wayne county juvenile assessment center audit 2004

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Juvenile Assessment Center andWayne County Department of Children and Family Services

Contract Compliance Audit Report

December 1999 – December 2003

SUMMARY AND ASSESSMENT OF

CORRECTIVE ACTION PLAN

Office of the Wayne County Legislative Auditor General DAP No. 2004-57-003(C)

No.

Auditor General

Recommendation

Management’sComments on

Findings and

Recommendation

Management’s Action

Taken or Planned

Management hasor Intends to

Implement the

Recommendation

Yes/No

Responsible

Person/Area

Im

Im

1. The JAC charge theapplicable rate authorized for

a service only in accordancewith their contract approvedby the County Commission.

Agree withrecommendation

The Juvenile Agency Information Systemhas been revised to include rates and

services in accordance with the approvedcontract. The Juvenile Assessment Center(JAC) has also established billingprocedures that occur prior to the

submission of the monthly bill comparingbilled services to eligible rates, servicenames, and any previously billed services.The JAC also compares the monthly

invoices to a roll up report provided by theDCFS to ensure there are no duplicationsfrom prior invoices.

Yes M&BFinance

Director –DCFS andExecutiveDirector,

JAC

2. The Department of Childrenand Family Servicesdetermine the amount of

over-payments paid to the

JAC that should berecovered, then establish arepayment plan to recoup the

over-paid amounts.

This recommendation is included and fully addressed in the OAG’s Corrective Action Plan report for the D

Services Division, Controls Over Service Provider Contracts operational audit, dated February 9, 2006, DAP









No.

Auditor General

Recommendation

Management’s

Comments on

Findings and

Recommendation


Taken or Planned

Management has

or Intends to

Implement the

RecommendationYes/No

Responsible

Person/Area

Im

Im

7. The JAC establish andimplement a policy to ensure

all new hires receivebackground checksconducted by the Michigan

State Police prior to their

start date.

Agrees withrecommendation

In a few instances, the JAC had backgroundchecks performed by the city of Detroit.

The JAC now has a policy in place toensure that background checks areconducted by the Michigan State Police. In

addition, since 2002 all JAC employees

have a record of background checks in theirpersonnel files.

Yes HumanResource

Director,JAC

8. The JAC determine the

deficiencies in the controls inthe billing preparationprocess, modify wherenecessary, and then

implement the enhancedcontrol procedures.

Agrees with

recommendation

Both the JAC and the DCFS have instituted

manual and automated controls andsafeguards to improve the JAC billingprocess. Additional procedures establishedinclude the recording of billable services in

both the JAIS system and the JACaccounting database. Prior to submittingthe invoices, each billable service is cross-referenced to prior billings to ensure the

accuracy of the client number and servicedate. In addition, system controls havebeen implemented that prevents invoicingfor the same item more than once.

Yes Finance

Director,JAC









No.

Auditor General

Recommendation

Management’s

Comments on

Findings and

Recommendation


Taken or Planned

Management has

or Intends to

Implement the

RecommendationYes/No

Responsible

Person/Area

Im

Im

9. The Department of Childrenand Family Services

implement the plannedpreventive and detectivecontrols for the JAIS system.

Agrees withrecommendation

The department has implemented manypreventive and detective controls within the

JAIS system. Specifically, JAC serviceunits have been modified to eliminateinconsistency in services, once the

department authorizes a service; the service

is locked within the system. This willprevent double billing.

Yes Director,DCFS and

M&BFinance

Director -

DCFS.



APPENDIX

Corrective Action PlanJuvenile Assessment Center

andWayne County Department of Children and Family Services

Contract Compliance AuditDAP No. 2003-57-003(C)



Please find below the joint response of the Wayne County Department of Children and Family Services

(WCCAFS) and the Juvenile Assessment Center (JAC) to the restatement prepared by the Office of the

Auditor General of the recommendations contained in the Wayne County Department of Children and

Family Services Juvenile Services Division Juvenile Assessment Center Contract Compliance Audit dated

November 22, 2004.

Recommendation #1

To ensure the Juvenile Assessment Center charges the correct rate for services billed, we

recommend the JAC: Charge the applicable rate authorized for a service only in accordancewith their contract approved by the County Commission.

The WCCAFS JAIS data system has been revised by WCCAFS for the purpose of matching exactly the servicenames in the Wayne County JAIS database used to invoice for the contracted service names and rates in theCounty Commission approved contract. This reduces the potential for error or miscommunication regarding a

specific service in the JAC billing procedure.

