Rehabilitation and Health, Inc.
December 3, 2015 · Read the full official report (PDF) ↗
source
“Below is a summary of our findings and recommendations, with links to each page listed.”
Read the plain-English breakdown
This is a Massachusetts State Auditor performance audit of Rehabilitation and Health, Inc., a nonprofit in East Boston that provides inpatient mental-health and substance-abuse services.
“Rehabilitation and Health, Inc. (RHI) is a not-for-profit human-service organization providing inpatient mental-health and substance-abuse services in East Boston.”
The auditor reviewed whether RHI followed laws, rules, contract terms, its own bylaws, and other requirements during the audit period.
“The purpose of our audit was to review certain aspects of RHI’s operations to determine its compliance with applicable laws, regulations, policies, and procedures; the terms and conditions of its state contracts; and its corporate bylaws and other guidance in the areas reviewed.”
Most of RHI’s revenue came from the state Department of Public Health, so taxpayers have a stake in whether state money was properly documented and controlled.
“In 2013, RHI’s total revenue was $1,318,741, of which $1,077,673 was received from DPH.”
If you are a Massachusetts resident, this audit is about whether public funds supporting mental-health and substance-abuse services were properly tracked and overseen.
“RHI provides various services, including group and individual therapy, substance-abuse treatment, psychopharmacology and medication management, outreach services, and family therapy.”
The auditor found documentation and oversight problems, but the report says RHI’s state billings, cost allocation, leases, related-party transactions, and account monitoring were acceptable in the areas reviewed.
“Were the amounts that RHI billed to the state consistent with RHI’s contracts with the Commonwealth?”
RHI was told to improve documentation, work with the state on any costs that may need repayment, follow or update its board-meeting rules, and keep payroll records for seven years.
“After our audit, RHI created a purchase-authorization procedure to provide documentation of direct program expenses and began scanning employee time cards for record-retention purposes.”
The most serious public-risk issue was not only the $3,450 in unsupported expenses, but also that weak board-meeting records and missing payroll records could reduce oversight and accountability.
“Infrequent board meetings could result in a lack of proper oversight of the organization’s operations and in board members not being knowledgeable about the entity’s activities and therefore not being sufficiently informed to act in the best interest of the organization.”
“Inadequately documented expenses” means costs that RHI charged to state programs but could not back up with enough records, such as receipts or other proof.
“RHI could not provide documentation for a total of $3,450 paid to five vendors during our audit period.”
1 figure(s) pending source verification - not shown
What the Auditor checked
- Did not comply Were all the expenses that RHI charged to the Commonwealth reasonable and allowable according to applicable regulations and the terms and conditions of state contracts?
- Did not comply Did RHI’s board of directors fulfill its oversight duties in accordance with its bylaws and the Massachusetts Attorney General’s Guide for Board Members of Charitable Organizations?
- Complied Were the amounts that RHI billed to the state consistent with RHI’s contracts with the Commonwealth?
- Complied Were cost-allocation procedures adequately designed to allow segregation of costs by program?
- Complied Did contracts and leases initiated during our audit period comply with applicable state regulations and contract requirements?
- Complied Does RHI have adequate internal controls regarding reconciliation and monitoring of accounts?
- Complied Were related-party transactions appropriate and disclosed in accordance with applicable regulations promulgated by the state’s Operational Services Division (OSD) and with state contract terms?
- Did not comply Were payroll procedures adequate to document amounts charged to state programs?
What the Auditor found
Why it matters: The Commonwealth may have reimbursed costs that were not adequately supported and may be nonreimbursable.
Standard: 808 CMR 1.05(26) and Commonwealth Terms and Conditions for Human and Social Services record-retention requirements. ( Section 1.05(26) of Title 808 of the Code of Massachusetts Regulations; Commonwealth Terms and Conditions for Human and Social Services )
2 recommendations
- RHI should update its policies and procedures to require that documentation be retained for all expenditures charged to state programs.
- RHI should cooperate with OSD to resolve nonreimbursable cost issues and reimburse the Commonwealth for any costs OSD determines must be repaid.
Agency response & Auditor reply
Agency: "[In] the State Audit Report, $3,450 appears as undocumented expenses."
Auditor: "The requested information was not provided to us throughout our audit period."
Why it matters: Infrequent meetings could weaken board oversight and leave board members insufficiently informed about the organization’s activities.
Standard: Section 1 of Article II of RHI’s bylaws. ( Section 1 of Article II of RHI’s bylaws )
1 recommendation
- Board members and management should know and meet RHI’s bylaw meeting requirements, or amend the bylaws if meeting frequency or nature should change.agency: already implemented
Agency response & Auditor reply
Agency: "The By-Laws were discussed by the Board of Directors of Rehab & Health at the most recent Board Meeting on June 16, 2015, and voted to amend the By-Laws to reflect a minimum of two Board Meetings annually."
Auditor: "We continue to recommend that RHI convene board meetings in compliance with its bylaws and that all board meetings be documented."
Why it matters: Without time cards, RHI lacked payroll records documenting employee attestations and supervisory approval for hours charged.
Standard: 808 CMR 1.04(1), AICPA Document Retention Guide, and state contract record-retention requirements. ( 808 CMR 1.04(1); AICPA Document Retention Guide )
1 recommendation
- RHI should retain all payroll records, including time cards, for seven years.
Agency response & Auditor reply
Agency: "Rehab & Health does have a system of internal control which has been maintained for many years."
Auditor: "We therefore encourage RHI to revise its record-retention policies to comply fully with this requirement."