REPORT DIGEST

COVERING ALL KIDS HEALTH INSURANCE PROGRAM

PROGRAM AUDIT
For the Year Ended: June 30, 2012

Release Date: December 2013


State of Illinois, Office of the Auditor General
WILLIAM G. HOLLAND, 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

SYNOPSIS

Public Act 95-985 amended the Covering ALL KIDS
Health Insurance Act [215 ILCS 170/63] and
directed the Auditor General to annually audit
the ALL KIDS program.  This is the fourth annual
audit and covers FY12.  The focus of this audit
is on “EXPANDED ALL KIDS,” which is the portion
of the ALL KIDS program that serves uninsured
children not previously covered by KidCare
(children whose family income was greater than
200 percent of the federal poverty level or who
were undocumented immigrants).

This FY12 audit follows up on the Department of
Healthcare and Family Services’ (HFS) and the
Department of Human Services’ (DHS) actions to
address prior audit findings.  Our audit found:

• In FY12, 92,879 children were enrolled in the
EXPANDED ALL KIDS program.

• Total claims paid in FY12 for the EXPANDED ALL
KIDS enrollees were $77.2 million.

• FY12 ALL KIDS claim data included 193
recipients who received 1,802 services totaling
$80,752 after the month of their 19th birthday,
when their eligibility ended.  Additionally, the
data included 246 individuals who appeared to be
enrolled with more than one identification
number.

• Our FY12 review indicated a continued problem
with HFS incorrectly categorizing documented
immigrants as undocumented in its data.
However, HFS noted that manual reviews were
being completed and as of February 1, 2013, $1.2
million in federal match for the individuals
identified by our previous audit had been
received.

• While HFS and DHS took action to address the
previous recommendations, many of these actions
did not occur within this audit period (FY12).
We determined that one recommendation was
implemented and 10 were repeated.

Future audit populations will be decreased due
to the passage of PA 96-1501, which made
children whose families’ household income is
above 300 percent of the federal poverty level
(FPL) ineligible for EXPANDED ALL KIDS.

In June 2013, Illinois was retroactively
approved back to July 1, 2008, to receive
federal reimbursement under Title XXI of the
Social Security Act for citizens and documented
immigrant children in EXPANDED ALL KIDS Premium
Level 2.

Due to the limited time for HFS and DHS to
implement prior audit recommendations, the
General Assembly may wish to consider reducing
the frequency of the EXPANDED ALL KIDS audit
period from annually to at least once every
three years or on a more frequent basis if
determined necessary by the Auditor General.

FINDINGS, CONCLUSIONS, AND RECOMMENDATIONS

BACKGROUND

Effective July 1, 2006, Illinois’ KidCare
program, which included Medicaid and Children’s
Health Insurance Program (SCHIP) populations,
was expanded by the Covering ALL KIDS Health
Insurance Act (Act) to include all uninsured
children not previously covered.  The expansion
added children whose family income was greater
than 200 percent of the federal poverty level
and all undocumented immigrant children.  At
that time, the KidCare program was renamed ALL
KIDS.  Since the EXPANDED ALL KIDS program is a
subset of a much larger ALL KIDS program, many
of the recommendations in this report may be
relevant to the program as a whole.

Throughout this audit, we will refer to the
portion of the ALL KIDS program that serves the
uninsured children not previously covered by
KidCare as “EXPANDED ALL KIDS.”  The children
who were added as a part of the expansion were
not eligible for federal reimbursement and thus
are funded entirely by the State.

Public Act 95-985 amended the Covering ALL KIDS
Health Insurance Act [215 ILCS 170/63] directing
the Auditor General to annually audit the
EXPANDED ALL KIDS program beginning June 30,
2008, and each June 30th thereafter.  The Public
Act was effective June 1, 2009.  This is the
fourth audit (FY12).  The first audit (FY09) was
released in May 2010 and contained 13
recommendations.  The second audit (FY10) was
released in April 2011 and contained 14
recommendations.  The third annual audit (FY11)
was released in October 2012 and contained 11
recommendations.

