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Audit Report - A-04-96-54001


Office of Audit

 Audit of the Tennessee`s Disability Determination Services Administrative Costs for Fiscal Years 1993 Through 1995 (A-04-96-54001)   3/24/98

TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

SCOPE AND METHODOLOGY

RESULTS OF REVIEW

TNDDS’ ACCOUNTING FOR DISBURSEMENTS

Medical Service Costs

ALL OTHER NONPERSONNEL COSTS

Overpayment of Contract to Install Computer Equipment
Controls over Computer Equipment Inventory
TNDDS Difference In Audited vs. Claimed Indirect Costs

TNDDS’ ACCOUNTING FOR UNLIQUIDATED OBLIGATIONS

INTERNAL CONTROL ISSUES AT TNDDS

Controls over Time and Attendance Records and Sign-in Logs
Controls over the Earning of Employee Overtime

OTHER MATTERS

CONCLUSIONS AND RECOMMENDATIONS

APPENDICES

Appendix A - Obligations Reported/Allowed TNDDS for Fiscal Year 1993 as of June 30, 1996

Appendix B - Obligations Reported/Allowed TNDDS for Fiscal Year 1994 as of June 30, 1996

Appendix C - Obligations Reported/Allowed TNDDS for Fiscal Year 1995 as of June 30, 1996

Appendix D - Consultative Exam Overpayment Calculation Methodology

Appendix F - Major Report Contributors 

EXECUTIVE SUMMARY

  

We conducted an audit of the administrative costs claimed by the Tennessee State Department of Human Services (TNDHS) for its Disability Determination Services (TNDDS) for the 3-year period ending September 30, 1995.

BACKGROUND

The Social Security Administration (SSA) pays State agencies (SA) for 100 percent of allowable expenditures. Each year, SSA determines the amount of funding authorization. Once approved, each SA is allowed to withdraw Federal funds through the Payment Management System (PMS) within the U.S. Department of Health and Human Services (HHS) to meet immediate program expenses. At the end of each quarter of the Federal Fiscal Year (FY), each SA submits to SSA a "State Agency Report of Obligations for SSA Disability Programs" (Form SSA-4513).

The Disability Insurance (DI) program, established in 1954 under title II of the Social Security Act (the Act), is designed to provide benefits to disabled wage earners and their families in the event the family wage earner becomes disabled. In 1972, the Congress enacted title XVI, the Supplemental Security Income (SSI) program (Public Law (P.L.) 92-603). Title XVI of the Act provides a nationally uniform program of income and disability coverage to financially needy individuals who are aged, blind, or disabled.

SSA is primarily responsible for implementing the general policies governing the development of disability claims under the DI and SSI programs. Disability determinations under both DI and SSI are performed by an agency in each State in accordance with Federal regulations. In carrying out its obligation, each SA is responsible for determining the claimants` disabilities and ensuring that adequate evidence is available to support its determinations. To assist in making proper disability determinations, each SA is authorized to purchase medical examinations, x-ray, and laboratory tests on a consultative basis to supplement evidence obtained from the claimants` physicians or other treating sources.

The objectives of our audit were to determine whether:

  • expenditures and obligations for the period October 1, 1992 through September 30, 1995, were properly authorized, approved, and disbursed;
  • the unliquidated obligation balance is correct;
  • the Federal funds drawn down agree with total expenditures for FYs 1993 through 1995; and
  • internal controls over the accounting and reporting of administrative costs claimed for TNDDS were adequate.

Our methodology included a review of Federal laws, regulations, and instructions pertaining to administrative costs incurred by TNDDS and to the draw down of Federal funds. We held discussions with TNDHS’ internal auditors, State of Tennessee auditors, and SSA`s Atlanta regional office staff. We also reviewed TNDDS’ general operating policies and procedures, and maintenance of computer equipment inventory.

We reviewed internal controls regarding the administration of disability determination activities and performed an examination of administrative expenditures (personnel, medical service, and indirect costs) incurred and claimed by TNDDS for the period October 1, 1992 through September 30, 1995. We reviewed the reconciliation of official accounting records to administrative costs reported by TNDDS to SSA on the Form SSA-4513 report for the period October 1, 1992 through September 30, 1995, and compared the amount of Federal funds drawn for support of program operations to allowable expenditures.

The work was performed at the site of the TNDDS located in Nashville, Tennessee; at the Office of Audit field office in Birmingham, Alabama; and SSA Headquarters in Baltimore, Maryland. The field work was conducted from October 1996 to August 1997.

RESULTS OF REVIEW

TNDDS claimed administrative costs of $79,911,653 for SSA disability determinations as of June 30, 1996, for the years ended September 30, 1993, 1994, and 1995. Obligations reported to SSA should be reduced by $2,012,196 to adjust for overstated disbursements and unliquidated obligations for 1993, 1994, and 1995. (See Appendices A, B, and C.) Specifically, we determined that:

  • MEDICAL SERVICE COSTS OF $425,024 CLAIMED ON FORM SSA-4513 FOR FYs 1993 TO 1995 WERE OVERSTATED
  • A CONTRACT TO INSTALL COMPUTER EQUIPMENT WAS OVERPAID BY $18,750
  • CLAIMED INDIRECT COSTS EXCEEDED AUDITED INDIRECT COSTS BY $6,372
  • COMPUTER EQUIPMENT COSTING $17,839 WAS NOT BEING USED BY TNDDS PERSONNEL
  • UNLIQUIDATED OBLIGATIONS WERE OVERSTATED BY $1,544,211
  • INTERNAL CONTROL WEAKNESSES WERE IDENTIFIED IN MEDICAL SERVICE COSTS, THE MAINTENANCE OF EQUIPMENT INVENTORIES, AND THE RECORDING AND REPORTING OF TIME AND ATTENDANCE (T & A) AND OVERTIME (OT)

CONCLUSIONS AND RECOMMENDATIONS

Based on the tests performed and information obtained from SSA, TNDDS, TNDHS and the State of Tennessee, we recommend that SSA require TNDDS to:

  • refund $425,024 with applicable interest for costs claimed on consultative examination (CE) reimbursements in excess of the highest Federal or State rates for FYs 1993, 1994, and 1995;
  • refund $18,750 with applicable interest for costs claimed in excess of a contract price for FY 1995;
  • refund $6,372 with applicable interest for unsupported indirect costs claimed for FY 1993 and periodically review these obligations to assure that proper balances are reported on Form SSA-4513;
  • reimburse SSA $17,839 with applicable interest for the cost of computer equipment used by TNDHS; and
  • decrease unliquidated obligations by $1,544,211 for computer system upgrades not supported by outstanding purchase orders for FYs 1994 and 1995.

