination for the
two years ending June 30, 2017. At June 30,
2017 the Department operated 6 Developmental
Centers, 7 Mental Health Centers, 1 combined
Mental Health and Developmental Center, and 3
Rehabilitation Services Facilities. The
findings are presented in the report
beginning at page 17.

FINDINGS, CONCLUSIONS, AND RECOMMENDATIONS

APPLICANT SOCIAL SECURITY INFORMATION IN IES
NOT SUFFICIENTLY SUPPORTED

The Department of Human Services and the
Department of Healthcare and Family Services
(Departments) did not have adequate controls
to ensure the social security information of
applicants for human services programs was
sufficiently supported.

The Departments have shared responsibility
for various human service programs in the
State, including the intake, processing, and
approval of applications for benefits. The
Departments have shared responsibility for
internal control over manual and automated
processes relating to eligibility for these
programs.

As part of our testing of the Integrated
Eligibility System (IES), we compared the
applications approved utilizing IES to the
Social Security Administration (SSA) Master
Death Records. We noted 164 approved
applicants had applied for services after the
date of death associated with the Social
Security Number (SSN) the applicant had
provided. In addition, we noted 39 approved
applicants had death dates associated with
the SSN the applicants had provided that were
prior to their birth dates within IES.

As part of the IES clearance process, the
applicant’s SSN is matched to the SSA in
order to determine if the SSN is valid. We
reviewed case information within IES for a
sample of five cases, noting the case
information documented the applicant’s SSN as
not being valid. However, it appeared each
case had been overridden by the caseworker,
thus allowing services. As a result, the
Departments incurred expenditures of $983,656
for applicants that may not have been
eligible for the benefits received. (Finding
12, page 42)

We recommended the Department of Human
Services work with the Department of
Healthcare and Family Services to improve
controls over caseworker involvement by
refining supervisory oversight to confirm all
applications are properly approved and
caseworkers are properly obtaining and
retaining documentation in IES to support
eligibility. In addition, we recommended the
Departments seek reimbursement for improper
payments.

The Departments accepted the recommendation
and stated over 1 million applications were
approved using the IES system during FY16 and
FY17. The 203 cases (0.019%) identified as
having a social security number in question
were entered into the system manually and
appear to have been entered incorrectly and
these cases will be corrected and any
improper payments identified will be
recouped. The Departments also stated IDHS
will discuss with HFS whether more stringent
edits or approvals should be implemented to
eliminate the approval of cases with
incorrect social security numbers.

FAILURE TO IMPLEMENT INTEGRATED LIVING RULES
AND ADEQUATELY MONITOR CILAS

The Department of Human Services (Department)
failed to finalize and implement certain
community integrated living arrangement
(CILA) rules. Further, the Department failed
to adequately monitor CILA providers during
the examination period.

Failure to Finalize and Implement Rules

The Community-Integrated Living Arrangements
Licensure and Certification Act (210 ILCS
135/9) states that by December 31, 2011, the
Department shall adopt rules under the
Illinois Administrative Procedure Act that
govern the assignment and operations of
monitors and receiverships for community-
integrated living arrangements wherein the
Department has identified systemic risks to
individuals served. The rules are required to
specify the criteria for determining the need
for independent monitors and receivers, their
conduct once established, and their reporting
requirements to the Department. These
monitors and receivers shall be independent
entities appointed by the Department and not
staff from State agencies.

During the examination period, we noted the
Department had drafted but had not yet
finalized and implemented rules related to
the assignment and operations of monitors and
receiverships for CILAs as required by the
Act.

Failure to Follow-up on Substantiated
Allegations and Publishing Testing Results on
Website

The Community-Integrated Living Arrangements
Licensure and Certification Act (210 ILCS
135/4 (g-5)) states as determined by the
Department, a disproportionate number or
percentage of licensure complaints; a
disproportionate number or percentage of
substantiated cases of abuse, neglect, or
exploitation involving an agency; an apparent
unnatural death of an individual served by an
agency; any egregious or life-threatening
abuse or neglect within an agency; or any
other significant event as determined by the
Department shall initiate a review of the
agency's license by the Department, as well
as a review of its service agreement for
funding. The Department shall adopt rules to
establish the process by which the
determination to initiate a review shall be
made and the timeframe to initiate a review
upon the making of such determination.

For 3 out of 3 (100%) community agencies
which had substantiated allegations in
FY2017, the Department could not provide
supporting documentation that the community
agencies had been subsequently reviewed by
the Department, as of our testing date in
December 2017.

In addition, the Community-Integrated Living
Arrangements Licensure and Certification Act
(210 ILCS 135/14) states that by July 1,
2012, the Department shall make available
through its website information on each
agency regarding licensure and quality
assurance survey results; licensure and
contract status; and substantiated findings
of abuse, egregious neglect, and
exploitation. The Department shall adopt
rules regarding the posting of this
information and shall inform individuals and
guardians of its availability during the
initial provider selection process.
?
During the examination period, it was noted
the oversight activities conducted by the
Department were not published as of our
testing date in December 2017. (Finding 14,
pages 46-47)

We recommended Department management comply
with the law by completing and adopting rules
related to the assignment and operations of
monitors and receiverships for CILA
arrangements as required by statute. In
addition, we recommended the Department
improve internal controls over providing
timely reviews of substantiated allegations.
Lastly, we recommended Department management
adopt a reasonable date for providing
information on its website for each agency
regarding licensure and quality assurance
survey results; licensure and contract
status; and substantiated findings of abuse,
egregious neglect, and exploitation, as
specified in the applicable Act.

The Department accepted the recommendation
and stated its Bureau of Accreditation and
Licensure (BALC) database manager will
provide updated survey results quarterly to
the Division of Developmental Disabilities
personnel for posting on the Division of
Developmental Disabilities (DDD) webpage. The
Department also stated this practice began
February 20, 2018 followed by an update on
April 25, 2018.

OTHER FINDINGS

The remaining findings are reportedly being
given attention by Department personnel. We
will review the Department’s progress towards
the implementation of our recommendations in
our next Audit/Examination.

AUDITOR’S OPINION

The financial audit report was previously
released. The auditors stated the financial
statements of the Department as of and for
the year ended June 30, 2017, are fairly
stated in all material respects.

ACCOUNTANT’S OPINION

The accountants conducted a compliance
examination of the Department for the two
years ended June 30, 2017, as required by the
Illinois State Auditing Act. Because of the
effect of the noncompliance described in
Findings 2017-001 through Finding 2017-042,
the accountants stated the Department did not
materially comply with the requirements
described in the report.

The financial audit and this compliance
examination was performed by RSM US LLP.

JANE CLARK
Division Director

This report is transmitted in accordance with
Section 3-14 of the Illinois State Auditing
Act.

FRANK J. MAUTINO
Auditor General

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