Unlike previous contracts, the current Wayne County JAC Contract has effective begin and end dates defined inthe contract thus better ensuring a match of eligible contract dates, the contract names for services and thecontract amount eligible for each service reimbursement.

The JAC has established written financial billing review steps for an in-depth internal billing review that occursprior to submission of each monthly JAC bill that compares all billed services with eligible rates, service namesand with any previously billed JAC invoices.

WCCAFS now maintains a monthly and fiscal year to date roll up report. A copy of the roll up report isprovided to the JAC. The WCCAFS roll up report provides documentation to the JAC that WCCAFS has

approved the bills submitted by the JAC as eligible for payment. As a final step in quality assurance, the JACmatches the new JAC invoice to the WCCAFS roll up report to be certain there are no duplications.

Recommendation #2

We recommend the Department of Children and Family Services:

Determine the amount of over-payments paid to the JAC that should be recovered, then

establish a repayment plan to recoup the over-paid amounts.

The Juvenile Assessment Center (JAC) received payments of $529,214 in excess of what the contract allowed

for on-site screens/alcohol and other drug (AOD) pick ups through February 2004. The Department and theJAC acknowledged the majority of the overpayment and in July 2004 the JAC reimbursed the county $358,854.

At the time of the Audit, the Department acknowledged that the Contract Managers misinterpreted thecontract’s language in this area. We also acknowledged that the payments were not tied to a specific child in theJuvenile Agency Information System (JAIS) making this area prone to error.

In our professional opinion, the County cannot hold the JAC responsible for the remaining $170,360. This errorcan be traced to the newness of the system and the initial flaws that have now been corrected.



It should be noted that the Department has continued to refine the services provided by the JAC (and all otherentities involved in the county’s juvenile justice program). In FY-2005/06 these refinements will result in asavings of over $900,000.

The County issued an RFP (April 2005) seeking an independent review of the operations of the JAC. PlanteMoran, in partnership with Alan C. Young and Associates, were the sole bidders and will begin their reviewmomentarily. Findings from this review will guide the development of the Scope of Services for the assessmentRFP currently being developed.

Recommendation #3

The Department of Children and Family Services: Revise the vendor invoice and review process

to include adequate review procedure to ensure that proper rates are billed and approved.

The finance area of the department has been restructured. In September 2004 the Department of Managementand Budget installed a member of their staff as director of the CAFS finance division. In December 2004 apermanent director (also a member of M & B) was assigned to the department. All current CAFS finance staff report to this individual, as does the department’s contract staff. In FY 2006/07 this staff will be re-aligned and

become M & B employees.

Monthly invoices are verified by a Finance Department Analyst and subsequently reviewed and approved bythe department’s Director of Finance. Currently no transactions are processed for payment without the Directorof Finance’s signed approval.

This issue is also addressed in the new contracts. In addition major improvements have been made in theJuvenile Agency Information System (JAIS) that facilitate the department’s ability to monitor and analyzerequired performance, for example, the number of service codes have been dramatically reduced and can nowbe easily matched with the invoices.

In addition, the department’s executive and finance staff host monthly meetings with CMS and JAC executives

to ensure that financial and programmatic issues are addressed expeditiously.

Recommendation #4

To ensure the JAC complies with other major contract provisions, we recommend the JAC:

Obtain documentation for each service rendered and billed, and maintain it in the youth’s casefile.

It is not practical or in some case even possible to maintain all of the information relating to a youth intreatment in their individual case files. The JAIS system is the Wayne County data system. It is this

system that WCCAFS requires the JAC to use.

The JAIS database and not the youth’s file is the location of the record of both the contracted serviceprovision documentation and verification of the JAC’s invoice.

The JAC has established a process to review all billable JAC services in conjunction with the JAIS data baserecord of the services provided.

Services that require narrative or clinical documentation are maintained in the youth’s case file.



JAC services that have or are numerical summaries or specialized codes are maintained only in the JAISdatabase. In addition other items that reside only in the JAIS database include AOD screen lab results,psychological evaluation scores and Care Management Track entries and reviews. AOD lab results arenumerous and are recorded and maintained only in the JAIS database.

The JAC data entry staff matches cup numbers supplied by the Lab, used by the JAC for AOD screens, and thenthis information is entered into the JAIS database. This information is then printed in a multiple list format anddue to the multiple clients on each printed page are not in each youth’s case file.

The JAIS AOD data can be matched to lab cup numbers in both the Lab’s computer and in the JAIS database toconfirm the accuracy of the information and to prove that the tests were completed.