In addition, we have the following internal control recommendations for TNDDS:

  • maintain a crosswalk of TNDDS’ CE codes to the American Medical Association’s (AMA) Physicians’ Current Procedural Terminology (CPT) manual codes used by Federal and State agencies that provide similar services. Provide a costing methodology to enable SSA to determine that TNDDS’ services do not exceed the highest rate paid by Federal or other agencies in the State for the same or similar services;
  • strengthen internal controls over payroll T&A records to prevent duplicate certifications and the potential for submission of erroneous T&A records; and
  • improve internal controls to assure that OT logs and OT workload reports contain prior approval and certification of employee OT, evidenced by signatures of supervisory personnel responsible for the OT.

We also have the following recommendations to SSA:

  • review the various components of the Statewide Indirect Cost Allocation Plan (Cost Allocation Plan) to assure that services are planned and will be rendered to TNDDS for all categories of indirect costs and notify HHS of any exceptions prior to final approval; and
  • controls over desktop computers, printers, and other equipment should be monitored as part of its oversight procedures.

AGENCY COMMENTS AND THE OFFICE OF THE INSPECTOR GENERAL (OIG) RESPONSE

An exit conference was held with TNDDS and SSA on November 25, 1997. Subsequently, TNDDS responded with written comments to our draft findings. Overall, TNDDS did not concur with our findings. The findings and recommendations as presented consider the comments and additional information provided by TNDDS. We believe our recommendations are valid and should be implemented. SSA advised us that it had no further comments. For a full explanation, see page 15 of this report. The full text of TNDDS’ comments is shown in Appendix E.

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INTRODUCTION

 The DI program was established in 1954 under title II of the Act. The program is designed to provide benefits to wage earners and their families in the event the wage earner becomes disabled. In 1972, the Congress enacted the SSI program (P.L. 92-603). Title XVI of the Act provides a nationally uniform program of income to financially needy individuals who are aged, blind, or disabled.

SSA is primarily responsible for implementing the general policies governing the development of disability claims under the DI and SSI programs. Disability determinations under both DI and SSI are performed by an agency in each State in accordance with Federal regulations. In carrying out its obligation, each SA is responsible for determining claimants’ disabilities and ensuring that adequate evidence is available to support its determinations. To assist in making proper disability determinations, each SA is authorized to purchase medical examinations, x-rays, and laboratory tests on a consultative basis to supplement evidence obtained from claimants’ physicians or other treating sources. SSA pays the SA for 100 percent of allowable expenditures. Each year, SSA determines the amount of funding authorization. Once approved, each SA is allowed to withdraw Federal funds through HHS’ PMS to meet immediate program expenses. HHS` Division of Payment Management is responsible for operating this centralized payment system.

Cash drawn from the Department of the Treasury (Treasury) to pay for program expenditures is to be drawn in accordance with 31 Code of Federal Regulation (CFR), Part 205 and, since July 1, 1994, a Treasury/State agreement under the Cash Management Improvement Act (CMIA). At the end of each quarter of the Federal FY, each SA submits to SSA a "State Agency Report of Obligations for SSA Disability Programs" (Form SSA-4513) to account for program disbursements and unliquidated obligations. An advance or reimbursement for costs under the program is subject to the requirements set forth in the Office of Management and Budget’s (OMB) Circular A-87, "Cost Principles for State and Local Governments."

TNDDS is a component within the Division of Rehabilitation Services (DRS) under TNDHS, the parent agency. TNDDS employed approximately 375 people, and for the 3 years audited, had an average annual budget of $26.7 million. SSA authorized a budget of $79,983,108 for FYs’ 1993 through 1995 disability determinations, the only Federal program for which TNDDS conducted operations. TNDHS’ Fiscal Services group performs TNDDS’ primary accounting functions. Allocation of indirect costs is done according to TNDHS’ indirect cost agreement approved by HHS.

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SCOPE AND METHODOLOGY

We audited the costs reported by TNDDS in its Report of Obligations for SSA Disability Programs (Form SSA-4513) for the period October 1, 1992 through September 30, 1995, as reported to SSA through June 30, 1996. The purpose of the audit was to determine whether TNDDS complied with the laws, rules and regulations, and established policies governing SSA’s DDS program. The audit included a review of allowed expenditures and the proper balances of unliquidated obligations. We also reconciled the Federal payments to the allowed expenditures to determine the final amounts due to or from TNDDS.

TNDDS costs are reported in four categories: personnel, medical, indirect, and all other costs. We developed sampling plans to test personnel. Medical expenditures were randomly selected from the universe. (See Appendix D.) TNDDS’ records were not sufficient for us to test all maximum allowable charges for CEs claimed as medical expenditures. However, we were able to test x-ray and lab fees, and other medical costs. We determined that indirect costs were claimed in accordance with the Cost Allocation Plan. We judgmentally selected two cost items reported in the "all other" category for review. For unliquidated obligations, we reviewed the balances of all amounts reported.

We obtained sufficient evidence and conducted such tests, as necessary, to assess TNDDS’ compliance with applicable laws and regulations relating to the draw down of funds pursuant to HHS’ PMS regulations, and its accounting for disbursements and unliquidated obligations pursuant to Treasury regulation 31 CFR Part 205, the CMIA agreement effective July 1, 1994, OMB Circular A-87, and SSA’s Program Operations Manual System (POMS). Except as noted under "RESULTS OF REVIEW," the results of our tests indicated that, with respect to the items tested, TNDDS complied in all material respects with Federal cost principles and regulations. For those items not tested, nothing came to our attention to indicate that the untested items were not in compliance with applicable laws and regulations.

Our audit of TNDDS’ administrative costs for FYs 1993 through 1995 was performed in accordance with generally accepted government auditing standards. The objectives of our audit were to determine whether:

  • expenditures and obligations for the period October 1, 1992 through September 30, 1995, were properly authorized, approved, and disbursed;
  • unliquidated obligation balances were correct;
  • Federal funds drawn down agree with total expenditures for FYs 1993 through 1995; and
  • internal controls over the accounting and reporting of administrative costs claimed for TNDDS were adequate.