This FY12 audit of the EXPANDED ALL KIDS program
follows up on the Department of Healthcare and
Family Services’ (HFS) and the Department of
Human Services’ (DHS) actions to address prior
audit findings.  Many of the previous audit
recommendations that were addressed by HFS and
DHS were not addressed until FY13.  Since this
annual audit’s time period is FY12, we will
review these changes in future audits. (pages
2-5)

Recent Changes to the Covering ALL KIDS Health
Insurance Program

Two events in recent years will have a
significant impact on the EXPANDED ALL KIDS
program and our audits.  The first was the
passage of Public Act 96-1501, which added an
income limit for determining eligibility for the
EXPANDED ALL KIDS program.  Effective July 1,
2011, children whose families’ household income
is above 300 percent of the federal poverty
level (FPL) are no longer eligible.  Children
enrolled as of July 1, 2011, were able to remain
enrolled in the program until June 30, 2012.
Eliminating eligibility for children in families
with household income above 300 percent of the
FPL will reduce the number of Program
participants and expenditures to be audited.

The second occurred on June 4, 2013.  HFS
received a notification from the federal
Department of Health and Human Services (HHS)
that Illinois was approved to receive federal
reimbursement for citizens and documented
immigrant children in a family with income up to
300 percent of the FPL under Title XXI of the
Social Security Act, as reauthorized under the
Children’s Health Insurance Program
Reauthorization Act of 2008 (CHIPRA).  CHIPRA
was formerly titled the State Children’s Health
Insurance Program (SCHIP).  HFS applied for this
reimbursement on March 31, 2009.  HFS officials
noted that the only State law that provides
coverage to children in families with income
between 200 and 300 percent of the FPL is the
Covering ALL KIDS Health Insurance Act (All Kids
Premium Level 2).

Our prior EXPANDED ALL KIDS audits have only
included children whose medical care was totally
State-funded.  The federal government granted
the State retroactive reimbursement for this
population (children from families with income
between 200 and 300 percent of FPL) dating back
to July 1, 2008.  As of September 2013, HFS
officials indicated they are in the exploratory
phase as to their approach for recovering these
federal matching funds.  We will follow up on
HFS’s efforts to obtain retroactive
reimbursement as part of the FY13 audit. (page
12)

Matter for Consideration by the Illinois General
Assembly

HFS and DHS accepted all recommendations from
our past ALL KIDS audit and have been working to
implement them.  The Covering ALL KIDS Health
Insurance Act requires the Auditor General to
conduct an annual audit of the EXPANDED ALL KIDS
program.  However, with an annual audit, HFS and
DHS have had limited time to implement the
recommendations before the next audit period
began.

Due to the limited time for HFS and DHS to
implement prior audit recommendations before the
next audit begins, and the decline in EXPANDED
ALL KIDS participants (discussed above), the
General Assembly may wish to consider reducing
the frequency of the EXPANDED ALL KIDS audit
period from annually to at least once every
three years or on a more frequent basis if
determined necessary by the Auditor General.
(pages 13-14)
ALL KIDS Program

In FY12, Illinois’ ALL KIDS program as a whole
had almost 1.9 million enrollees and HFS paid
$2.6 billion in claims.  In FY12, enrollees that
were eligible at any point in the year as a
result of the July 1, 2006 ALL KIDS expansion
totaled 92,879.  As seen in Digest Exhibit 1, on
June 30, 2012, there were 67,616 enrollees as a
result of the expansion of which 47,282 (70%)
were classified as undocumented immigrants in
the HFS data. (pages 6-7)

Payments for ALL KIDS Services

According to data provided by HFS, in FY09 the
payments for services that were added as a
result of the July 1, 2006 expansion totaled
$79,068,335.  The payments for services
increased to $84,199,508 in FY10 and to
$96,556,069 in FY11.  In FY12, the total
payments for services dropped to $77,174,711.
We questioned HFS about the large decrease in
payments.  HFS indicated that the decrease in
payments was due to the payment cycle and not a
decrease in services.  The majority of the
payments for services were for undocumented
immigrants.  Payments for undocumented
immigrants totaled $54.9 million in FY09, $59.2
million in FY10, $58.8 million in FY11, and
$48.3 million in FY12.

Digest Exhibit 2 breaks out the payments for
services by whether the child had documentation
for citizenship/immigration status or whether
the child was undocumented for both FY11 and
FY12.  However, due to HFS incorrectly
categorizing some documented immigrants as
undocumented immigrants, the payments for
undocumented immigrants are overstated, while
the payments for documented immigrants are
understated. (pages 7-8)

Cost for Services Provided in FY12

As noted above, the decrease in payments from
$96.6 million in FY11 to $77.2 million in FY12
was due to the payment cycle and not a decrease
in services.  This means that the services may
have been provided in FY12, but were not paid
until FY13.

