| Medical Assistance Program |
Eligibility. Eligibility redeterminations for 7 beneficiaries out of 69
reviewed were not performed within the required interval of once every 12
months. Health Care Services has delegated the performance of eligibility
redeterminations to county welfare agencies in subawards. Excessive case
management workload at the county welfare agency level resulted in
insufficient resources to ensure compliance with the redetermination
requirements. |
2014-15 |
| Remains Uncorrected. Health Care Services began systematic data
collection and review of County welfare agencies’ performance of timely
eligibility redeterminations on a monthly basis to ensure that
redeterminations occur within the required timeline. Ongoing, this data is
used to select counties for audits that focus on timeliness of
redeterminations. Health Care Services began performing random audits
of counties focusing on the renewal process in March 2017. Upon
completion of each audit, counties that do not meet the redetermination
timeliness processing standard must submit a corrective action plan to
Health Care Services. Health Care Services will review all corrective
action plans and measure the effectiveness of each plan by monitoring
redeterminations data that demonstrates a gradual increase in the number
of redeterminations performed timely.
The Medi-Cal Eligibility Division Information Letter 17-12 notifying
counties of Macias Gini & O’Connell LLP's findings was released on
August 11, 2017. |
35 |
| Block Grants for Prevention and Treatment of Substance Abuse |
Cash Management. The cash management process of the Substance Use
Disorder Program, Policy and Fiscal Division (Division) of Health Care
Services does not provide for appropriate monitoring to ensure that
subrecipients are minimizing the time elapsing between the receipt and
disbursement of federal funds. The Division was unaware of the
requirement to monitor the cash needs of their subrecipients.
|
2015-16 |
| Partially Corrected. Health Care Services was unable to implement the
previously proposed quarterly line-item invoicing process for Substance
Abuse Prevention and Treatment Block Grant (SABG) Substance Use
Disorder (SUD) services beginning with the federal fiscal year 2017
SABG award.
The currently established SABG allocation and cost reporting processes
have been in place since 1999 and would require significant collaborative
efforts by Health Care Services and California’s 58 counties to amend
current processes and procedures for implementation. Additionally, prior
to implementation of a quarterly invoicing process, the California Health
and Safety Code - HSC §11758.10 would need to be amended as it
currently requires advance SABG payments to counties.
After further consultation with the federal cognizant, the Substance Abuse
and Mental Health Services Administration (SAMHSA), it has been
determined that Health Care Services will strengthen the currently
established Quarterly Federal Financial Management Report (QFFMR)
process to minimize the time elapsing between the receipt and
disbursement of federal funds to subrecipients (counties). Health Care
Services will require county subrecipients to provide actual SABG
expenditures with supporting detail from accounting ledgers and actual
SABG cash on hand prior to any additional disbursement of federal funds.
Health Care Services will implement the enhanced QFFMR process
following consultation with Health Care Services Internal Audits,
Accounting, the California Behavioral Health Director’s Association and
County Alcohol and Drug (AOD) Administrators.
Health Care Services and SAMHSA will confer and develop a corrective
action plan in state fiscal year 2018-19.
|
33 |
| Medical Assistance Program |
Subrecipient Monitoring. Health Care Services could not provide evidence
that the required subrecipient versus contractor determinations were
performed for the Children's Health Insurance Program and Medical
Assistance Program. Health Care Services does not have policies and
procedures in place to perform and document the required determinations. |
2015-16 |
| Remains Uncorrected. Health Care Services is in periodic meetings with
counsel and is reviewing and working towards finalizing the policies and
procedures that will be used to perform and document the required
subrecipient and contractor determinations. Health Care Services is on
track to meet the originally proposed implementation date.
|
58 |
| Medical Assistance Program |
Subrecipient Monitoring. Health Care Services did not evaluate each
subrecipient's risk of noncompliance with federal statutes, regulations, and
the terms and conditions of the subaward of the Children's Health
Insurance Program and Medical Assistance Program. Health Care
Services did not develop policies and procedures for evaluating each
subrecipient's risk of noncompliance in a timely manner.
|
2015-16 |
| Remains Uncorrected. Health Care Services is working on reviewing all
federal requirements that will be used to develop policies and procedures
to evaluate each subrecipient’s risk of noncompliance. Health Care
Services plans to develop the policies and procedures by March 31, 2018. |
64 |
| Medical Assistance Program |
Subrecipient Monitoring. The Mental Health Division of Health Care
Services did not communicate the universal identifier and system for
award management requirements to applicants of Short-Doyle funding in
accordance with 2 CFR 25.200. Additionally, the Mental Health Division
did not collect the unique entity identifier prior to awarding funds in
accordance with 2 CFR 25.205. Further, the Mental Health Division did
not communicate to its subrecipients the required federal award data upon
making a subaward including identifying the award as a subaward in
accordance with 2 CFR 200.331. The Mental Health Division does not
have a process in place to ensure the required information is
communicated to subrecipients, nor was the Mental Health Division aware
of these pre-award and post-award requirements for pass-through entities. |
2015-16 |
| Remains Uncorrected. Health Care Services embarked on the following
approach to satisfy Data Universal Numbering System (DUNS)
requirement;
1. Adding it to the Mental Health Block Grant policy letters –
Health Care Services implemented this policy on May 22,
2014.
