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Audit of the Greater Springfield Senior Services, Inc. Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Greater Springfield Senior Services, Inc.

Table of Contents

Overview

In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of certain activities of Greater Springfield Senior Services, Inc. (GSSSI) for the period July 1, 2016 through June 30, 2018.

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Below is a list of our audit objectives, indicating each question we intended our audit to answer, the conclusion we reached regarding each objective, and where each objective is discussed in the audit findings.

Objective

Conclusion

  1. Did GSSSI’s Protective Services Unit prepare, document, and maintain case record documentation in accordance with Section 5.18(2) of Title 651 of the Code of Massachusetts Regulations (CMR)?

No; see Finding 2

  1. Did GSSSI’s Protective Services Unit screen and investigate allegations, develop and execute service plans, and make reports to district attorneys’ (DAs’) offices in accordance with 651 CMR 5.09, 5.10, 5.13, 5.18(1)(a)(5), and 5.19?

No; see
Findings 1
, 3, and 4

  1. Were Protective Services Unit caseworkers and supervisors whom GSSSI hired qualified in accordance with 651 CMR 5.02?

No; see Finding 5

 

To achieve our audit objectives, we gained an understanding of the internal controls related to our audit objectives by reviewing applicable laws, regulations, and agency policies and procedures; conducting interviews; and performing walkthroughs of cases of abuse of elderly persons with GSSSI personnel.

We assessed the reliability of the data obtained from the Adult Protective Services (APS) system, which included interviewing knowledgeable personnel at the Executive Office of Elder Affairs (EOEA) and GSSSI about APS and testing the data for missing records or fields, duplicate records, invalid identifiers, and report dates outside our audit period. We tested APS’s controls, which included security management, access control, and segregation of duties, and verified that configuration management and contingency planning policies were in place during the audit period. Because of expungement practices, our review of cases of unsubstantiated allegations was limited to fiscal year 2018 cases. As a result of our data reliability analysis and information system control testing, we found that the data in APS were reliable for the purposes of our audit.

Case Record Documentation

We obtained GSSSI’s data related to investigations of abuse of elderly persons (taken from APS) from EOEA. We split the original population into investigations of substantiated and unsubstantiated allegations of abuse, with populations of 1,101 and 355, respectively.

We selected a statistical random sample of 60 investigations of substantiated allegations (with a 95% confidence level, a 5% tolerable error rate, and an expected error rate of zero) from a population of 1,101. We did not project the result to the entire population. We also selected a nonstatistical random sample of 40 investigations of unsubstantiated allegations from a population of 355. We tested both samples to determine whether GSSSI complied with the documentation requirements of 651 CMR 5.18(2). Because 651 CMR 5 was revised during our audit period, we used both versions for our testing, as necessary. We tested to determine whether each case record included the following:

  • documentation regarding the screening of the report; the identity of the allegedly abused elderly person; the cause, nature, and extent of the abuse; and the identity of the alleged abuser/s
  • a determination of the elderly person’s decisional and functional capacity or mental status and documentation of his/her refusal to participate in the investigation or refusal of the investigation, if applicable
  • documentation of activity conducted during the investigation, supporting facts to back up decisions made, actions taken, and projected timelines for proposed actions
  • documentation of names and relationships of collaterals contacted and the date, type, location, and purpose of contact made
  • descriptions of activities of others providing services or assistance to the elderly person, if applicable, as well as any supporting documentation obtained from outside sources
  • documentation of a service plan; the elderly person’s consent to, or refusal of, services; and timely supervisor approval of the service plan, if applicable (investigations of substantiated allegations only)
  • timely supervisor approval of the completed investigation, timely case record documentation, and an investigation summary addressing all allegations

Casework Compliance

We also tested the same randomly selected investigations from our case record documentation tests to determine whether GSSSI complied with the requirements regarding the screening and investigation of reports of abuse of elderly persons, the development and execution of service plans, and reporting to DAs’ offices, described in 651 CMR 5.09, 5.10, 5.13, 5.18(1)(a)(5), and 5.19. Because 651 CMR 5 was revised during the audit period, we used both versions for our testing, as necessary. We tested to determine the following:

  • whether each screening decision was made in the correct timeframe based on response time (24 hours for emergency and rapid response situations, five days for other non-emergency situations)
  • whether the investigation was initiated and initial contact was made with the elderly person in the correct timeframe
  • whether evidence existed that the elderly person was notified of the investigation; interviews were conducted with other members of the person’s household, if applicable; and the investigation was completed within 30 calendar days
  • whether the service plan was developed within five business days after the investigation ended, a supervisor in the Protective Services Unit was involved in the development of the service plan, and the service plan was developed in consultation with the elderly person (investigations of substantiated allegations only)
  • whether the service plan was reassessed during the first month of service and every three months thereafter, as well as whether a caseworker in the Protective Services Unit performed a home visit or an in-person interview with the elderly person once per month during the service plan and maintained contact with the person in accordance with the service plan (investigations of substantiated allegations only)
  • whether evidence existed that a DA’s office was notified immediately of deaths of elderly persons due to abuse and notified within 48 hours of reportable conditions other than death, and whether evidence existed that GSSSI released the full report to the DA’s office and tried to schedule a meeting with the DA after the report was filed, if applicable (investigations of substantiated allegations only)

Protective Services Unit Hiring

We obtained a list of all Protective Services Unit personnel hired by GSSSI during the audit period from the GSSSI Protective Services Unit director, a second list of those personnel from GSSSI’s Human Resources manager, and a list of all active GSSSI Protective Services Unit employees from APS. We compared the lists for completeness. Additionally, we randomly selected 10 employees from the list obtained from APS, as well as their personnel files, and documented their dates of hire. We determined whether any of these employees were hired into the Protective Services Unit during our audit period. If they were, we verified that they were appropriately included on the lists of new hires from the audit period. We then verified that the dates of hire were accurate on the lists provided. We determined that the list of Protective Services Unit new hires provided by GSSSI’s Human Resources manager was complete and accurate.

To determine whether Protective Services Unit caseworkers and supervisors hired by GSSSI were qualified in accordance with 651 CMR 5.02, we tested the entire population of 15 Protective Services Unit employees hired during the audit period by reviewing the 15 employee personnel files. Because 651 CMR 5 was revised during the audit period, we used both versions for testing, as necessary.

Except for our testing of substantiated cases, we used a nonstatistical sampling approach for our testing and therefore cannot project our results to the entire population.

Date published: September 4, 2019

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