To determine the actual cost for services
occurring during the fiscal year for the ALL
KIDS program, we requested the cost for services
that were provided in each of the last three
fiscal years from HFS.  We determined that the
cost for services provided during the fiscal
year increased from $89 million in FY10, to
$89.3 million in FY11, and decreased slightly to
$87.8 million in FY12. (page 9)

Payments vs. Premiums Collected

In FY11, HFS received approximately $10.8
million in premiums from enrollees, thus making
the net cost of the ALL KIDS expansion
approximately $85.8 million.  In FY12, based on
a report provided by HFS, HFS received almost
$10.5 million in premiums, thereby decreasing
the net cost of the ALL KIDS expansion to almost
$66.7 million.  We requested the amount of
unpaid premiums for EXPANDED ALL KIDS in FY12
from HFS.  HFS officials indicated the accounts
receivable system tracks unpaid premiums by
family and not by individual.  As a result,
since families could have family members in
various medical programs, outstanding premium
payments for a specific program such as EXPANDED
ALL KIDS could not be provided.  Digest Exhibit
3 shows both FY11 and FY12 payments and premiums
collected from the EXPANDED ALL KIDS program.
(page 11)

Follow up on FY11 Recommendations

While HFS and DHS took some action to address
the previous recommendations, many of these
actions did not occur within this audit period
(FY12).  As a result, many recommendations are
repeated in this audit.  We determined that one
recommendation was implemented and 10 were
repeated. We will continue to follow up on the
actions taken after our period during our FY13
annual audit. (pages 2-3)

Redetermination of Eligibility

In the FY09 audit, auditors concluded that the
annual reviews of ALL KIDS eligibility – also
called redeterminations – required by the
Illinois Administrative Code [89 Ill. Adm. Code
123.260] were not being adequately implemented
by HFS.  For ALL KIDS enrollees that fall in the
Assist, Share, and Premium Level 1 categories
(e.g., at or below 200 percent of the federal
poverty level), an annual “passive”
redetermination was used by HFS.  Prior to the
end of the eligibility period, HFS sent each
family an annual renewal notice.  The renewal
notice listed the eligibility information for
the family and instructed the family to return
the form only if any of the information had
changed.  If there were no changes, the family
was instructed to do nothing.  In contrast, to
continue coverage, enrollees in Premium Levels 2
through 8 were required to send in the annual
redetermination form, which included updated
eligibility information.

This recommendation to adequately implement
eligibility redeterminations was repeated in our
FY10 and FY11 audits.  Effective October 1,
2011, Public Act 96-1501 required verification
of one month’s income for determining continued
eligibility (instead of passive
redetermination).  According to HFS officials,
the passive renewal process ended in July 2012,
but corrective action did not begin until
January 2013.  Actions taken to implement this
recommendation were included in the contract
with a third party vendor, which began
performing electronic eligibility verifications
after this audit period.  Since corrective
action was not taken during FY12, this
recommendation is repeated and will be followed
up on during the next audit cycle, which covers
the period July 1, 2012, to June 30, 2013.
(pages 15-16)

Income of Stepparent

During the review of HFS and DHS policies during
the FY09 audit, auditors determined that DHS did
not calculate family income for EXPANDED ALL
KIDS eligibility as required by the
Administrative Code.  The Administrative Code
[89 Ill. Adm. Code 123.110] defines family as
the child applying for the program and
individuals who live with the child, which
includes “the spouse of the child’s parent”
(i.e., the child’s stepparent).  Therefore, the
income calculation for any child receiving
services under the Covering ALL KIDS Health
Insurance Act (i.e., those children whose
services are totally State funded) should
include the income of the stepparent.

HFS and DHS officials indicated that the policy
has been updated and now requires stepparent
income to be included when determining
eligibility.  In this FY12 audit, we reviewed 16
eligibility files and determined that in all 8
of the cases with a stepparent in the household,
the income of the step-parent was included when
determining eligibility. Therefore, this
recommendation is implemented. (pages 16-17)

Non-Payment of Premiums

During the FY09 and FY10 audits, auditors found
that HFS did not terminate ALL KIDS coverage
when the enrollee failed to pay premiums timely
as required by 89 Ill. Adm. Code 123.340(a).
Auditors also found that HFS and DHS did not
have controls in place to ensure that families
who were previously terminated from coverage met
re-enrollment requirements found in the
Administrative Code.  The Administrative Code
[89 Ill. Adm. Code 123.210(c)(2)] requires full
payment of premiums due, for periods in which a
premium was owed and not paid, before the child
can be re-enrolled.  Additionally, the
Administrative Code [89 Ill. Adm. Code
123.210(c)(4)] requires the first month’s
premium be paid if there was an unpaid premium
on the date the child’s previous coverage was
cancelled.

