Lack of Documentation Resulted in Improper Payments Totaling Over $20,000 in Medicaid Compliance Report of Urban Ounce of Prevention Behavioral Health Services, Incorporated
Columbus – Auditor of State Keith Faber’s Officer released the Medicaid compliance report for Urban Ounce of Prevention Behavioral Health Services, Incorporated, an Ohio Department of Mental Health and Addiction Services licensed treatment program located in Summit County. The report identified improper Medicaid payments in the amount of $20,976.91 between January 1, 2018 and June 30, 2018. With interest, $22,682.22 is due to the Ohio Department of Medicaid.
The scope for the engagement was limited to intensive outpatient program, case management, and individual counseling/psychotherapy services. Auditors found that 187 out of 461 services tested did not meet the applicable Medicaid requirements. The most frequent error, found in 163 instances, was the lack of documentation to support the payment. Due to these issues, auditors were unable to gain assurance over the validity of the service documentation.
Issues with documentation included:
- Overlapping services with the recipient being documented as present on both service documents;
- The documented time did not meet the minimum required and the Provider subsequently submitted a clone of the original document except for a different time and clinical supervisor;
- The Provider submitted two documents for the same recipient, date, time, service and practitioner but the narrative in the notes were different;
- Manually changed the date and case number on a note and the description of the recipient appears to describe a different person compared to a different service narrative for the same recipient on the same date; and
- Multiple instances in which the Provider re-submitted documentation with a hand written notation indicating a procedure code which contradicted the service check marked on the document.
Other errors were due to billing for time in excess of actual service delivery, non-compliance with treatment plans, and failing to provide the minimum time required for the type of service billed
The report contains recommendations for the Provider to improve its internal controls to ensure compliance with the Medicaid requirements. The Provider indicated it intends to implement a quality review process to ensure accurate claims for payment, documentation support units billed, as well as addressing the other issues identified in the report. The Provider stated its intent to add a position with responsibilities to oversee these quality assurance activities.