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The Edinburg Center, Inc. Administration of Limited Unit Rate Service Agreements

July 17, 2013 · Edinburg Center, Inc. Administration of Limited Unit Rate Service Agreements · Read the full official report (PDF) ↗

Published July 17, 2013 Audit covers July 1, 2008 – June 30, 2011 Under Suzanne M. Bump · 2011–2023

In plain English
Auditors found serious problems with $477,555 in payments to The Edinburg Center, including late approvals, weak documentation, and spending LUSA money on things it was not meant to cover.
source
“We found problems with $477,555 of Edinburg’s accounts-payable-period LUSA transactions, including inadequate documentation to substantiate that LUSA services were properly authorized, inadequate documentation to support LUSA billings, and LUSA contract funding not being used for its intended purposes, as follows:”
Read the plain-English breakdown
Why was it audited?

The State Auditor reviewed these payments to check whether state human-service contracting money was being used properly, transparently, and cost-effectively.

“The overall audit of DDS 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.”
Why it matters

The report says DDS’s poor handling of these agreements contributed to problems at contractors, including Edinburg, and raised questions about whether public funds were used correctly.

“DDS’s practice of improperly administering and using LUSAs has led to the problems with the administration and use of these funds at various DDS contractors, such as Edinburg.”
What's in it for me?

If you are a Massachusetts resident, this matters because state money paid to human-service contractors needs to be supported by clear records showing what services were actually provided.

“Adequate documentation is required by the previously quoted provisions of the Commonwealth Terms and Conditions for Human and Social Services, and without it, there was insufficient evidence to show that these LUSA payments had been properly authorized and accounted for; that they were not duplicative or excessive; and that the contractor had actually provided the LUSA services billed.”
The bottom line

The Auditor’s bottom line was that Edinburg should tighten its controls so any LUSA services are real, documented, billed correctly, and properly accounted for.

“In accordance with the recommendations of the overall report and the testing results specific to Edinburg, Edinburg should implement appropriate control measures to ensure that all LUSA services are performed, documented, billed, and accounted for in compliance with applicable requirements.”
What happens next

Edinburg said DDS had changed how it uses LUSA agreements and said it would make sure future LUSA services are handled properly.

“DDS has made several changes to its utilization of Limited Unit Rate Service Agreements, and The Edinburg Center will ensure that any services provided under LUSA agreements are performed, documented, billed, and accounted for appropriately.”
Why it's significant

The amount questioned was a large share of Edinburg’s LUSA payments during the audited period: 63.1% of its total DDS LUSA payments.

“Approximately $477,555 (63.1%) of the payments to Edinburg was processed during the accounts-payable periods for fiscal years 2009 through 2011.”
Jargon, unpacked

A LUSA is a state contracting tool DDS can use to buy short-term or occasional services from an approved provider when a client is not already covered by another contract.

“LUSAs are a form of a master contract agreement that can be used by DDS to purchase services from a preapproved contractor on an intermittent, limited-time basis for clients who are not already covered through an existing contract.”
Identified in this audit - source-verified
$64,311

5 figure(s) pending source verification - not shown

What the Auditor found

DDS and Edinburg used $477,555 in LUSA funds in questionable ways, including retroactive authorizations, inadequate documentation, and improper non-service purchases.
procurement/contractsrecordkeeping/documentationinternal controlsvendor oversight

Why it matters: There was insufficient evidence that payments were properly authorized, not duplicative or excessive, and supported by actual LUSA services provided.

Standard: DDS requirements for Authorization for Services Forms; Commonwealth Terms and Conditions for Human and Social Services, Section 7; DDS Purchase of Service Manual; OSD and OSC rules governing capital and service payments. ( Chapter 11, Section 12, of the Massachusetts General Laws; DDS Purchase of Service Manual; Section 7 of the Commonwealth Terms and Conditions for Human and Social Services; 808 CMR 1.00; OSD Procurement Policies and Procedures, “How to Draft a Request for Response” )

1 recommendation
  • Edinburg should implement appropriate control measures to ensure that all LUSA services are performed, documented, billed, and accounted for in compliance with applicable requirements.agency: agreed
Agency response & Auditor reply
Agency: "DDS has made several changes to its utilization of Limited Unit Rate Service Agreements, and The Edinburg Center will ensure that any services provided under LUSA agreements are performed, documented, billed, and accounted for appropriately."

Verified dollar findings

Improper payments identified $64,311

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

$64,311 - improper non-service-item reimbursements