During the FY11 audit, HFS noted that it was in
discussion with DHS regarding system
enhancements that could be made to the Automated
Intake System so the proper coding would be
automatically applied to these cases to prevent
re-enrollment of children with outstanding
premium debt.  According to HFS officials, DHS
has been providing reports to HFS for
individuals that did not pay premiums since
October 2012.  Consequently, corrective action
taken by HFS and DHS staff did not occur until
FY13 and the effects of corrective action would
not be reflected in the FY12 eligibility data.
Therefore, this recommendation is repeated and
testing will be performed during the next audit
cycle. (pages 17-18)

ALL KIDS Data Reliability

Auditors identified five specific issues
associated with the FY09, FY10, and FY11 data
provided by HFS.  These five areas were: 1)
eligibility data included individuals that were
older than 18 years of age; 2) eligibility data
included duplicate enrollees with two different
recipient identification numbers, and/or
different birth dates or addresses; 3)
eligibility data included end dates that were
not accurate; 4) irregularities between claims
and eligibility data; and 5) some documented
immigrants were categorized as undocumented
immigrants.  The number of undocumented
immigrants as well as the cost associated with
them in the EXPANDED ALL KIDS program were
overstated due to the incorrect categorizing of
documented immigrants.

We continued to find that eligibility data
contained individuals who were enrolled in ALL
KIDS more than once.  In the FY12 data, we
identified 246 individuals who appeared to be
enrolled with more than one identification
number.  We also identified 193 recipients that
received 1,802 services totaling $80,752 after
the month of their 19th birthday.  Therefore,
the status of this part of the recommendation is
repeated and will be followed up on during the
next audit cycle, which covers the period July
1, 2012, to June 30, 2013. (pages 18-19)

Classification of Documented Immigrants

During the FY09 audit, auditors determined that
HFS did not accurately classify documented
immigrants who receive ALL KIDS services.
According to HFS officials, to ensure that
federal matching funds were not requested for
documented immigrants who were ineligible for
matching funds (i.e., those documented
immigrants who had not been in the country for
five years), those documented immigrants were
classified as undocumented immigrants.

In an updated response to the FY11 audit, HFS
noted that the recommendation was partially
implemented and new coding now more accurately
records immigration status.  HFS noted that
manual reviews were being completed and as of
February 1, 2013, $1.2 million in federal match
for the individuals identified by the audit had
been received.

HFS also indicated that the incorrect
classification of immigrants was due to a
matching problem with the Social Security
Administration.  According to HFS, the matching
process is done monthly to continuously improve
its data.  HFS officials noted changes are made
when they identify an undocumented recipient
with a social security number that is matched
incorrectly.  Since this process is on-going,
the status of this recommendation is repeated
and will be followed up on during the next audit
cycle. (pages 19-20)

Duplicate Claims

As part of our review of EXPANDED ALL KIDS
payments, auditors analyzed FY10 claim data and
identified potential duplicate payments.  A
sample of 20 pairs of potential duplicate claims
was chosen because the claims had the same
recipient, same service date, same procedure,
and both providers were paid the State maximum
rate for the procedure.  The judgmental sample
of 20 possible duplicate claims was provided to
HFS for explanation.

HFS reviewed the 20 potential duplicate pairs of
claims and determined that 7 were duplicates.
Examples of the seven duplicates included:
claims submitted by the physician and by the
hospital or clinic; and claims submitted by two
different physicians.  The seven duplicate
claims totaled $1,428.

HFS officials indicated that implementation of
this recommendation is still in progress. Since
implementation of corrective action was not
taken during the FY12 audit period, this
recommendation is repeated.  Detailed testing
will be performed in the next audit cycle.
(pages 20-21)

Eligibility Documentation

All three of the previous ALL KIDS audits found
that, due to the way HFS implemented the
Covering ALL KIDS Health Insurance Act, HFS and
DHS did not obtain documentation to support
eligibility in some instances.  This included
documentation for residency, birth, and income.
As a result, auditors could not determine
whether eligibility was determined correctly by
HFS and DHS.