2. Health Care Services plans to include the information in the
Mental Health Plan (MHP) Contract (not the cost report as
indicated in the corrective action plan) indicating that the
payments are considered a subaward and identifying the
regulations with which they need to comply. Health Care
Services is currently working to amend the MHP contract to
implement changes to Federal Medi-Cal managed care
regulations; therefore, the sub award language has not yet been
implemented in the MHP contract. Once the MHP Contract
amendment is complete, Health Care Services will include the
DUNS reporting requirement in the annual cost report policy
letters and add it to the annual cost report template as a required
field in the county information page. |
60 |
| Medical Assistance Program |
Subrecipient Monitoring. The Mental Health Division of Health Care
Services did not take the required action of notifying subrecipients in
writing within 30 days of the noncompliance regarding timeliness of
submitting reports. Even when cost reports are submitted timely, Mental
Health Division will often not review them for up to two years after
submission. The Mental Health Division did not perform the required
follow-up action for late cost reports because they are not tracking cost
report submission. |
2015-16 |
| Partially Corrected. Health Care Services has developed and released a
Cost Report Submission Requirements Information Notice. The
information notice contains a form that Mental Health Plans (MHPs) may
use to request an extension to file a cost report. Health Care Services has
begun sending out letters to MHPs whose cost reports are late. |
66 |
| SCHIP (State Children's Insurance Program) |
Subrecipient Monitoring. Health Care Services could not provide evidence
that the required subrecipient versus contractor determinations were
performed for the Children's Health Insurance Program and Medical
Assistance Program. Health Care Services does not have policies and
procedures in place to perform and document the required determinations. |
2015-16 |
| Remains Uncorrected. Health Care Services is in periodic meetings with
counsel and is reviewing and working towards finalizing the policies and
procedures that will be used to perform and document the required
subrecipient and contractor determinations. Health Care Services is on
track to meet the originally proposed implementation date.
|
58 |
| SCHIP (State Children's Insurance Program) |
Subrecipient Monitoring. Health Care Services did not evaluate each
subrecipient's risk of noncompliance with federal statutes, regulations, and
the terms and conditions of the subaward of the Children's Health
Insurance Program and Medical Assistance Program. Health Care
Services did not develop policies and procedures for evaluating each
subrecipient's risk of noncompliance in a timely manner.
|
2015-16 |
| Remains Uncorrected. Health Care Services is working on reviewing all
federal requirements that will be used to develop policies and procedures
to evaluate each subrecipient’s risk of noncompliance. Health Care
Services plans to develop the policies and procedures by March 31, 2018. |
64 |
| SCHIP (State Children's Insurance Program) |
Subrecipient Monitoring. The Mental Health Division of Health Care
Services did not communicate the universal identifier and system for
award management requirements to applicants of Short-Doyle funding in
accordance with 2 CFR 25.200. Additionally, the Mental Health Division
did not collect the unique entity identifier prior to awarding funds in
accordance with 2 CFR 25.205. Further, the Mental Health Division did
not communicate to its subrecipients the required federal award data upon
making a subaward including identifying the award as a subaward in
accordance with 2 CFR 200.331. The Mental Health Division does not
have a process in place to ensure the required information is
communicated to subrecipients, nor was the Mental Health Division aware
of these pre-award and post-award requirements for pass-through entities. |
2015-16 |
| Remains Uncorrected. Health Care Services embarked on the following
approach to satisfy Data Universal Numbering System (DUNS)
requirement;
1. Adding it to the Mental Health Block Grant policy letters –
Health Care Services implemented this policy on May 22,
2014.
2. Health Care Services plans to include the information in the
Mental Health Plan (MHP) Contract (not the cost report as
indicated in the corrective action plan) indicating that the
payments are considered a subaward and identifying the
regulations with which they need to comply. Health Care
Services is currently working to amend the MHP contract to
implement changes to Federal Medi-Cal managed care
regulations; therefore, the sub award language has not yet been
implemented in the MHP contract. Once the MHP Contract
amendment is complete, Health Care Services will include the
DUNS reporting requirement in the annual cost report policy
letters and add it to the annual cost report template as a required
field in the county information page. |
60 |
| SCHIP (State Children's Insurance Program) |
Subrecipient Monitoring. The Mental Health Division of Health Care
Services did not take the required action of notifying subrecipients in
writing within 30 days of the noncompliance regarding timeliness of
submitting reports. Even when cost reports are submitted timely, Mental
Health Division will often not review them for up to two years after
submission. The Mental Health Division did not perform the required
follow-up action for late cost reports because they are not tracking cost
report submission. |
2015-16 |
| Partially Corrected. Health Care Services has developed and released a
Cost Report Submission Requirements Information Notice. The
information notice contains a form that Mental Health Plans (MHPs) may
use to request an extension to file a cost report. Health Care Services has
begun sending out letters to MHPs whose cost reports are late. |
66 |
