Audit for School-Based Services

Audit for School-Based Services

School-based services (SBS) – defined as any health care-related service covered by Medicaid and delivered in a school setting – are critical for the underserved children who receive them. These children and their parents rely on these programs to provide holistic care and specialized services, delivered in an integrated fashion directly through their schools.

Typically, Medicaid covers services such as physical therapy, speech therapy, occupational therapy, case management, and even non-emergency medical transportation. Cost reports are not required for all kinds of funding – some services can be just a fee schedule with no cost report, depending on the state and program. However, in many cases, to qualify for federal funding, schools must provide cost reports to demonstrate transparency, accountability, and compliance with requirements established by the Centers for Medicare & Medicaid Services (CMS).

Challenges Ahead

These nuanced and functional programs bring health and social services providers, including behavioral health professionals, together with underserved children in their own schools, which translates into complexity and challenges, in both regulatory compliance and logistical execution.

In fact, audits by the Office of Inspector General (OIG) of state SBS and their associated cost reports have uncovered numerous issues. One of the most critical is incorrect coding in a Random Moment Time Study (RMTS), a tool for defining the amount of time spent on specific activities. This metric helps allocate costs and ensure schools are reimbursed for Medicaid-allowable services. Other challenges include:

  • Lack of service documentation. 
  • No plan available or plans that do not justify the service or cover the delivery date.
  • Local education agencies (LEAs) unable to produce attendance records or coding and billing incorrectly.

Such issues can delay or prevent ongoing federal funding, which in turn causes disruptions to critical programs and services. In addition, schools that are submitting cost reports with incorrect coding or otherwise improper reporting may be liable for repayment to CMS for funding for which they were not qualified.

SBS programs must pass legal muster so that beneficiary children can continue to receive needed services without interruption. And that requires that state agencies have a skilled partner with decades of expertise and depth of knowledge accrued to its trained and experienced professionals. 

How We Can Help

Myers and Stauffer is a nationally based consulting and certified public accounting (CPA) firm. Since 1977, we have worked exclusively with local, state, and federal government health and human-services agencies to help them accomplish their most critical goals for the nation’s most vulnerable people.

We work alongside our clients to help them solve complex financial, performance, compliance, and reimbursement issues. We provide audit, consulting, and compliance oversight services, including performing benefit and program integrity services, which encompasses claims and benefit payment integrity, benefit eligibility integrity, investigative support/expert witness testimony, and program integrity consulting. 

Most importantly, we never work on behalf of schools, only the state Medicaid programs that provide services in the schools. In this way, we maintain our independence and can offer the state impartial advice designed to maximize allowable reimbursement while minimizing risk of overpayment and compliance shortfalls.

Our Targeted and Timely Services

At Myers and Stauffer, providing states with accurate and trustworthy program integrity, audit and attest, and cost report examination services has long been a cornerstone of our business. We have helped our Medicaid clients defend provider appeals and class-action lawsuits, and when requested, we have provided testimony as either fact or expert witnesses. Our efforts have saved state agencies millions of dollars and ensured that accurate cost and statistical information are driving program policies.

  • SBS Specific Experience

    We have nationwide experience with reviews of state compliance with Medicaid SBS reimbursement requirements. We have also helped several states review their SBS claims and Medicaid requirements consistent with guidelines established by the federal government. During these engagements, we help our clients with:

    • Gathering of cost data.
    • Review of RMTS coding.
    • Recalculation of administrative and direct-services claims.
    • Communication and coordination with providers, fiscal agent contractors, and other stakeholders.
    • Development of policies and guidelines, performance of desk reviews of cost data, and help with appeals and litigation associated with reimbursement matters.

  • Audit and Attest Services

    Federal, state, and local government human services agencies reimburse providers billions of dollars annually for services for their fragile, at-risk populations. Our independent attest and consulting services help ensure proper distribution of states’ limited resources. Our work also gives the provider community assurances of fair treatment relative to peers.

  • Cost Report Services

    Our people are fluent in cost report-related regulations and well versed in their methodologies. Our meticulous hands-on work with clients has given our professionals complete understanding of how cost reports work, as well as the reimbursement issues that may result. We currently help 33 state clients with cost report work, and we perform 12,780 health care provider cost report examinations and desk reviews each year. We can help you with the following:

    • Receipt and review of cost reports for a variety of provider types using the uniform desk-review program.
    • Professional review to ensure cost reports have been prepared in compliance with Generally Accepted Accounting Principles, Medicare, and Medicaid guidelines under allowability and classification of costs.
    • Design, implementation, and collection of cost reports.
    • Certified public expenditures.
    • Examinations of cost reports, including verification of:
      • Direct staffing costs and indirect cost rate.
      • Medicaid Individual Education Program (IEP) and Individual and Family Support Program eligibility and counts.
      • RMTS methodology.
      • Third-party contractor costs and IEP student transportation cost.
    • Collaboration to determine procedures necessary for records review to ensure compliance with requirements set forth in the Medicaid state plan.
    • Determination of Medicaid allowable cost and compare to interim payments.
    • Reconciliation of Medicaid paid claims data to claims reported by local government agencies.
    • Review of time-study data and cost allocation plans to ensure appropriate allocations of indirect costs.
    • Representation of states before CMS, the U.S. Department of Justice, and the OIG.

  • Program Integrity Services

    We have intensive experience delivering a comprehensive suite of program integrity services to clients ranging from state Medicaid agencies and Medicaid fraud control units to federal agencies such as the Department of Justice, the Federal Bureaus of Investigations, and the Centers for Medicare & Medicaid Services. We can help with the following:

    • Analyses of claims and encounter data for outliers or items to investigate further.
    • Review of provider documentation to support services billed for compliance with state and federal regulations, provider-specific manuals, and department memoranda.

Why Myers and Stauffer?

In a word… Independence.

Demonstration of comprehensive oversight of programmatic and financial requirements is important for grant recipients to show they are using grant funding appropriately and consistent with established goals. Ongoing program compliance and financial monitoring is an effective method for providing oversight of grant programs and sub recipients and contractors before, during, and after a grant’s lifecycle.

We work with clients to develop monitoring and oversight tools to review adherence to grant requirements and federal regulations, appropriateness of expenditures, invoices and supporting documentation, and oversight and monitoring of sub-recipients and contractors. Compliance tools can be designed for future use by our clients, allowing for easy modifications to criteria conforming to different grant programs and requirements.

For more information about what we offer for School-Based Services, visit our general program page.

For More Information

Johanna Linkenhoker

CPA, Member

PH 804.418.8125

JLinkenhoker@mslc.com

 Kasi Snow

Senior Manager

PH 615.514.6737

KSnow@mslc.com