On January 25, 2011, Public Act 96-1501 was
adopted, which addressed some of this
recommendation.  The Public Act mandated two
changes to eligibility documentation
requirements.  These changes required one
month’s worth of income verification for
determining eligibility and required
verification of Illinois residency.  These
changes were effective on July 1, 2011.

According to both HFS and DHS officials,
effective March 14, 2012, an automated Secretary
of State clearance was completed to verify
residency.  We tested whether HFS and DHS were
verifying Illinois residency after March 14,
2012.  We selected 50 cases identified by DHS
that had eligibility beginning in June 2012.
Both DHS and HFS pulled electronic and paper
files for our review.  HFS and DHS could not
locate three of the recipient files, and an
additional recipient file sampled had an
application date prior to March 2012.  Of the
remaining 46 files reviewed, we found that
residency was verified in 44 of the 46 files.
Of the 44 recipients verified, 20 had
eligibility verified by the Secretary of State
clearance and 24 were verified by various forms
of documentation.  Documentation of residency
verification included a social security number
match with the Illinois Secretary of State’s
Office or hard copy documentation such as
addresses on bills, Mexican Consular
identification cards, driver’s licenses, or pay
stubs.  Each of these documents contained the
applicant’s Illinois address.  Although progress
was made, in the 49 applicable files tested,
proof of residency verification was not found in
two files and three additional files were not
able to be located by HFS and DHS; therefore,
this part of the recommendation is repeated and
will be followed up on in future audits.

In addition, HFS and DHS indicated that the new
income requirement was not addressed in FY12.
As a result, since HFS and DHS have not
implemented the required one month’s worth of
income requirement, the status of this part of
the recommendation is repeated.  This
recommendation will be followed up on during the
next audit cycle.  Also, according to both HFS
and DHS, neither agency has addressed the
portion of the recommendation related to
applicants who are self-employed; therefore, the
status of this part of the recommendation is
repeated. (pages 21-23)

Transportation Claims

During the review of FY10 EXPANDED ALL KIDS
claim data, auditors determined that HFS did not
have effective controls over transportation
claims.  As a result, transportation providers
were able to bill multiple trips in a single day
for the same recipient.  Additionally, controls
in the billing system do not contain edits for
pickup or drop off times or locations.  In its
updated responses, HFS indicated that corrective
action was taken to address this recommendation
prior to the current audit period.  This
includes implementing system edits to allow only
one round trip per day and sending notices to
providers reminding them to submit accurate
claim details.

We reviewed FY12 transportation claims and
continued to find duplicate transportation
claims and claims with inaccurate details.  Our
review identified seven providers that billed
202 duplicate services totaling $1,524 in FY12.
We also identified 141 services totaling $2,925
that did not have the necessary information to
make any determinations about the services that
were provided.  For example, there were several
instances where all the origin and destination
times for a given day for a recipient were all
the same.  Likewise, there were several
instances where the origin and destination
locations were all the same.  Since it was not
possible to determine where and when these
recipients were picked up and where and when
they were dropped off, it is unclear how the
claims were approved for payment.

Since we continue to find issues with
transportation claim documentation, the status
of this recommendation is repeated.  This
recommendation will be followed up on during the
next audit cycle. (pages 23-24)

Optical Edits

During the review of FY10 EXPANDED ALL KIDS
claim data, auditors determined that HFS did not
have effective controls over optical claims.
HFS allows children to receive as many
eyeglasses as needed through the Department of
Corrections – Illinois Correctional Industries
(ICI) without prior approval. As a result,
optical providers were able to bill for multiple
frames and fittings for same recipient during
the year. Specifically, auditors identified one
provider with a large number of recipients
receiving multiple frames and fittings during
FY10.  Additionally, auditors also determined
that HFS did not have effective controls in
place over the number of eye exams billed for
each recipient.

Due to this provider’s high correlation of
customers with multiple pairs of frames received
during FY10, auditors reported this provider to
HFS and to the HFS-OIG for further
investigation.  The HFS Office of the Inspector
General (OIG) noted it was aware of this
provider’s billing patterns and was in the early
stages of auditing this provider.  We followed
up with the OIG in the FY11 audit; the OIG
failed to act on our referral and noted it could
not find a case on this provider.