To accomplish our objectives, we performed the following:

  • Reviewed Title 20 CFR sections, POMS, and other instructions pertaining to administrative costs incurred by TNDDS and the draw down of Federal funds covered by the CMIA agreement.
  • Interviewed internal auditors for the State of Tennessee and SSA`s regional office (RO) staff on the reporting of costs and RO oversight.
  • Reviewed SSA and TNDDS’ policies and procedures on the recording and reporting of expenditures and obligations.
  • Reviewed the Federal funds drawn down by TNDDS.
  • Performed an examination of administrative expenditures (personnel, medical service, indirect, and all other nonpersonnel costs) incurred and claimed by TNDDS for the period October 1, 1992 through September 30, 1995.
  • Reviewed the reconciliation of official accounting records to administrative costs reported by TNDDS to SSA on Form SSA-4513 reports for the period October 1, 1992 through September 30, 1995.
  • Compared the amount of Federal funds drawn for support of program operations to the allowable expenditures.

We reviewed the internal controls applicable to the recording and reporting of funds authorized, expensed, and obligated. We also reviewed internal controls related to the disbursement of funds and personnel costs. We found the internal controls were logical in design except for the weaknesses identified in this report. Our review of controls included tests of each line item on Form SSA-4513, including personnel, medical, and indirect costs, and a limited review of all other costs.

Our work was performed at the site of TNDDS located in Nashville, Tennessee; the Office of Audit field office in Birmingham, Alabama; and SSA Headquarters in Baltimore, Maryland. Field work was conducted from October 1996 through August 1997. (See Appendix G for SSA’s Organizational Chart.)

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 RESULTS OF REVIEW

 

Our review of the reconciliation of accounting records to administrative costs claimed by TNDDS showed that disbursements and unliquidated obligations were overstated. During FYs 1993 through 1995, TNDDS overstated disbursements by $467,985 and unliquidated obligations by $1,544,211. As a result, total obligations reported to SSA by TNDDS for the periods under audit should be reduced by a total of $2,012,196. (See Appendices A, B, and C.)

We reviewed personnel costs by selecting a sample and reviewing transactions in accordance with that sample. We also reviewed draw downs to determine whether the draw downs agreed with the costs that were claimed. We did not find any questioned costs in either of these areas.

TNDDS’ accounting for disbursements

TNDDS’ costs claimed on Form SSA-4513 should be reduced by $467,985 for the 3-year audit period, FYs 1993 through 1995. Cost adjustments occurred in the medical services, indirect costs, and all other nonpersonnel cost categories. We compared the line item costs reported on Form SSA-4513 to the audited cost accounting records for TNDDS.

The audit adjustments between Form SSA-4513 and the audited cost accounting records are shown below.

DISBURSEMENTS FOR FYs 1993 – 1995

 

FORM SSA-4513 LINE ITEMS

FORM SSA-4513 COSTS CLAIMED

AUDITED COST ACCOUNTING RECORDS

AUDIT ADJUSTMENTS

PERSONNEL COSTS

$40,699,215

$40,699,215

$0

MEDICAL SERVICE COSTS

22,036,696

21,611,672

425,024

INDIRECT COSTS

5,759,691

5,753,319

6,372

ALL OTHER NONPERSONNEL COSTS

11,416,051

11,379,462

36,589

TOTAL DISBURSEMENTS

$79,911,653

$79,443,668 $467,985

Medical Service Costs

In reviewing medical service costs, we selected a sample of CE fees claimed by TNDDS during our audit period. CEs are ordered by TNDDS as part of its eligibility determination process. We tested expenditures for medical examinations, X-rays, and laboratory tests to confirm that TNDDS’ rates of payment complied with SSA requirements for the reimbursement of medical and other services.

According to TNDDS personnel, the CE fee schedule was historically based, in part, on the Medicaid Maximum Price Listing, and, in part, on a psychological services price list provided by TNDHS’ DRS which uses usual and customary charges. TNDDS did not use the AMA CPT codes when requesting CE services. TNDDS created an internal coding system to expedite purchases of medical services by its personnel. TNDDS did not crosswalk its CE codes or otherwise maintain its records in a manner that would enable us to test CE fees for compliance with SSA regulations. We made several requests for TNDDS’ criteria for maximum allowable charges. TNDDS used Medicaid as its criteria for maximum allowable charges for FY 1993. However, TNDDS was unable to demonstrate the use of maximum allowable charges in its payment of medical services. For FYs 1994 through-95, TNDDS did not have criteria for maximum allowable charges. TNDDS personnel stated they were unable to obtain fee schedules from Medicare, TennCare, or other organizations that provide medical services. Therefore, we performed alternative tests.

Title 20 CFR, sections 404.1624 and 416.1024, set forth SSA’s requirements for the purchase of medical and other services, as follows:

The State will determine the rates of payment to be used for purchasing medical or other services necessary to make determinations of disability. The rates may not exceed the highest rate paid by Federal or other agencies in the State for the same or similar type of service. The State will maintain documentation to support the rates of payment it uses.

SSA’s POMS, section DI 39545.210, states the DDS will consider its fee schedules as a maximum payment schedule. Authorized payments will represent the lower of either the provider’s usual and customary charge or, the maximum allowable charge under the fee schedule. (Emphasis added.) The rates must be reasonable and necessary for the administration of the program. POMS, section 39545.410, states that where possible, the AMA coding system should be used to identify each procedure in the schedule. In addition, the DDS should maintain a well-documented methodology for establishing and updating rates of payment.

Since TNDDS was unable to provide copies of its Medicaid and Medicare fee schedules, we obtained Medicare fee schedules for 1993 through1996 and AMA CPT reference books for 1994, 1995, and 1997 from the Medicare intermediary for the State of Tennessee. In testing CE fees, we used established Medicaid and/or Medicare fee schedules and TNDDS’ fee schedules. For FY 1993 and the first quarter of FY 1994 (ending December 31, 1993), we applied the greater of 1990 through 1993 Medicaid rates used by TNDDS as its maximum allowable charges or the Medicare rates to determine the highest allowable rates of payment. For the remainder of FY 1994 and all of 1995, we used Medicare rates because they represented the highest rates of reimbursement available after TNDDS terminated its Medicaid program.

Effective January 1, 1994, Tennessee adopted a statewide managed care program known as TennCare. All medical fees under the new program were negotiated on a provider-by-provider basis. These changes eliminated TNDDS’ use of the Medicaid price list as its maximum allowable charge for rates of payment to be used in purchasing medical or other services. The Tennessee Bureau of Medicaid confirmed the State of Tennessee terminated its Medicaid program on December 31, 1993.

