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Nonotuck Resource Associates Inc.

December 6, 2016 · Read the full official report (PDF) ↗

Published December 6, 2016 Audit covers July 1, 2013 – June 30, 2015 Under Suzanne M. Bump · 2011–2023

In plain English
The auditor found problems with Nonotuck’s paperwork and spending controls: consultant contracts were incomplete, caregiver personnel files were missing required documents, and $4,304 in costs should not have been charged to state contracts.
source
“Nonotuck charged $4,304 of nonreimbursable costs to state contracts.”
Read the plain-English breakdown
What is this?

This is a Massachusetts State Auditor performance audit of Nonotuck Resource Associates Inc., a Northampton nonprofit human-service agency, covering July 1, 2013 through June 30, 2015.

“Nonotuck Resource Associates Inc., founded in 1972, is a not-for-profit human-service agency located in Northampton.”
Why was it audited?

The auditor reviewed whether Nonotuck followed selected laws, regulations, and contract rules, especially because it receives much of its money from state agencies and MassHealth.

“The purpose of our audit was to determine whether Nonotuck complied with certain laws, regulations, and contractual requirements in the areas reviewed.”
Why it matters

The audit matters because state-funded human-service contracts are supposed to be transparent, accountable, and cost-effective.

“This audit was conducted as part of OSA’s ongoing efforts to audit human-service contracting activity by state agencies and to promote accountability, transparency, and cost-effectiveness in state contracting.”
What's in it for me?

If you are a Massachusetts taxpayer or someone who depends on state-funded care programs, this report shows whether public money was properly controlled and used for services.

“Further, this $4,304 could have been used by the state agencies that contract with Nonotuck to pay for program-related expenses for needy citizens.”
The bottom line

Nonotuck generally provided human services, but the auditor found weaknesses in contract administration, personnel-file documentation, and reporting of nonreimbursable costs.

“Nonotuck did not properly administer its consultant contracting process.”
What happens next

The auditor recommended that Nonotuck strengthen policies, put consultant agreements in writing, keep required caregiver documents on file, and work with the state on whether to repay or refile the $4,304 issue.

“Nonotuck should collaborate with OSD to determine whether Nonotuck should repay the unallowable $4,304 or refile its fiscal year 2014 UFR and properly classify the salary and alcohol as nonreimbursable costs.”
Why it's significant

The findings are significant because Nonotuck served people across Massachusetts and received most of its funding from state sources, so weak controls affected publicly funded services.

“Nonotuck receives the majority of its funding from Commonwealth agencies.”
Jargon, unpacked

Adult foster care means eligible elderly or disabled MassHealth members get help with daily tasks like eating, bathing, dressing, walking, household chores, transportation, and medication management.

“The Adult Foster Care Program provides elderly or disabled MassHealth members with assistance in performing activities of daily living (ADLs) and instrumental activities of daily living (IADLs).”
Identified in this audit - source-verified
$4,304

4 figure(s) pending source verification - not shown

What the Auditor checked

What the Auditor found

Nonotuck did not properly administer consultant contracts.
procurement/contractsinternal controlsvendor oversight

Why it matters: Nonotuck lacked legal and financial protections and could not be certain that consultant services and bills matched agreed terms.

Standard: Section 21.08(1) of Title 801 of the Code of Massachusetts Regulations ( Section 21.08(1) of Title 801 of the Code of Massachusetts Regulations )

3 recommendations
  • Nonotuck should establish written policies and procedures for consultant contracts.agency: already implemented
  • Nonotuck should enter into formal written contracts with all its consultants, setting forth clearly defined duties and responsibilities for both parties.agency: agreed
  • Nonotuck should enhance its monitoring of consultant contracts to ensure that all payments are made in accordance with specific terms and conditions of properly executed contracts.agency: already implemented
Agency response & Auditor reply
Agency: "Nonotuck has established a written policy and procedures for consultant contracts. . . ."
Nonotuck did not keep required caregiver personnel-file documentation.
recordkeeping/documentationinternal controls

Why it matters: Nonotuck could not be certain that caregivers knew required policies, completed training and evaluations, had signed required documents, and had suitable homes.

Standard: Nonotuck’s Policies and Procedures Manual; 130 CMR 408.433–435; 115 CMR 7.06 ( 130 CMR 408.433–435 and 115 CMR 7.06 )

1 recommendation
  • Nonotuck should enhance its policies and procedures to ensure that required documentation is maintained in AFC and DDS caregiver files.agency: already implemented
Agency response & Auditor reply
Agency: "Nonotuck has instituted strengthened procedures to ensure that all AFC and DDS care provider files contain all of the required documents."
Nonotuck charged nonreimbursable salary and alcohol costs to state contracts.
internal controlsrecordkeeping/documentation

Why it matters: The costs reduced transparency and could have been used for program-related expenses for needy citizens.

Standard: 808 CMR 1.05 ( 808 CMR 1.05; 808 CMR 1.05(23); 808 CMR 1.05(24) )

2 recommendations
  • Nonotuck should collaborate with OSD to determine whether Nonotuck should repay the unallowable $4,304 or refile its fiscal year 2014 UFR and properly classify the salary and alcohol as nonreimbursable costs.agency: partially agreed
  • Nonotuck should establish adequate internal controls to ensure that all nonreimbursable expenses it incurs are properly identified and reported as such in its UFRs and that no state funds are used to pay for them.agency: already implemented
Agency response & Auditor reply
Agency: "Nonotuck will re-submit the FY2014 UFR within (30) days."
Auditor: "However, it should first collaborate with OSD to determine the appropriate course of action: repaying the $4,304 or refiling the UFR."
MassHealth allowed Nonotuck to bill for unallowable duplicative adult foster care services.
internal controlsvendor oversight

Why it matters: MassHealth paid for duplicative services that regulations did not allow.

Standard: 130 CMR 408.437 and 651 CMR 3.01(2) ( Section 408.437 of Title 130 of the Code of Massachusetts Regulations; 651 CMR 3.01(2) )

1 recommendation
  • Nonotuck should collaborate with MassHealth to find out whether MassHealth intends to cease paying for these duplicative services.
Agency response & Auditor reply
Agency: "MassHealth stated that it needed to review the data that we used in this analysis so that it could evaluate whether its regulations had been violated."

Verified dollar findings

Improper payments identified $4,304

Money paid out that the audit found should not have been - overpayments, unallowable and nonreimbursable charges, improper claims.

$4,304 - nonreimbursable costs