Audit of the Office of Medicaid (MassHealth) - Review of Payment for Telehealth Adult Foster Care and Group Adult Foster Care (September 4, 2024)
September 4, 2024 · Office of Medicaid (MassHealth) · Read the full official report on mass.gov ↗ · official site ↗
source
“The purpose of this audit was to determine whether MassHealth monitored telehealth practices for AFC and GAFC services to ensure compliance with its regulations.”
Read the plain-English breakdown
This is a State Auditor review of MassHealth payments for adult foster care and group adult foster care services delivered or billed as telehealth during the COVID-19 period.
“OSA has conducted a performance audit of MassHealth’s payments for telehealth adult foster care (AFC) and group adult foster care (GAFC) services for the period January 1, 2020 through December 31, 2021.”
The Auditor’s office reviews Medicaid spending to look for fraud, waste, abuse, and weak controls in MassHealth.
“The Office of the State Auditor (OSA) receives an annual appropriation for the operation of a Medicaid Audit Unit to help identify fraud, waste, and abuse in the Commonwealth’s Medicaid program.”
These programs serve older adults and adults with disabilities, so missing oversight and missing records can raise questions about whether people got the care they needed.
“The MassHealth adult foster care (AFC) and group adult foster care (GAFC) programs provide adult members over 65 and adult members with disabilities with assistance performing activities of daily living (ADLs) and instrumental activities of daily living (IADLs).”
If you are a taxpayer, MassHealth member, caregiver, or family member, the audit is about whether public healthcare money was spent properly and whether care was documented and monitored.
“Our audit is designed to identify issues that will help improve the Medicaid program, so taxpayers know that their dollars are spent prudently and that there is a system of continuous improvement to support improved efficiency and service over time.”
The audit found three main problems: missing required oversight visits, missing or incomplete caregiver logs, and claims incorrectly coded as telehealth.
“Below is a summary of our findings, the effects of those findings, and our recommendations, with links to each page listed.”
MassHealth agreed with the recommendations, said it will strengthen monitoring, and said it will add a system edit to stop these telehealth-coded AFC and GAFC claims.
“We will be conducting a post-audit review in approximately six months to follow up.”
The dollars were large: MassHealth paid more than $771 million for AFC and GAFC claims in the audit period, including nearly $23 million for claims coded as telehealth.
“During this period, MassHealth paid $771,112,638 for 7,099,054 AFC and GAFC claims, of which, $22,979,654 was paid for 310,831 telehealth AFC and GAFC claims.”
AFC means adult foster care, GAFC means group adult foster care, and ADLs are basic daily needs like eating, dressing, bathing, toileting, and walking.
“ADLs include activities such as eating, toileting, dressing, bathing, and walking.”
What the Auditor checked
- Did not comply Did MassHealth monitor adult foster care (AFC) and group adult foster care (GAFC) providers to ensure that they complied with Section 408 of Title 130 of the Code of Massachusetts Regulations (CMR), 130 CMR 450, and MassHealth Adult Foster Care Bulletins 18 and 21?
What the Auditor found
Why it matters: Missing oversight visits call into question whether members received proper quality of care and whether caregivers and direct care aides were adequately supported.
Standard: 130 CMR 408.415 and 130 CMR 408.505 require nursing oversight and care management visits at prescribed intervals. ( Section 408.415 of Title 130 of the Code of Massachusetts Regulations; 130 CMR 408.505(B)(6) )
1 recommendation
- MassHealth should establish effective monitoring controls to ensure that AFC and GAFC providers conduct the required oversight visits for MassHealth members and caregivers / direct care aides.agency: agreed
Agency response & Auditor reply
Agency: "MassHealth agrees with this recommendation."
Auditor: "We commend MassHealth for implementing stronger monitoring controls over AFC and GAFC providers."
Why it matters: Insufficient documentation makes it unclear whether services were delivered and whether they were necessary or appropriate for members.
Standard: 130 CMR 408.433(C)(2) and (3), 130 CMR 408.434(C), 130 CMR 408.524(B)(1), (2), and (5), 130 CMR 408.524(C)(2)(a), and 130 CMR 450.205 require caregiver and direct care aide logs and complete records. ( 130 CMR 408.433(C)(2) and (3); 130 CMR 408.434(C); 130 CMR 408.524(B)(1), (2), and (5); 130 CMR 408.524(C)(2)(a); 130 CMR 450.205 )
1 recommendation
- MassHealth should establish an effective monitoring process to ensure that caregivers / direct care aides of AFC and GAFC providers properly document care in their logs.agency: agreed
Agency response & Auditor reply
Agency: "MassHealth agrees with this recommendation."
Auditor: "We commend MassHealth for implementing stronger monitoring controls over AFC and GAFC providers."
Why it matters: Incorrectly billed services may result in payment for unallowable services and reduce funds available for allowable services for other MassHealth members.
Standard: MassHealth Adult Foster Care Bulletin 21 prohibits AFC and GAFC providers from using telehealth for caregiver or direct care aide assistance with activities of daily living or instrumental activities of daily living. ( MassHealth Adult Foster Care Bulletin 21 )
1 recommendation
- MassHealth should add a system control in MMIS to deny AFC and GAFC caregiver / direct care aide services in a telehealth setting.agency: agreed
Agency response & Auditor reply
Agency: "MassHealth agrees with this recommendation."
Auditor: "Based on its response, MassHealth agrees with our recommendation and plans to implement the system control to prevent providers the ability to submit claims for AFC and GAFC as telehealth."
Verified dollar findings
Money paid out that the audit found should not have been - overpayments, unallowable and nonreimbursable charges, improper claims.
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