We requested the assistance of TNDDS personnel in matching its CE codes to established AMA CPT codes to assure the comparison of similar medical services in our testing. After consultation with TennCare personnel, most of the remaining coding discrepancies were resolved. We also contacted CIGNA Medicare of Tennessee and the Health Care Financing Administration to resolve other questioned codes.

We selected a simple random sample of 200 CEs purchased by TNDDS for each year under audit. (See Appendix D.) We matched TNDDS’ CE codes to AMA CPT codes. After determining the equivalent AMA CPT codes, we calculated the differences between established Medicaid/Medicare fee schedules and TNDDS’ fee schedules. The resulting variances were applied to the actual number of procedures paid by TNDDS for each year under audit. We determined TNDDS was not in compliance with 20 CFR 404 and 416 due to its failure to apply maximum allowable charges in FY 1993 and its lack thereof for FYs 1994 and 1995.

TNDDS’ psychological fees were based on the usual and customary charges of TNDHS’ DRS whereas AMA CPT codes were based on an hourly rate. We accepted the conversion of customary charges to hourly rates based on information provided by TNDDS and other professionals. Based on our review, we concluded that the amounts paid for psychological fees did not exceed the highest rates paid by Federal or other agencies in the State for the same or similar services.

As an additional comment, a third-party medical professional contacted by us observed, after reviewing TNDDS’ psychological descriptions and codes, that, in the absence of any reporting of time spent by the CE providers, the extent of testing and quality of services provided to patients was a serious concern. SSA may wish to study the impact of this on disability determinations.

We also tested TNDDS’ laboratory, x-ray, and other medical costs. In testing x-rays, we selected CPT codes that represented the types of x-rays performed and number of views taken. X-rays listed in the Medicare fee schedules contained three codes: an overall code, a technical component modifier, and a professional component (–26) modifier. The Medicaid Maximum Price Listing provided by TNDDS did not use the same modifiers. The modifiers allow for separate billing of the two x-ray components: the technical (filmtaking) component and the professional (interpretation) component. The maximum allowable charge on the Medicare schedules for the 5-digit overall code includes filmtaking and interpretation but also allows for separate billing of the components using the modifiers. In all instances, we used the overall code (inclusive of the two components) as the maximum fee allowed.

We also used Deficit Reduction Act of 1984 (DEFRA) legislation in applying maximum price caps of 80 percent and 62 percent to x-ray and blood test codes. Applying the maximum allowable charges for labs, x-rays, and other medical costs for each FY resulted in total overpayments of $425,024, as shown below:

 

Labs

X-rays

Other Medical Costs

Total

FY 1993

$1,516

$ 83,872

$ 8,857

$ 94,245

FY 1994

$3,516

$158,136

$ 28,828

$ 190,480

FY 1995

$2,172

$104,880

$ 33,247

$ 140,299

Totals

$ 7,204 $ 346,888 $ 70,932 $ 425,024

Results of our analyses for the 3-year audit period show that TNDDS’ CE costs exceeded the highest allowable rates by a total of $425,024 and should be refunded to SSA with applicable interest. TNDDS’ practice of using an internal procedural coding system that does not readily translate to the AMA CPT coding system and its lack of and/or failure to apply maximum allowable charges were the primary reasons for the CE overcharges. TNDDS should be required to maintain a crosswalk of its CE codes to AMA CPT codes used by Federal and State agencies that provide similar services. TNDDS should also provide a costing methodology to enable SSA to determine that TNDDS’ services do not exceed the highest rate paid by Federal or other agencies in the State for the same or similar services.

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ALL OTHER NONPERSONNEL COSTS

Overpayment of Contract to Install Computer Equipment

On March 31, 1994, TNDDS was funded by SSA to upgrade its AS/400 minicomputer, undertake software conversion, site preparation, and training. On May 16, 1994, TNDDS entered into a sole source, proprietary contract with VERSA, with headquarters in Toronto, Canada, in the amount of $300,000, for the purpose of converting present software in preparation for examiner workstations.

We reviewed five invoices and disbursement records totaling $318,750 in payment to VERSA under contract number FA-4-11091-4-00. Contract sections B.2., B.3., and B.7. provide:

Section B.2.: The Compensation set forth in Section B.1. shall constitute the entire compensation due the Contractor for the Service and all the Contractor’s obligations hereunder regardless of the difficulty, materials or equipment required.

Section B.3.: The Compensation set forth in Section B.1. is firm for the duration of the Contract and is not subject to escalation for any reason, unless amended.

Section B.7.: In no event shall the maximum liability to the STATE under this contract exceed Three Hundred Thousand Dollars ($300,000).

The only contract amendment, signed by TNDHS on April 26, 1995, extended the contract period for deliverables through December 29, 1995. The amendment stipulated the State would have no obligation for services not performed in accordance with the accompanying schedule. No other amendments were provided by TNDDS or acknowledged by the vendor. VERSA confirmed the $18,750 payment related to the referenced contract. In the absence of an amendment modifying the contract price, TNDDS violated the contract provisions and the excess payment of $18,750 should be refunded to SSA with applicable interest.

Controls over Computer Equipment Inventory

We reviewed TNDDS’ controls over computer equipment by selecting three locations in which to trace inventory logs to the physical equipment. The review disclosed several instances in which equipment was assigned outside TNDDS or to the wrong person, unassigned, or not listed on the inventory.

TNDHS Office Services staff, not TNDDS personnel, were using four desktop computers and two laser printers purchased by SSA for $17,839. Costs associated with TNDHS’ Office Services are allocated based on TNDDS’ average filled positions. Cost centers allocated to TNDDS are as follows: Office Services Administration (cc125), Printing (cc126), Procurement (cc127), Central Supply (cc128), and Lease Management (cc133). During the audit period, these cost centers allocated costs to TNDDS. Therefore, we consider the use of TNDDS equipment duplicative of costs claimed through the Cost Allocation Plan.

In addition, we tested inventory controls and visually inspected 5 of 12 IBM ThinkPad notebook computers. The remaining seven notebook computers could not be verified. The notebooks were stored in a locked cabinet, but the key could not be found. We were told that all the notebooks had been signed out, but no log was produced, and no internal control procedures were provided. TNDDS later produced a sign-out sheet for the 12 notebooks that we tested for accuracy. Computer assignments could not be determined. For example, one person had possession of a notebook still assigned to another employee. The person with the notebook had not signed the inventory control sheet. Another employee had a notebook at his home since November 1996. TNDDS’ record was inadequate and poorly maintained.

