Overview
In 52 of 60 instances, CHD did not properly administer the person-served representative payee process. Each of these 52 instances had one or more of the following issues:
- One person served did not have an Adult Comprehensive Assessment (ACA) on file, and three ACAs that were on file had not been reviewed or updated within the required 12 months.
- Fifteen Consent of Management of Client Funds Forms for persons served were not signed by the client (or the guardian, when the client was unable to sign) and the CHD person obtaining consent.
- Twenty-three persons served did not have a Representative Payee Monthly Financial Plan (RPMFP) that matched the payments made, 21 did not have supporting documentation for periodic and/or manual payments, 17 did not receive personal spending funds in the amounts stated in their RPMFPs (16 of these 17 individuals also did not receive their funds in the frequency stated in their RPMFPs), and 39 had missing supporting documentation for charges for services.
- Funds provided to 26 persons served for personal spending were not logged on a Personal Funds Management Sheet (PFMS) or signed for on a Client Spending Received Receipt. PFMSes for 6 persons served had one or more expenditures without attached receipts.
We also identified 4 of 60 instances where checks were made out to a CHD employee from a person-served account; these totaled $845. Our results are limited to the sampled items tested.
During our assessment of internal controls related to the administration of CHD’s representative payee function for DMH persons served, we inspected the PFMSes for 18 persons served and found the following deficiencies: 6 persons served had no PFMS on file, 1 PFMS was missing the initials of two staff members, and 1 PFMS was missing both the signature of the person served and the initials of two staff members.
These issues could increase lapses in oversight of personal funds for persons served at the corporate and group home levels and could increase the opportunity for mismanagement, unaccounted-for variances, losses, or thefts of funds.
In addition, with no documentation for some of these transactions, there is no evidence that expenses have been paid correctly or that the people served have received their personal funds.
Authoritative Guidance
In relation to conducting ACAs, CHD’s “Person Served Funds Management Policy” states,
All persons . . . will be assessed for money/financial management skills. The assessment will be conducted by the [Adult Community Clinical Services, or ACCS] Licensed Practitioner of the Healing Arts (LPHA) [a CHD clinical staff member] through the Adult Comprehensive Assessment (ACA). The results will be documented in the person’s Electronic Health Record (EHR) and shared with the person receiving ACCS services and related stakeholders.
Additionally, 104 CMR 30.01(4)(a) states that this evaluation must be done at least every 12 months:
Unless a legally authorized representative has been appointed with authority to manage all of the . . . funds [of a person served], or the [person served] is a minor, the clinical staff of [CHD] shall evaluate the [person served] . . . at least every 12 months.
In relation to the unsigned Consent of Management of Client Funds Forms, CHD’s “Representative Payee Account Policy” states,
This policy is designed to enhance existing program policies and procedures around the treatment of persons served in the area of [funds] management. It does not replace individual program responsibility for . . . obtaining the consent of [the] persons served. . . .
If changes are required [for an RPMFP], program supervisors need to complete a Request to Amend the [RPMFP].
CHD’s form for documenting this consent is the Consent of Management of Client Funds Form.
In relation to missing RPMFPs, CHD’s “Person Served Funds Management Policy” states,
When CHD has been appointed by [the Social Security Administration, or SSA] as Representative Payee. . . . [Program supervisors are] responsible for notifying the CHD Fiscal Department and submitting the following documents: SSA approval letter [and RPMFP].
In relation to other missing documentation, the policy states,
3. Records: A complete financial record will be maintained for every person receiving ACCS services whereby CHD is appointed Representative Payee. . . . Additionally, an excel spreadsheet of account transactions will be maintained by CHD representative payee bookkeepers. . . . Staff will maintain a cash-on-hand ledger for all persons for whom the program maintains this function. . . .
5. Cash-on-Hand: . . . the distribution of funds must be documented by receipt [for those receiving financial assistance with personal use funds]. . . .
7. Distribution of Client Funds: . . . Under no circumstance will a check be written from a CHD individual’s representative payee bank account and be made payable to a CHD staff member.
CHD’s “Representative Payee Account Policy” requires a signature or initial from the person served to acknowledge the receipt of the appropriate amount every time s/he receives personal spending funds. Additionally, for persons served who require fund management assistance, CHD’s unwritten policy requires the PFMS to include the initials of two staff members in a designated location for each transaction listed. CHD’s unwritten policy also requires the program manager to review the PFMS at the end of the month and sign the top of the form in the designated location to indicate that the end-of-month review has been completed.
In addition, Section III(e) of the “Representative Payee Account Policy” states,
All disbursements from the [representative] payee account must be supported by adequate documentation.
- Checks made out to the person served [for personal use] will be supported by having him or her sign a [Client Spending Received Receipt or PFMS].
- Recurring payments such as rent or charges for care should be supported by 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.
Reasons for Issue
CHD lacked monitoring controls to ensure that its staff members adhered to its policies and procedures for administering the DMH 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. Similarly, CHD lacked monitoring controls to prevent check disbursements to staff members from the accounts of persons served.
Recommendations
- CHD should document and implement monitoring controls to ensure that check disbursements are not made to staff members from accounts for persons served.
- CHD should document and implement monitoring controls to ensure that all required forms used in the representative payee function for its DMH persons served are on file and up to date; that they have the required initials and signatures and supporting documentation for recurring, periodic, and manual payments; and that funds for personal use are correctly disbursed.
Auditee’s Response
In that the reference to administering representative payee functions is in regards to matters that include required client or staff signatures, required dates on records and storage of records, and not reflective of any misuse of funds, CHD has improved some of these administrative processes already by requiring that funds management sheets for individuals served will be scanned into the electronic health record in addition to being delivered to the corporate representative payee. This new process will need to be incorporated into the new electronic health record system that is now being implemented by CHD. Additionally, the representative payee staff has improved its filing systems to ensure that all records pertaining to the representative payee process administered by its staff are properly filed and retrievable and have started logging receipt of personal funds management sheets to track receipt of the documentation. CHD’s Organizational Excellence Division will continue to analyze how the representative payee process for these clients can be further enhanced to ensure that the documentation is audited and corrective action is taken when staff do not adhere to CHD representative payee policy.
Auditor’s Reply
Based on its response, CHD is taking measures to address our concerns about documenting and implementing monitoring controls to ensure that all required forms are appropriately completed and signed, all payments are supported, and funds for personal use are correctly disbursed. CHD should also document and implement monitoring controls to ensure that check disbursements are not made to staff members from accounts for persons served.
| Date published: | December 23, 2021 |
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