The Care Management Track for each youth contains each event of utilization in the youth’s treatment path.The number of these events is huge and consequently they are only recorded and maintained in the JAISdatabase. Each CMS is paid based upon these Care Management Track records. The JAIS system has an auditfunction that maintains a record of each individual who makes an entry together with the contents of that entryfor each youth in treatment. This information is retained in the JAIS database and is available at any time toverify the accuracy of the Care Management Track record for each youth in care.

Recommendation #5

The JAC: Annually forward insurance binders documenting that required coverages are

obtained and in-force to the department and the Division of Risk Management.

The JAC has provided all documentation of all insurance coverages required by the Wayne County contract toWCCAFS by delivery of that information to the Division of Risk Management. The JAC Finance Director hasbeen given the task of providing to the Division of Risk Management proof of the required coverages upon eachpolicy renewal.

Under the reengineered county contracting process Risk Management establishes insurance requirements prior

to the release of any RFP or contract. Further, Risk Management is responsible for ensuring that appropriateinsurance coverage and certificates are maintained.

Recommendation #6 and #7

The JAC: Determine which present employees have not had a background check performed bythe Michigan State Police and ensure they are conducted and if necessary take appropriate

action against employees if background checks warrant.

The JAC: Establish and implement a policy to ensure all new hires receive background checks

conducted by the Michigan State Police prior to their state date.

All current employees have background checks and as noted in the JAC response to OAG in November of 2004, it was confirmed by the JAC that since 2002 all JAC employees have a record of background checks intheir personnel file.

Recommendation #8



To strengthen and enhance controls over the billing process, we recommend the JAC: Determine

the deficiencies in the controls in the billing preparation process, modify where necessary, thenimplement the enhanced control procedures.

Multiple tiers of manual and automated controls and safeguards have been designed and implemented to correctto improve the JAC invoice process, as outlined below.

Two primary deficiencies in the control of the JAC billing process were identified by the JAC. The first wasthat the use of the Wayne County JAIS database, which is required by WCCAFS, contained flaws that wereunknown to both the JAC and WCCAFS. The discovery of these flaws in the JAIS database that included errorsin client names resulting in duplicate billing led the JAC to create a Quality Assurance review process withwritten billing procedures that must now be complied with prior to submission of the JAC invoice each month.Billable JAC services are recorded in JAIS. When the service is completed it is also recorded in the JACaccounting database. Thus, the service is recorded in separate and distinct databases. Prior to submission of theJAC Invoice to WCCAFS, each JAC service unit is cross referenced with previous submissions in the JACAccounting data base and with the JAIS service entry documentation to validate and assure accuracy of JACservice documentation, the correct client registration match, service date match and possibility of duplicationand/or policy discrepancy before the JAC Invoice is completed and submitted.

Further, as noted in Response #1, WCCAFS has revised the JAIS system to also correct this deficiency.

The second deficiency of the JAC was not obtaining a copy of the monthly invoice review as performed byWCCAFS. The institution of the WCCAFS monthly roll up report provides the verification to the JAC of WCCAFS review of submitted invoices and the rejection or acceptance of each service unit. Further, indevelopment with the plan being no check box, but the system will not allow same services for same youth tobe repeated and prevents invoicing for the same item more than one time. This check box system also alertsJAC staff that an item has already been invoiced and approved by WCCAFS. All JAC invoice submissions arealso cross-referenced by the JAC accounting staff against prior invoices and the JAC accounting database tosearch for and eliminate duplicates.

Recommendation #9

We recommend the Department of Children and Family Services: Implement the planned

preventative and detective controls for the JAIS system.

Improvements in the GVT/JAIS

Issue: Overpayments and Duplicate Payments

Answer: Refine/Re-program existing “JAC Services Report” on JAIS

Report needs to be organized by service rather than by juvenile’s name in alphabetical order. This is

100% complete.

JAC Service Units include:



01 – Intake and Commitment and Evaluation;02 – Psychological Test and Comprehensive Report;03 – Academic Outcome Testing;06 – Employment Outcome Verification08 – Abridged Intake09 – Abridged Psychological11 – Non-scheduled Payment;

13 – On Site Screening Pick-up;14 – Satisfaction Survey;15 – Psychiatric Evaluation;16 – Title IV-E Eligibility Determination;17 – Adoption Home Study;18 – AOD Juvenile Justice;AOD Screen Child Welfare

Issue: JAIS terminology needs to be revised, in some cases, to match the above terminology. This willprovide consistent terminology between the JAC and JAIS and eliminate multiple descriptions. This is

100% complete.

Issue: Allow for a CAFS Authorization column. Once authorized, JAIS should lock date, youth andservice authorized. This will prevent double billing. In process.

wayne county juvenile assessment center audit 2004

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