TNDDS remedied the situation by establishing a formal inventory log book for the notebook computers which contains the employee’s name, date the equipment is signed out, and expected and actual return dates. A second inventory check verified or accounted for all 12 notebooks. We did not test any changes TNDDS made to inventory controls over the desktop computers, printers, and other equipment. These controls should be monitored by SSA as part of its oversight procedures.

TNDDS Difference In Audited vs. Claimed Indirect Costs

We have also determined there is a difference of $6,372 between the audited and claimed indirect costs under the Cost Allocation Plan in accounts 345.01, and 345.17, statewide parent and departmental allocations, and space allocations, respectively. Total indirect costs billed by the State of Tennessee to TNDDS were $1,916,628. Total costs claimed on Form SSA-4513 for FY 1993 were $1,923,000. Since no unliquidated obligations exist, TNDDS should reimburse SSA the difference of $6,372 and adjust the account balances to their proper amounts. SSA should periodically review the Cost Allocation Plan with TNDDS to assure that indirect costs reflect the proper charges and types of services rendered to TNDDS.

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TNDDS’ accounting for unliquidated obligations

Unliquidated obligations are cost commitments for orders placed, contracts awarded, and services received that have not been paid. Our review showed that TNDDS costs reported on Form SSA-4513 as of June 30, 1996, were overstated by $1,544,211 for unliquidated obligations that were no longer needed. We found controls were inadequate to detect the overstatement. TNDDS did not follow procedures for the approval and monitoring of unliquidated obligations.

 The errors occurred in the line item category as follows:

UNLIQUIDATED OBLIGATIONS FOR FYs 1994 – 1995

 

FORM SSA-4513 LINE ITEMS

FORM SSA-4513 COST CLAIMED

AUDITED COST ACCOUNTING RECORDS

AUDIT ADJUSTMENT

ALL OTHER NONPERSONNEL COST

$11,416,051

$9,871,840

$1,544,211

TOTAL UNLIQUIDATED OBLIGATIONS

$11,416,051

$9,871,840

$1,544,211

We reviewed the unliquidated obligation line item - All Other Nonpersonnel Costs for FYs 1994-1995. TNDDS obligated $527,476 and $1,016,735 in FY 1994 and 1995, respectively, to buy electronic data processing equipment (EDP) for the intelligent work station/local area network (IWS/LAN) approved by SSA. We obtained copies of purchase orders and interviewed TNDDS systems personnel and TNDHS purchasing personnel. We determined that no EDP equipment purchases remained outstanding.

TNDDS and TNDHS are responsible for ensuring obligations are proper. POMS, section DI 39506.809, states that obligations should be supported by a valid purchase order or other binding agreement for the purchase of supplies, equipment, and other contractual services.

POMS, section DI 39506.812, states that valid unliquidated obligations should be supported by documents and records describing the nature of obligations and supporting amounts recorded. POMS further provides that SAs should review unliquidated obligations at least once each month and cancel those no longer valid. However, we found that neither TNDHS nor TNDDS reviews unliquidated obligations as a monthly routine. Controls over the monitoring of unliquidated obligations should be improved so that funds obligated but no longer needed can be reduced.

Internal control issues at TNDDS

OMB Circular A-123 defines management controls as the organization, policies, and procedures used to reasonably ensure that: (i) programs achieve their intended results, (ii) resources are used consistent with agency mission; (iii) programs and resources are protected from waste, fraud, and mismanagement; (iv) laws and regulations are followed; and (v) reliable and timely information is obtained, maintained, reported and used for decision-making.

The American Institute of Certified Public Accountants’ Statements on Auditing Standards, No. 1, section 110, states management is responsible for adopting sound accounting policies and establishing and maintaining an internal control structure that will, among other things, record, process, summarize, and report financial data that is consistent with management’s assertions embodied in the financial statements.

Controls over Time and Attendance Records and Sign-in Logs

TNDDS had personnel service costs of $40.7 million, during the 3-year audit period. We reviewed T&A records for 37 of 45 employees in our sample (8 records could not be found). We verified the missing employee records by other means. T&A records require certification of accuracy by three different signatories: the timekeeper, employee, and his/her supervisor. For 15 of the 37 employee records reviewed, 2 of the 3 signatures were the same. In some instances, the employee was also his/her own timekeeper, and in others, the supervisor was also the timekeeper or had signed for the employee. These duplications occurred on 41 percent of T&A records reviewed.

OMB Circular A-123 states key duties such as authorizing, approving, recording transactions, . . . shall be assigned to separate individuals to minimize the risk of loss to the Government. TNDDS did not follow procedures for the separation of payroll recordkeeping functions to ensure the accuracy and reliability of payroll records. TNDDS should strengthen internal controls over payroll T&A records to prevent duplicate certifications and the potential for submission of erroneous T&A records.

Controls over the Earning of Employee Overtime

We selected employee OT for review because TNDDS’ OT usage, though not extreme, totaled more than 75,000 hours, or the equivalent of 38 staff positions, over the 3-year audit period. TNDDS’ OT expense totaled $1.1 million for the audit period. A comparison of personnel service costs among the eight states in the southeastern region disclosed that TNDDS had the second highest costs in FYs 1993 and 1994, behind Georgia. TNDDS had the highest costs for FY 1995, as Georgia dropped to second place. TNDDS’ FY 1995 obligations per case (i.e., total obligations total claims processed) were highest at $311, followed by Georgia with $301. The average for the remaining six states was $254. TNDDS’ obligations per case were 22 percent higher than the average. In contrast, TNDDS’ production ranked fourth and fifth in the region during the audit period.

SSA’s POMS DI 39518.015 states DDS management has a responsibility to establish payment procedures for OT worked by employees of the disability unit such as disability examiners, clerical personnel, and medical consultants. For all direct and indirect personnel services and related employee costs, DDSs are required to maintain records that support payroll expenditures and related services rendered by officers or employees of the agency, reflect that OT expense was necessary and properly approved, and demonstrate applicable personnel rules and regulations were observed. POMS also states while OT may be necessary to provide the productive capacity to cope with variations and peaks in workload levels, OT should be used only where it would be consistent with efficient economical administration and that necessary controls applicable to OT work must be maintained in State agencies.