In an updated response to this recommendation,
the HFS OIG stated that it was in the process of
developing predictive modeling routines related
to optical care.  The OIG also noted it ran data
mining routines to determine children with
multiple eyeglass expenditures, and requested
charts to determine whether the multiple
eyeglasses were medically necessary or if there
was evidence of fraud, waste, or abuse.  During
our FY12 review, the OIG had not completed a
review, but indicated it was currently auditing
the provider that was identified in the FY10
audit.

Since the steps taken by the OIG occurred after
our FY12 audit period, the status of this
recommendation is repeated.  Therefore, this
recommendation will be followed up on during the
next audit cycle. (pages 24-25)
Guidance Over Preventive Medicine Service Claims

During the review of FY10 EXPANDED ALL KIDS
claim data, auditors determined that HFS did not
have effective controls over the billing of
preventive medicine service claims.  The claims
are for preventive medicine services for healthy
children who are established patients.
According to an HFS official, preventive
medicine services are used for annual doctor
visits and are not to be used numerous times per
year.  These services generally bill at a higher
rate than a problem focused visit.  In the FY10
EXPANDED ALL KIDS claim data, we identified
1,013 recipients that received three or more
preventive medicine services for healthy
children.

During our review of the FY12 data, auditors
continued to identify EXPANDED ALL KIDS
recipients that received preventive medicine
services for healthy children during FY12 that
exceeded the benefit limitation.  The Handbook
for Providers of Healthy Kids Services
establishes the number of preventive medicine
services allowed per year by age of the
recipient.  We identified 2,255 recipients that
received 2,732 preventive medicine services in
excess of the limit.  According to HFS, controls
were not set up to address this until December
2012.  As a result, the status of this
recommendation is repeated and will be followed
up on during the next audit cycle, which covers
the period July 1, 2012, to June 30, 2013.
(pages 25-26)
Inconsistent Dental Policies

During our review of FY10 EXPANDED ALL KIDS
dental claims, we found deficiencies in controls
related to dental billings.  Auditors found
instances in FY10 data where dental services
were paid for in excess of the allowed benefit
schedule.  Auditors also found instances where
the allowed benefit schedule differed from what
officials said was allowed and from what was
posted on HFS’ ALL KIDS Dental Services webpage.
Additionally, we identified billing outliers
within the dental claims.  These irregularities
were reported to the Department of Healthcare
and Family Services for follow-up and/or
investigation.

In this FY12 audit, we analyzed the data and did
not find instances of payments beyond the
established frequency limits for periodic oral
examinations, sealants, and prophylaxes
(cleanings).

Additionally, in the FY10 and FY11 audits, we
recommended that HFS ensure that dental policies
or other information available to the public
accurately states frequency of benefits.  We
found in our FY12 review, the ALL KIDS Dental
Services webpage still states that children are
limited to a periodic oral exam once every 12
months per dentist, whereas the Dental Office
Reference Manual schedule of Benefits still
states that children can receive an oral exam
once every 6 months in an office setting and
once every 12 months in a school setting.  HFS
indicated that it was in the process of revising
the Dental Office Manual and Administrative
Rules to accurately state frequency and
benefits.  As a result, the status of this part
of the recommendation is repeated and will be
followed up on during the next audit.

During this audit, we followed up on providers
that we referred to the HFS OIG during our FY10
audit.  In response to our inquiry, the OIG
noted one provider was audited and the provider
repaid $9,471.  The OIG performed Quality of
Care Reviews which found no issues for two of
the other providers referred in FY10.  For the
last provider, the OIG initiated a Special
Project Audit in FY10 which was never completed.
During our review of top ten providers in FY12,
we found this provider continued to have a high
average cost per client or other outliers, and
again referred this provider to the OIG.
According to the OIG, it is currently auditing
this provider. (page 27)

RECOMMENDATIONS

The audit report contains 10 recommendations.
Eight recommendations were specifically for the
Department of Healthcare and Family Services.
Two recommendations were for both the Department
of Healthcare and Family Services and the
Department of Human Services.  The Department of
Healthcare and Family Services and the
Department of Human Services agreed with all 10
recommendations.  Appendix H to the audit report
contains the agency responses.

WILLIAM G. HOLLAND
Auditor General

WGH:SAW

AUDITORS ASSIGNED:  This Program Audit was
performed by the Office of the Auditor General’s
staff.