Louisiana Legislative Auditor:
A Closer Look at Three Recent
Reports
Melissa Barbato, Senior Performance Auditor
Cassadara Johnson, Senior Performance Auditor
David Leingang, Senior Data Analyst
March 12, 2014
• Special Supplemental Nutrition Program for Women,
Infants and Children (WIC), Office of Public Health,
Department of Health and Hospitals, November 2013
• Medicaid Participant Fees Paid for Deceased Individuals,
Department of Health and Hospitals, October 2013
• Monitoring of Non-Secure Residential Contract
Providers, Office of Juvenile Justice, January 2014
Special Supplemental Nutrition
Program for Women, Infants and
Children (WIC)
Melissa Barbato, Senior Performance Auditor
• Special Supplemental Nutrition Program for
Women, Infants, and Children
• Federal U.S. Department of Agriculture
program
• Louisiana’s $126 million program certified
about 145,000 participants in FY12
• Pregnant women, breastfeeding women,
postpartum women, infants, children up to
age 5
• Must meet income requirements
• Must be a Louisiana resident
• Must have a nutrition-related problem
• Nutrition education
• Healthy foods, such as:
–
–
–
–
–
Milk
Eggs
Whole grain bread
Fruits
Vegetables
• Food
instruments
• Redeemed
at vendor
locations
• WIC vendors are authorized by OPH
• 723 vendors across Louisiana in FY12
• Vendor types
• OPH should strengthen its process for
administering and monitoring vendors and
clinics.
• We will discuss four of the nine findings
today.
• OPH assigns vendors to groups, or tiers
• Based on self-reported sales volume and
location
• Rural/small sales volume vendors can
generally charge more than large urban
vendors
Tier
Description
1
Urban Vendor & $200,000+ in sales
2
Rural Vendor & $30,000-$100,000 in sales
3
Rural Vendor & less than $30,000 in sales
4
Urban Vendor & less than $200,000 in sales
5
6
WIC Only Vendor
Above 50% Vendor
7
Rural Vendor & $100,000+ in sales
Source: Prepared by legislative auditor’s staff using WIC redemption data, January-June 2013
• Some vendors may
have charged too
much, while others
may not have charged
enough
• Overall, vendors may
have overcharged the
program an estimated
$655,132
Assigned Tier
Correct Tier
# Vendors
Potential
Overcharge /
Undercharge
1
7
21
-$31,407.35
3
1
35
$176,329.73
7
1
144
$381,225.29
Source: Prepared by legislative auditor’s staff using WIC redemption data, January-June 2013.
• We recommended that OPH develop a
review process to ensure it assigns vendors
to the correct tier.
• OPH agreed.
• Attempts to redeem food instruments over
the maximum are rejected
• Vendors are required to submit monthly
price reports
• OPH did not verify the accuracy of prices
Vendor
Total WIC food
items priced
Total accurate
prices
Total inaccurate
prices – too high
Vendor #1
44
33
11
Vendor #2
14
6
8
Vendor #3
20
12
8
Total
78
51 (65%)
27 (35%)
Source: Prepared by legislative auditor’s staff using August 2013 price information.
• We recommended that OPH modify its
routine monitoring process to include
verification of the vendor’s prices.
• OPH agreed.
• “High risk” vendors have a high probability
of program abuse
• Federal requirements
• FY12 discrepancy: 24 or 5 high risk vendors?
• No required FY12 activity documented for 2
of the 5 high risk vendors
• Smaller vendors redeemed large numbers of
transactions over time:
– One vendor had over 38,000 paid
transactions totaling approximately $873K
in FY13
• Vendors with high numbers of “even dollar”
transactions:
Vendor (Top Five)
# Even Dollar
Transactions
Total Amount
Vendor #1
1,311
$32,944
Vendor #2
1,081
$7,721
Vendor #3
702
$23,183
Vendor #4
483
$14,740
Vendor #5
455
$17,214
4,032
$95,802
Total
Source: Prepared by legislative auditor’s staff using redemption data and other OPH vendor data.
• Vendors consistently redeemed at/near the
maximum amount:
% Maximum
# Vendors
95
96
97
98
99
100
375
315
339
290
268
206
Source: Prepared by legislative auditor’s staff using data from Solutran.
Amount
$58,209.76
$56,214.95
$71,267.89
$66,729.82
$39,991.68
$48,471.25
• Vendors with high numbers of returned food
instruments:
Return Reason
# Vendors
Stale Dated
Early Cashing
Altered
Unreasonable Dollar Amount
(Above Max for Food Instrument)
153
465
427
$13,373.88
$117,480.66
$138,758.51
611
$724,155.81
Source: Prepared by legislative auditor’s staff using data from Solutran.
Amount
• We recommended the following to OPH:
– Correctly report number of high risk vendors
– Investigate high risk vendors as required
– Adopt analyses similar to those presented in
the report and other analyses as identified
• OPH agreed.
• Enforcement authority in several sources;
however, these sources are inconsistent
• FY12 enforcement actions:
– Disqualified one vendor
– Issued no penalties
– Did not track warning letters sent
• Counting WIC food inventory during routine
monitoring
• OPH sent 71 warning letters in the sample
we reviewed
• However, there were 90 total stock
violations in our sample
• Nine documented instances with no follow
up
• May/September 2013 observations
• Complaint regarding expired infant formula
• Warning letter -> 90 day disqualification or
penalty
• 6 of the 75 vendors in our sample had
repeat violations but only received a
warning letter
• Informal/nonspecific correction action plans
accepted
• Some of our recommendations to OPH
included:
–
–
–
–
Ensure sanctions are consistent across sources
Address unsanitary conditions
Develop template for corrective action plans
Develop sufficient tracking system to detect
patterns/improve effectiveness
• OPH agreed.