We analyzed OT from the statistical sample of employees drawn for the purpose of testing payroll costs. We determined that 93.5 hours of OT were recorded during the sampled pay periods, with one employee accounting for the majority of OT hours. OT was recorded for this employee every month during the 3-year audit period, except October 1993 when OT could not be earned due to budget constraints. Analysis of this clerical supervisor’s use of OT disclosed that the employee routinely worked 11 to 14 hour days and was among the last TNDDS employees to leave the building. OT for this and several other clerical supervisors was 37 percent to 56 percent above the normal 1,950 hour work year. TNDDS did not require these supervisors to use a sign-in/sign-out log for OT.

TNDDS provided excerpts of departmental OT procedures for 1993 through 1994. Copies of signature logs received at the conclusion of field work were generally outside the audit period. OT hours for selected employees with high OT were independently verified through inspection of sign-in logs maintained by building security. Two clerical supervisors routinely left 4 to 5 hours after the supervisor who certified their time cards. OT logs and workload reports contained insufficient evidence of supervisory signatures and approval. While these examples appeared to be aberrant situations compared to all other employees, TNDDS should improve internal controls to assure that OT logs and workload reports contain prior approval and certification of all employee OT, evidenced by signatures of supervisory personnel responsible for the OT.

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OTHER MATTERS

TNDDS’ Indirect Costs for Internal Audit Are Not Allocable

Single Audits conducted by the Division of State Audit for State FYs 1994 and 1995 contained findings that TNDHS’ internal audit function was ineffective and understaffed. State Audit Reports disclosed that, in both periods, TNDHS’ internal audit section did not have sufficient personnel to meet the needs of the department. The FY 1994 report noted that TNDHS’ internal audit section had no more than four auditors, two of whom performed audits solely of Child and Adult Care Food Program recipients. The FY 1995 report noted TNDHS’ internal audit function was understaffed and due to the lack of personnel, planned audits and reviews were not completed.

TNDHS internal auditors attending the October 1996 entrance conference stated they had not performed any internal reviews for TNDDS during our 3-year audit period. TNDDS incurred internal audit charges of $21,769 for FYs 1993 through 1995 under indirect cost allotment code 345.01, cost center 104. TNDDS was reimbursed by SSA for 100 percent of the quarterly charges, as shown below.

Quarter Ended: Indirect cost charged:
December 31, 1992

$1,040

March 31, 1993

1,749

June 30, 1993

1,948

September 30, 1993

1,837

$ 6,574

(FY 1993)
December 31, 1993

$1,733

March 31, 1994

2,047

June 30, 1994

2,126

September 30, 1994

2,080

  $ 7,986

(FY 1994)
December 31, 1994

$1,984

March 31, 1995

1,195

June 30, 1995

1,719

September 30, 1995

2,311

$ 7,209

(FY 1995)
   
Total Indirect Cost  

$21,769

Based on the Single Audit Reports of the State Audit Division and statements of the TNDHS auditors, TNDDS incurred costs for which no services or benefits were received.

Since indirect costs were reviewed on a selective basis, we were unable to determine the extent of SSA reimbursements to TNDDS for services not rendered by the State of Tennessee. SSA needs to take a more active role in the development and acceptance of the Cost Allocation Plan. SSA should review the various components of the Cost Allocation Plan to assure that services are planned and will be rendered to TNDDS for all categories of indirect costs. SSA should notify HHS of any exceptions prior to final approval.

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CONCLUSIONS AND RECOMMENDATIONS

  

Based on information obtained from SSA, TNDDS, TNDHS, and the State of Tennessee, and the tests performed, we recommend that SSA require TNDDS to:

1.   Refund $425,024 with applicable interest for the costs claimed on CE reimbursements in excess of the highest Federal or State rates for FYs 1993, 1994, and 1995.

2.   Refund $18,750 with applicable interest for costs claimed in excess of a contract price for FY 1995.

3.   Refund $6,372 with applicable interest for unsupported indirect costs claimed for FY 1993 and to periodically review these obligations to assure that proper balances are reported on   Form SSA-4513.

4.   Reimburse SSA $17,839 with applicable interest for cost of computer equipment used by TNDHS.

5.   Decrease unliquidated obligations by $1,544,211 for computer system upgrades not supported by outstanding purchase orders for FYs 1994 and 1995.

In addition, we have the following internal control recommendations for TNDDS:

6.   Maintain a crosswalk of TNDDS’ CE codes to AMA CPT codes used by Federal and State agencies that provide similar services. Provide a costing methodology to enable SSA to determine that TNDDS’ services do not exceed the highest rate paid by Federal or other agencies in the State for the same or similar services.

7.   Strengthen internal controls over payroll T&A records to prevent duplicate certifications and the potential for submission of erroneous T&A records.

8.   Improve internal controls to assure that OT logs and OT workload reports contain written approval and certification of employee OT, evidenced by signatures of supervisory personnel responsible for the OT.

We also have the following recommendations to SSA:

9.   Review the various components of the Cost Allocation Plan to assure that services are planned and will be rendered to TNDDS for all categories of indirect costs and notify HHS of any exceptions prior to final approval.

10. Controls over desktop computers, printers, and other equipment should be monitored as part of its oversight procedures.

AGENCY COMMENTS AND OIG RESPONSE

An exit conference was held with TNDDS and SSA on November 25, 1997. Subsequently, TNDDS responded with written comments to our draft findings. Overall, TNDDS did not concur with our findings. The findings and recommendations as presented consider the comments and additional information provided by TNDDS. We believe our recommendations are valid and should be implemented. SSA advised us that it had no further comments. See below for a full explanation. The full text of TNDDS’ comments is shown in Appendix E.

FINDING 1 – MEDICAL SERVICE COSTS

TNDDS’ COMMENTS

TNDDS did not concur that the costs for laboratory, x-ray services, and other medical costs exceeded the highest rate paid by Federal or other agencies in the State for the same or similar type of service. TNDDS responded that the OIG had failed to include the fee for interpretation as part of the necessary costs in most of the laboratory, x-ray, and other medical cost rates cited in the fee schedules. TNDDS also stated it has an adequate crosswalk system to AMA CPT manual codes but will undertake further efforts to clarify this as an aid for an audit trail.

