REPORT HIGHLIGHTS OVERSIGHT OF THE INDEPENDENT SERVICE COORDINATION (ISC) PROGRAM BY THE DEPARTMENT OF HUMAN SERVICES’ DIVISION OF DEVELOPMENTAL DISABILITIES PERFORMANCE AUDIT Release Date:  December 19, 2024 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, 400 West Monroe, Suite 306, Springfield, IL 62704-9849 (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 BACKGROUND: On May 15, 2023, the Illinois House of Representatives adopted House Resolution Number 66, which directed the Office of the Auditor General to conduct a performance audit of the oversight of the Independent Service Coordination (ISC) program by the Department of Human Services’ Division of Developmental Disabilities (DDD).  ISC agencies are contracted with DDD to provide case management/service coordination to individuals with developmental disabilities. It is the primary responsibility of the Grant Management Unit within DDD to provide monitoring and oversight to the ISC agencies based on all activities in the grant agreements. During the audit period FY21-FY23, there were eight ISC agencies providing case management services to an average of nearly 25,000 individuals with developmental disabilities.  These eight ISC agencies expended more than $133 million on ISC services. Key Findings: Funding for the ISC Program • The majority of funding provided to ISC agencies is for case management services supported by the Waiver program.  These services are billed on a fee-for-service basis and are based on a DHS calculation. The billings are limited to the maximum budget total for each grant.  During the audit period, DHS had not analyzed the formula that sets the rate which ISC agencies are reimbursed for case management services.  DHS has excluded ISC agency services from any external reviews and has not addressed the recommendations from the reviews involving aspects of the ISC program. • DHS rejected more than $1.7 million in case management bills submitted by the ISC agencies during the audit period.  While some of those rejections could have been for legitimate reasons, our analysis found that more than 40 percent of the total rejected bills were for an unknown error.  DHS could not explain the reasons for the unknown errors.  Further, DDD, the Division charged with oversight of the ISC agencies, does not regularly review the rejected billing data and does not have complete access to all rejected billings. Examination of ISC Caseloads • DHS does not have a set required minimum or maximum ISC case manager ratio (number of individuals served by a case manager) and does not track this ratio information.  The Community Services Act requires DHS to include case coordination services as part of its community services system and also establishes that one factor of the funding methodologies be staffing ratios. • DHS could not provide the addresses for the entire population of individuals served by ISC agencies.  As a result, we reviewed ISC agency coverage on a sample basis. During testing, we found that DHS did not adhere to the ISC Manual and utilized an unwritten policy to allow an individual to choose an ISC agency outside of the individual’s assigned region.  DHS could not provide any additional documentation to support its decision. ISC Agency Documentation and Reporting Allegations • ISC agencies are statutorily required to be mandated reporters of allegations of suspected abuse, neglect, and financial exploitation.  However, DHS does not know and does not track if ISC agencies are statutorily meeting the requirement to report all allegations to the four oversight entities:  DHS’ Office of Inspector General (OIG), Adult Protective Services (APS) within the Department on Aging, the Department of Children and Family Services (DCFS), and the Department of Public Health (DPH).  During testing, we did not find any instance of noncompliance by the ISC agencies with the mandated reporting requirement. • DHS does not regularly share allegation information with the ISC agencies.  In our sample of 75 individuals receiving waiver services, we identified 41 instances of allegations of abuse, neglect, or financial exploitation from OIG and APS data.  We found that ISC agencies had no documentation to support awareness of a known allegation in 30 out of 41 instances.  DHS stated that neither DHS nor anyone else is required to inform the ISC agency of an allegation or share the results of an investigation with the ISC agency. Oversight and Monitoring • It is the primary responsibility of the Grant Management Unit within DDD to provide monitoring and oversight to the ISC agencies based on all activities in the grant agreements.  However, DDD failed to adequately oversee and monitor the ISC program.  While ISC agencies receive a number of reviews, we found overlapping waiver-focused reviews and limited coordination with the Division. • DDD has not updated the ISC Manual to reflect the number of required waiver visits found in the FY23 grant agreements. Additionally, DDD has not updated the ISC Manual or the grant agreement to reflect the proper program codes, which was a pre-COVID pandemic change that went into effect more than five years ago. • ISC agencies are required to complete the person-centered planning process initially and annually.  The purpose of the person centered planning process is to gather information about an individual’s interests, preferences, and abilities and to outline the delivery of services.  During testing, we found missing or not timely discovery tool or personal plan updates in at least one fiscal year for 33 of 75 individuals sampled. • ISC agencies are also responsible for conducting monitoring visits to ensure implementation of the personal plan, as well as ensure the health, safety, and welfare of individuals receiving developmental disability services.  During testing, we found only 86 percent of the required visits were conducted for the 75 individuals sampled. • DHS did not monitor the Americans with Disabilities Act (ADA)/Olmstead Outreach and Housing Navigator pilot programs.  These programs were new for FY23 and provided a total of $725,000 in funding to the ISC agencies.  DHS failed to request grant funds back from one ISC agency, Champaign County Region Planning Commission, who received more than $49,000 in funding for both programs, yet admittedly did not conduct any of the required activities for either program.  We reviewed Housing Navigator program information and found three out of eight ISC agencies did not secure housing for a single individual as part of the Housing Navigator program.  Additionally, the ISC agencies did not always provide complete information on the required grant deliverables, and did not always conduct the training, presentations, and meetings as required. Key Recommendations: The audit report contains twelve recommendations directed to DHS including: • DHS should regularly and systematically review the ISSA formula utilized to fund the case management services provided by the ISC agencies. • DHS should regularly analyze the rejected billings and ensure the reasons for rejection are appropriate.  Additionally, DHS should specifically review billings rejected for an unknown error and facilitate any needed corrections. • DHS should set case manager ratios and should track ISC case manager information to ensure all grant required activities can reasonably be conducted. • DHS should follow the ISC Manual and require each individual to only be served by the ISC agency assigned to the specific region of residence.  If DHS decides to allow exceptions to the Manual, those exceptions should be included in a written policy and documented in individual case files. • DHS should ensure all allegations reported to oversight entities (including the DHS Office of the Inspector General, Adult Protective Services, the Department of Children and Family Services, and the Department of Public Health) for developmentally disabled individuals are maintained by DHS and shared with the respective ISC agencies. • DHS should update the ISC Manual and grant agreements to ensure accurate and consistent guidance is provided to the ISC agencies. This performance audit was conducted by the staff of the Office of the Auditor General.