Overview
In 32 of 40 instances, CHD did not properly administer its DDS person-served representative payee function. Each of these 32 instances had one or more of the following issues:
- Two persons served did not have an Individual Service Plan (ISP) on file, and three ISPs that were on file had not been reviewed and updated within the required 12 months.
- Three persons served did not have a Money Management Plan (MMP), and eight had MMP consent forms that were not signed.
- Three persons served had PFMSes that did not log the receipt of funds for personal use, one had a PFMS with a transaction that did not have an attached receipt for an expenditure, and one had a PFMS with a transaction that had an incorrect receipt attached.
- Seven RPMFPs did not have supporting documentation for periodic and/or manual payments, seven persons served did not receive personal spending funds in the amounts stated in their RPMFPs (two of these seven people also did not receive their funds in the frequency stated in their RPMFPs), and one person served was overcharged for care.
- In 22 instances, an “Individual Funds Management Review” was not signed by the vice president (VP) of Disability and Elder Services.
During our assessment of internal controls related to the administration of CHD’s representative payee function for DDS persons served, we determined that four of seven PFMSes were missing one or both required sets of CHD staff initials and that one of those four sheets was also missing the required signature from the program manager.
Lapses in oversight of personal funds of persons served at the corporate and group home levels could increase the opportunity for the mismanagement, unaccounted-for variances, losses, or thefts of client funds.
With no documentation for some of these transactions, there is no evidence that expenses have been paid correctly or that people served have received their personal funds.
Authoritative Guidance
CHD’s “Meadows Homes Policies & Procedures for Individual Funds Management” states,
Each year, the ISP team will determine the degree and type of assistance needed. This assistance will be documented in both the annual Individual Service Plan (ISP) and in the annual Money Management Plan (MMP). . . .
10. The Residential Supervisor responsible for each site is the responsible person for the day-to-day safeguarding of individual financial accounts and or their monies kept at the residential site. This includes maintaining accurate and current financial transaction sheets with accompanying receipts kept in an organized manner. A Program Manager will verify that these safe guards remain in place during each visit to the residential location and subsequently each month when Residential Supervisors submit this documentation for review. . . .
16. . . . All expenses must be entered on a personal transaction sheet [PFMS], including date, detailed description of purchase, and amount of purchase. Calculations should be done with a calculator and rechecked for accuracy. Person assisting with the purchase must initial the entry. . . .
The Program Manager will review [and sign] monthly transaction sheets each month to ensure balance accuracies and content of purchases.
According to CHD’s unwritten policy, in addition to being initialed by the person assisting with the purchase, the PFMS must also be initialed by the reviewer who audits the transaction for mathematical accuracy and verifies the cash balance.
The regulation 115 CMR 3.08(10) states,
All funds received from the individual or on his or her behalf and all funds disbursed shall be accounted for and a permanent record made showing the amount of funds received, date received and source of funds. All funds disbursed shall be accounted for and a permanent record made of the person receiving funds, purpose of disbursement, amount of the disbursement, and date of disbursement.
Section III(e) of CHD’s “Representative Payee Account Policy” states,
All disbursements from the [representative] payee account must be supported by adequate documentation.
- Checks made out to the program participant will be supported by having him or her sign a check receipt form.
- Check will not be written to a staff member. Exceptions must be approved by VP of [Disability and Elder Services] and VP of Fiscal [Services] or designate of each.
- Recurring payments such as rent or charges for care should be supported by a charge for care calculation, or a copy of a lease or letter detailing the payment.
- Periodic payments should be initiated by an invoice or bill.
- All other payments should have receipts supporting the check amount. The check request form will note whether store receipts are required.
Section III(c) of CHD’s “Corporate Accounting Policy for DDS Funds Management” states,
At conclusion of each [Individual Funds Management Review], summarize findings in a report to [the chief financial officer], VP of [Disability and Elder Services], and VP of Fiscal Services [for review and signature].
Reasons for Issue
CHD lacked monitoring controls to ensure that its staff members adhered to its policies and procedures for the DDS representative payee function. The lack of monitoring controls resulted in unsigned forms; outdated forms on file; required forms not on file; missing supporting documentation for recurring, periodic, and manual payments; and incorrect disbursement of funds for personal use and charges for care.
Recommendation
CHD should document and implement monitoring controls to ensure that all required forms used in the representative payee function for its DDS persons served are up to date and have the required initials and signatures, as well as to ensure that personal funds and charges for care are correctly disbursed and supported by the required documentation.
Auditee’s Response
As with other audit findings, it appears that this finding relates to the organization’s failure to follow its own policy regarding individual funds management (including obtaining signatures on documentation) as contrasted with failure to follow DDS regulations or guidelines or any misuse of funds. The policy was prepared prior to the COVID-19 pandemic and does not take into consideration the demands on direct care and supervisory staff in this challenging environment; review of the policy and procedure at this time is warranted. CHD will continue to have a robust system of checks and balances to ensure that the funds of individuals it serves as a representative payee are managed properly and that individuals served have money management plans that conform to DDS requirements and are signed by the individual or guardian.
Auditor’s Reply
The Office of the State Auditor does not agree that this finding only cites violations of CHD policies and procedures. Issues associated with noncompliance with CHD policies and procedures can also result in noncompliance with DDS regulations. A contractor’s policies and procedures are implemented, in part, to ensure compliance with the CMR.
For example, 115 CMR 3.08(5)(a) states,
Unless a guardian or conservator has been appointed, the individual’s ability to manage and spend his or her funds shall be evaluated, as soon as possible after admission (but no later than 30 days after admission), and at least every 12 months thereafter or upon the individual’s request.
CHD has implemented a policy of completing an ISP to comply with this DDS requirement. If an ISP is not on file or is out of date, there is no evidence that CHD has complied with the regulation.
Additionally, this finding cites a DDS regulation with which CHD did not comply: 115 CMR 3.08(10), which requires CHD to create a permanent record and includes documentation requirements for funds received and disbursed for a person served.
Although CHD has policies and procedures intended to ensure that the funds of people for whom it serves as a representative payee are managed properly, and CHD has MMPs for persons served that conform to DDS requirements, we strongly reiterate our recommendation that CHD document and implement monitoring controls to ensure that these policies and procedures operate as intended.
| Date published: | December 23, 2021 |
|---|