OIG RESPONSE

While TNDDS is correct in stating that certain fees are separated into a technical (filmtaking) component and a professional (interpretation) component by code, there is also a 5-digit overall code that includes filmtaking and interpretation. In all instances, we used the overall code as the maximum fee allowed. TNDDS also contended type of service (TOS) codes 3 and 5 on the Medicaid Maximum Price Listing represented the filmtaking and interpretation fees. However, TOS codes represent the location of the service or type of service provider. Code 3 indicates medical services and code 5 indicates a hospital-based provider.

Information obtained from the Tennessee Bureau of Medicaid concerning x-ray and blood test codes revealed maximum price caps of 80 percent and 62 percent, due to DEFRA legislation. The Tennessee Bureau of Medicaid also advised us that TNDDS’ use of an interpretation fee equal to 33 percent of filmtaking charges was unique to the DDS and not a customary billing methodology under Medicaid. We used the DEFRA price caps to determine total CE overcharges for FY 1993 and the first quarter of 1994. Similar changes were made to exam codes and the hearing evaluation code based on information obtained from TNDDS and other third parties.

FINDING 2 – UNLIQUIDATED OBLIGATIONS

TNDDS’ COMMENTS

TNDDS did not concur. TNDDS responded that the original correspondence from SSA’s regional office in Atlanta on this issue could not be retrieved. In telephone conversations between TNDDS and the Atlanta SSA regional office, an agreement was made to obligate funds to the Tennessee Department of Finance and Administration to complete the reconfiguration of TNDDS’ occupied space.

TNDDS also stated that during the post-audit quarter ending September 30, 1996, the FY 1994 unliquidated obligation of $527,476 was liquidated in the amount of $140,760 and the remaining unexpended funds of $386,716 would be closed out on a final Form SSA-4513. The FY 1995 unliquidated obligation of $1,016,735 has been partially liquidated in the amount of $58,308, leaving a balance of $958,427, with invoices for upgrades continuing to be received.

OIG RESPONSE

Our audit disclosed that TNDDS reported outstanding obligations of $527,476 and $1,016,735 in FYs 1994 and 1995, respectively, to buy EDP equipment for the IWS/LAN approved by SSA.

Copies of purchase orders and interviews with TNDDS systems personnel and TNDHS purchasing personnel confirmed that no EDP equipment purchases remained outstanding. TNDDS did not provide evidence that the $140,760 and $58,308, subsequently liquidated, were obligated by valid purchase orders or binding agreements prior to the end of its respective FY. Therefore, TNDDS has not provided any documentary evidence indicating that the reported $1,544,211 unliquidated balance was for valid obligations recorded prior to the close of the FY. We affirm our recommendation that unliquidated obligations be decreased in the amount unsupported by purchase orders outstanding.

FINDING 3 – ALL OTHER NONPERSONNEL COSTS

TNDDS’ COMMENTS

TNDDS did not concur with three issues relating to all other personnel costs.

First, TNDDS believed that the $18,750 paid to VERSA Management Systems Incorporated (VERSA) was not part of its $300,000 contract but was contracted for separately.

Second, TNDDS believed that equipment used by TNDHS personnel, valued at $17,839, was used to provide services to TNDDS. TNDDS believed that these costs were not duplicative of costs contained in its Cost Allocation Plan.

Finally, TNDDS stated that its records supported costs amounting to $6,372, because the amounts reported on Form SSA-4513 match its schedule of indirect costs. The schedule agrees with the billings from Fiscal Services staff who calculate the indirect costs.

OIG RESPONSE

We examined invoices and disbursement records to VERSA totaling $318,750 in payment under contract number FA-4-11091-4-00 for the conversion of software in preparation for examiner workstations. Contrary to TNDDS’ comments, VERSA confirmed that the FY 1995 payment of $18,750 related to the referenced contract. In the absence of an amendment modifying the $300,000 contract price, TNDDS violated contract provisions prohibiting escalation and should be required to refund the excess payment to SSA with applicable interest.

With respect to the second issue, TNDHS Office Services staff not TNDDS personnel were using four desktop computers and two laser printers purchased by SSA for $17,839. During the 3-year audit period, these office services were also allocated to the TNDDS through the TNDHS Cost Allocation Plan. No evidence was presented to show that TNDHS’ Office Service costs dedicated to TNDDS were more than the costs included in the Cost Allocation Plan. Since office services are included in the Cost Allocation Plan, we recommend that TNDDS reimburse SSA for the cost of the computers plus applicable interest.

Finally, our review disclosed that claimed indirect costs under the Cost Allocation Plan exceeded audited costs by $6,372. Total indirect costs billed by the State of Tennessee to TNDDS in FY 1993 were $1,916,628. Total costs claimed by TNDDS on the Form SSA-4513 were $1,923,000. Information provided by TNDDS Fiscal Services staff at the close of our field work contained no evidence or explanation for the unlocated variance, and TNDDS has not provided any evidence since that time. Since no unliquidated obligations exist, TNDDS should reimburse SSA the difference of $6,372 and adjust the account balances to their proper amounts.

FINDING 4 – INTERNAL CONTROL ISSUES AT TNDDS

TNDDS’ COMMENTS

TNDDS partially concurred with this finding. TNDDS responded that for the audit period, some leave and attendance records could not be retrieved due to several moves resulting from space reconfiguration and employee transfers. Other records may have been purged in keeping with State government time frames for retention of files. TNDDS noted efforts have been initiated to improve internal controls over attendance records.

OIG RESPONSE

We reviewed T&A records for 37 of 45 employees in our sample. Although the TNDDS provided a general explanation for the loss of records POMS governs record retention in TNDDS’ operations. POMS, sections DI 39509.001 and DI 39509.005, require all financial records and supporting documents to be retained for a period of 3 years with the qualification that financial records and supporting documents will be retained until resolution of Federal audit findings. We recommend TNDDS strengthen internal controls to ensure proper certification and prior approval of employee payroll and OT records.

