Brockton Area Multi-Services, Inc.
May 14, 2015 · Read the full official report (PDF) ↗
source
“BAMSI billed the Department of Developmental Services (DDS) for $1,429,041 of supplemental services but could not provide the necessary documentation verifying that the services were rendered.”
Read the plain-English breakdown
This is a Massachusetts State Auditor performance audit of Brockton Area Multi-Services, Inc., a nonprofit human-services provider, covering July 1, 2011 through June 30, 2013.
“I am pleased to provide this performance audit of Brockton Area Multi-Services, Inc.”
Auditors checked whether BAMSI followed the rules for its state contracts, including billing, documentation, and allowable expenses.
“The purpose of our audit was to determine whether BAMSI complied with laws, regulations, and contract requirements pertinent to its state contracts.”
BAMSI received tens of millions of dollars from government contracts and grants, so weak documentation or improper charges affect public money.
“In fiscal year 2013, it received $404,964 from external contributions, $522,637 from grants, $61,782,248 from government contracts and grants, and $622,267 from other sources.”
If you are a taxpayer or rely on public services, this audit is about whether state-funded human-service money was properly tracked and spent.
“During our audit period, BAMSI employed approximately 1,700 people and operated a variety of programs serving approximately 25,000 individuals each year in Worcester, Middlesex, Norfolk, Bristol, Plymouth, and Barnstable Counties.”
Auditors said BAMSI needed better records, should fix its policies, and should pay back $18,593 in unallowable charges.
“BAMSI should reimburse the Commonwealth for the $18,593 of unallowable charges to state-funded programs that we identified.”
The state was told to work with BAMSI to decide how much of the roughly $1.4 million should be recovered, and BAMSI said it was updating policies and returning the $18,593.
“Additionally, the state’s Operational Services Division (OSD), in collaboration with DDS, should work with BAMSI to determine how much of the approximately $1.4 million BAMSI billed for the improperly documented services should be recouped.”
The audit points to a basic accountability issue: when a provider bills state contracts, it must be able to prove the services happened and that expenses are allowed.
“According to 808 CMR 1.04(1), adequate documentation includes “supporting documents, statistical records, and all other records which reflect revenues associated with and costs incurred in or allocated to any Program of services rendered under the Contract.””
“Supplemental services” means extra help for certain clients, such as one-to-one help with eating, personal care, nursing care, skill building, or behavior management.
“The supplemental services, billable in 15-minute increments, comprised services such as one-to-one staff assistance with eating/feeding, personal care, skill building, nursing care, and behavior management.”
4 figure(s) pending source verification - not shown
What the Auditor checked
- Complied Does BAMSI have an acceptable allocation plan to assign indirect costs to programs?
- Did not comply Is BAMSI billing only for services that are authorized and supported with the necessary documentation verifying that the services were provided?
- Did not comply Is BAMSI charging only reimbursable expenses against revenue received from state contracts in accordance with 808 CMR 1.05?
What the Auditor found
Why it matters: The undocumented services represented unallowable charges to state contracts and may require recoupment.
Standard: 808 CMR 1.05(26) and 808 CMR 1.04(1) ( 808 Code of Massachusetts Regulations 1.05(26); 808 Code of Massachusetts Regulations 1.04(1) )
2 recommendations
- BAMSI should establish formal written policies and procedures that require that all services billed to its state contracts be adequately documented.agency: already implemented
- OSD, in collaboration with DDS, should work with BAMSI to determine how much of the approximately $1.4 million billed for improperly documented services should be recouped.
Agency response & Auditor reply
Agency: "BAMSI has upgraded its policy on billing to include requirements that the program staff and managers maintain detailed statistical records and provide additional supporting documentation to assure that billed revenue is quantified, and documented in accordance with all applicable requirements as stipulated by [the Executive Office of Health and Human Services]."
Auditor: "As previously noted, BAMSI was not able to provide us with adequate documentation to support the expenses in question; the clinical records, and the daily attendance logs to which BAMSI refers in its response, were not made available to us during our audit."
Why it matters: The state contracts were charged $417,371 in non-reimbursable expenses.
Standard: 808 CMR 1 ( 808 CMR 1 )
1 recommendation
- BAMSI should change its “Policy on Capitalization and Inventory of Agency Equipment” to consider groups of assets collectively for capitalization purposes.agency: already implemented
Agency response & Auditor reply
Agency: "BAMSI has revised its policy to be more explicit concerning group purchasing."
Why it matters: The charges were non-reimbursable and the Commonwealth should be reimbursed.
Standard: 808 CMR 1.05 and BAMSI’s Commercial Credit Card Policy ( 808 CMR 1.05(12); 808 CMR 1.05(23); 808 CMR 1.05(26) )
3 recommendations
- BAMSI should reimburse the Commonwealth for the $18,593 of unallowable charges to state-funded programs that we identified.agency: agreed
- BAMSI should document and enforce policies and procedures requiring original itemized receipts, documented business purposes, and retention of purchase records.
- BAMSI should discontinue the charging of alcohol and tobacco to state-funded programs.agency: disagreed
Agency response & Auditor reply
Agency: "While we will agree to return $18,593 to the Commonwealth of Massachusetts, BAMSI denies purchasing tobacco products with state funds."
Auditor: "Therefore, in accordance with OSD guidelines, the Office of the State Auditor has presumed that state funds were used to pay for these expenses."
Verified dollar findings
Money paid out that the audit found should not have been - overpayments, unallowable and nonreimbursable charges, improper claims.
More audits of this entity
Other Office of the State Auditor reports on Brockton Area Multi-Services, Inc. .
- Audit of Brockton Area Multi-Services, Inc. (BAMSI)Nonprofit / Vendor · June 1, 2021