Medicaid Participant Fees Paid for
Deceased Individuals
David Leingang, Senior Data Analyst
• Data Analytics Unit
• Project
•
•
•
•
•
•
Who – Subunit of Performance Audit
What – Analyze Data
When – November 2012
Where – State Agencies
Why – Do more with less, Proactive
How – ACL and Excel
• Bayou Health and Louisiana Behavioral
Health Partnership
• Eligibility Determination
• Per member per month fees
• To determine if DHH paid Medicaid
participant fees for deceased individuals
in the Louisiana Behavioral Health
Partnership and Bayou Health programs
between February 1, 2012, and June 30,
2013.
• DHH – Medicaid
–All payments made between
2/1/2012 and 6/30/2013
• DHH – Vital Records
–Deceased data from 1991
• Compared the deceased individuals
from Vital Records to the Medicaid
claims paid to determine if any
payments were made for claims
occurring after a participant’s death
Payment to Providers
$1,200,000
$1,000,000
$800,000
Payments for Deceased Individuals
$984,165
$796,305
$600,000
$400,000
$200,000
$69,004
$Before February 1, Between February 1,
2012
2012 and March 31,
2013
Date of Death
After March 31,
2013
Number of Participants
900
800
700
600
500
400
300
200
100
0
Before February 1, 2012
Between February 1, 2012 and March 31,
2013
Date of Death
After March 31, 2013
Breakdown of Payments by Entity
$700,000
$600,000
$598,965
$500,000
$527,341
$400,000
$441,216
$300,000
$257,963
$200,000
$100,000
$15,625
$8,364
UnitedHealthcare of
Louisiana
Community Health
Solutions of America
$LaCare
Louisiana Healthcare Amerigroup Louisiana
Connections
Bayou Health
Magellan Health
Services
Louisiana Behavioral
Health Partnership
• DHH does not have a sufficient process
in place for identifying deceased
Medicaid participants in a timely
manner
• According to DHH management, the
department should be able to recover
the payments identified in this report.
Office of Juvenile Justice (OJJ):
Monitoring of Non-Secure
Residential Contract Providers
Cassadara Johnson, Senior Performance Auditor
Objective: To determine if OJJ has improved
its monitoring of non-secure residential
contract providers since our 2010
performance audit.
•
We followed up on 14 recommendations
related to monitoring of contract providers.
Status of OJJ Recommendations
As of June 30, 2013
Number of
Recommendations
Percentage
Implemented
8
58%
Partially Implemented
3
21%
Did Not Implement
3
21%
Total
14
100%
Recommendation Status
Source: Prepared by legislative auditor’s staff using information obtained from OJJ.
• OJJ had 12 non-secure residential
contracts totaling over $42.9 million.
• Contract terms are approximately two to
four years, with the oldest contract
beginning September 2011.
• La.R.S. 15:1084 requires OJJ to use a formula
to determine the rates for non-secure
residential contracts.
• Rates paid to contract providers ranged from
$112.65 per day to $258.62 per day for similar
services.
• Recommendation: Establish a formula to establish rates
for non-secure residential facilities as required by law.
• No financial monitoring conducted to ensure that
contract providers operate within their budgets.
• No verification that invoiced amounts were spent
on required services.
• Recommendation: Develop a risk based approach for
monitoring whether contract providers are operating
within their budgets.
• OJJ’s monitoring tools did not address all
contract requirements.
• Some examples include:
– Substance Abuse Treatments
– Psychiatric Consultation
– Behavior Management
– Education Assessments
• OJJ had no comprehensive system to track
monitoring results.
– OJJ did not record any results from its
monthly monitoring visits
As a result, OJJ could not track deficiencies of
contract providers over time and ensure that
sanctions were consistently imposed.
• OJJ did not ensure outcome data collected
from contract providers was complete.
– All annual outcome reports submitted by contract
providers for fiscal year 2013 were incomplete.
– Contract providers failed to report over 50% of the
required outcome measures.
However, OJJ did not review the outcome
measures that contract providers did submit.
Number of Outcome Measures Providers Failed to Report
Fiscal Year 2013
Providers
Boys Town of LA
AMI Kids
Community Receiving Home (Renaissance)
Rutherford House
Harmony Center- Harmony III Group Home
Harmony Center- Camelia Group Home
Johnny Robinson's Boys Home
Christian Acres Youth Center, Inc.
Educational & Treatment Council
Allen's Consultation & Training
Boys and Girls Villages
Ware Youth Center
Source: Prepared by legislative auditor's staff using provider annual reports.
Number of Measures Providers
Failed to Report
(out of 24 Required Measures)
23
23
22
21
19
19
19
17
7
15
15
6
%
96%
96%
92%
88%
79%
79%
79%
71%
70%
63%
63%
55%
• Recommendations:
– Ensure monitoring tools address all contract
requirements.
– Develop a system to track monitoring results and
use this data to manage the overall monitoring
process.
– Monitor the annual outcome reports submitted
from all providers and use this information to
evaluate the quality and effectiveness of services
provided.
• OJJ entered into a two-year, $12 million contract with
Magellan to manage 5 of the 12 non-secure
residential contracts.
• OJJ had not developed a monitoring plan as required
by this contract.
• Recommendations:
– Develop a plan to monitor Magellan’s oversight of the 5
contracts
– Require Magellan to report on its progress towards
meeting the specific goals of the contract
Questions?
For these reports (and others), visit www.lla.la.gov