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  APPENDICES

 APPENDIX A

OBLIGATIONS REPORTED/ALLOWED TENNESSEE DISABILITY DETERMINATION SERVICES FOR FISCAL YEAR 1993 AS OF JUNE 30, 1996

 

TOTAL OBLIGATIONS

UNLIQUIDATED OBLIGATIONS

DISBURSEMENTS

COSTS

REPORTED

NET RECOMMENDED ADJUSTMENTS

ALLOWABLE

REPORTED

NET RECOMMENDED ADJUSTMENTS

ALLOWABLE

REPORTED

ADJUSTMENTS

ALLOWABLE

PERSONNEL

$12,581,127

$0

$12,581,127

$0

$0

$0

$12,581,127

$0

$12,581,127

MEDICAL

7,294,802

(94,245)

7,200,557

0

0

0

7,294,802

(94,245)

7,200,557

INDIRECT

1,923,000

(6,372)

1,916,628

0

0

0

1,923,000

(6,372)

1,916,628

ALL OTHER

1,976,981

0

1,976,981

0

0

0

1,976,981

0

1,976,981

TOTAL  

($100,617)

 

$0

$0

$0

 

($100,617)

 

 








APPENDIX B

OBLIGATIONS REPORTED/ALLOWED TENNESSEE DISABILITY DETERMINATION SERVICES FOR FISCAL YEAR 1994 AS OF JUNE 30, 1996

 

TOTAL OBLIGATIONS

UNLIQUIDATED OBLIGATIONS

DISBURSEMENTS

COSTS

REPORTED

NET RECOMMENDED ADJUSTMENTS

ALLOWABLE

REPORTED

NET RECOMMENDED ADJUSTMENTS

ALLOWABLE

REPORTED

ADJUSTMENTS

ALLOWABLE

PERSONNEL

$13,474,673

$0

$13,474,673

$0

$0

$0

$13,474,673

$0

$13,474,673

MEDICAL

7,542,866

(190,480)

7,352,386

0

0

0

7,542,866

(190,480)

7,352,386

INDIRECT

1,962,839

0

1,962,839

0

0

0

1,962,839

0

1,962,839

ALL OTHER

4,355,927

(527,476)

3,828,451

527,476

(527,476)

0

3,828,451

0

3,828,451

TOTAL      

$527,476

($527,476)

$0

 

($190,480)

 

 

 

 

 

 

 

 

APPENDIX C

OBLIGATIONS REPORTED/ALLOWED TENNESSEE DISABILITY DETERMINATION SERVICES FOR FISCAL YEAR 1995 AS OF JUNE 30, 1996

 

TOTAL OBLIGATIONS

UNLIQUIDATED OBLIGATIONS

DISBURSEMENTS

COST

REPORTED

NET RECOMMENDED ADJUSTMENTS

ALLOWABLE

REPORTED

NET RECOMMENDED ADJUSTMENTS

ALLOWABLE

REPORTED

ADJUSTMENTS

ALLOWABLE

PERSONNEL

$14,643,415

$0

$14,643,415

$0

$0

$0

$14,643,415

$0

$14,643,415

MEDICAL

7,199,028

(140,299)

7,058,729

0

0

0

7,199,028

(140,299)

7,058,729

INDIRECT

1,873,852

0

1,873,852

0

0

0

1,873,852

0

1,873,852

ALL OTHER

5,083,143

(1,053,324)

4,029,819

1,016,735

(1,016,735)

0

4,066,408

(36,589)

4,029,819

TOTAL      

$1,016,735

($1,016,735)

$0

     











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 APPENDIX D

CONSULTATIVE EXAM CALCULATION METHODOLOGY

Population: The total number of consultative exams (CE) encumbered and paid during any Federal fiscal year (FY) by the Tennessee Disability Determination Services (TNDDS) and submitted for reimbursement to the Social Security Administration (SSA). Our population consisted of 117,317 CE transactions paid and reimbursed by SSA for the audit period (52,031 for FY 1993, 64,841 for FY 1994, and 60,445 for FY 1995).

Sample Size: A sample size of 600 was used because of an expected high error rate. The 600 sample size consists of 200 items for each FY under review (1993 through 1995).

Sample Selection: A simple random sample was used.

Characteristics: An error would be a CE claim with a fee charge that is in excess of Medicaid/Medicare maximum charges for reimbursement.

Calculation Methodology: From the sample of CE claims, we developed a crosswalk to the American Medical Association’s Physician’s Current Procedural Terminology (CPT) codes. The crosswalk codes were determined in conjunction with TNDDS personnel and other medical service providers. For x-rays, we selected CPT codes that represented the types of x-rays performed and the number of views taken. We then matched the identified CPT codes with the Medicaid/Medicare fee schedules. Certain procedures, like x-rays, are a combination of a professional component (interpretation) and a technical component (filmtaking). When the professional component is reported separately, the service may be identified by adding the modifier ‘–26’ to the usual 5-digit procedure number. The technical component (TC)’ modifier used in the Medicare fee schedules denotes the technical component. The Medicare fee schedules list three codes: a 5-digit procedure code; a 5-digit procedure code with ‘TC’ modifier; and a 5-digit code with ‘–26’ modifier. The maximum allowable charge on the Medicare schedules for the 5-digit procedure code are inclusive of interpretation and filmtaking but allow for separate billing of the two components. For our audit, we used the overall 5-digit procedure code (inclusive of both filmtaking and interpretation), without modifiers, as the maximum fee allowed.

We applied our crosswalk to the files obtained from TNDDS representing CE reimbursements for the years under audit. We calculated the variance between established Medicaid/Medicare fee schedules and TNDDS’ fee schedules. The variances calculated were multiplied by the actual number of procedures paid by TNDDS for each year under audit and totaled to arrive at the overcharges. TNDDS codes that could not be crosswalked to CPT codes were excluded from our calculations.

Results: Calculated CE overpayments amounted to: $94,244.76 for FY 1993; $190,479.88 for FY 1994; and $140,299.45 for FY 1995. Total overpayments amount to $425,024.09, as follows:

Other

  Labs X-rays Medical Services Totals
1993 $ 1,515.86 $ 83,871.60 $ 8,857.30 $ 94,244.76
1994 $ 3,515.85 $ 158,136.20 $ 28,827.83 $ 190,479.88
1995 $ 2,172.32 $ 104,879.96 $ 33,247.17 $ 140,299.45
  $ 7,204.03 $ 346,887.76 $ 70,932.30 $ 425,024.09
APPENDIX E

  APPENDIX F

MAJOR REPORT CONTRIBUTORS

 This audit report was prepared by the Office of Audit, Eastern Program Audit Group in Baltimore,
under the direction of Gary Kramer, Director. Audit staff included:

Albert Darago, Acting Director
Betty Alexander, Deputy Director
Lance Chilcoat, Acting Team Leader
Robert Daniels, Jr., Auditor-in-Charge
Glenn Lee, Auditor
Reginald Palmore, Auditor

For additional copies of this report, please contact the Office of the Inspector General’s Public Affairs Specialist at (410) 966-9135.
Refer to Common Identification Number A-04-96-54001.

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