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ASBO SOUTHERN TIER CHAPTER October 22, 2014 MEETING

ASBO SOUTHERN TIER CHAPTER October 22, 2014 MEETING. Medicaid Compliance & Reporting Presented by Joe Kinney and Karen Shoemaker Kinney Management Services, LLC. A Few Issues No One Talks About. What is Going to Happen to the Final Settlement Payments Pitfalls In Cost Reporting

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ASBO SOUTHERN TIER CHAPTER October 22, 2014 MEETING

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  1. ASBO SOUTHERN TIER CHAPTER October 22, 2014 MEETING Medicaid Compliance & Reporting Presented by Joe Kinney and Karen Shoemaker Kinney Management Services, LLC

  2. A Few Issues No One Talks About • What is Going to Happen to the Final Settlement Payments • Pitfalls In Cost Reporting • Who You should be Concerned About • Record Retention • Recap

  3. Claiming Process • Schools are paid a fee for eligible services billed/claimed. These are advances, not final payments. • Throughout the Year Random Moment Time Studies (RMTS) are Conducted for service providers. • Annual Cost report are filed. • State accumulates the allowable cost into one final Medicaid Claim for the Year in question.

  4. Claiming Process - Continued • The Claim is filed with the Federal Government. • The Settlement Payment is Calculated • Total Allowed Cost (cumulative of all cost reports) • Less Advances Already Paid • Equals Net settlement Payment from Federal Government. • Depending on the Year the State Keeps All or Part of the settlement Amount

  5. Settlement Payment DistributionSocial Services Law §   368-d • SFY 4/11 through 3/13 – First $100 million (FS) is kept by State • SFY 4/13 – 3/14 and 4/14-3/15 First $100 million each – total $200 million (FS) • SFY 4/15-3/16 and beyond – 86.5% of all settlements (FS) is Kept by State. Schools get an 13.5% of Settlement Payment. (Note: fund are distributed to schools and counties in proportion to how much they contributed to the total settlement amount.) • Caution • If any county or district owes money back as a result of the settlement, it must be repaid. Repayment is usually done through claims offsets. • If any county or district neglects to file a cost report, all monies must be repaid for all advances received for that year.

  6. Impact on Compliance • The Cost Report is the Final Claim. • Incorrect cost reporting attaches to all filed claims. • The Federal false Claims act is always in play.

  7. Common Cost Reporting Errors • Including costs that are not Medicaid related. • Including staff benefit costs in report that are for more than the eligible staff. • Claiming cost for activity that is actually more than what it is stated to be. • Special Transportation when non-IEP children are also transported on the lift bus. • Including the cost of excluded/debarred parties in cost report – including in indirect cost.

  8. Common Cost Reporting Errors – Continued • Including cost where there is no supporting documentation. • Supporting Documentation must be kept for at least 7 years from the final settlement. Even if your district doesn’t receive a settlement payment. • The service documentation must be kept for the same period and perhaps longer under State Education Law.

  9. Who is Watching You • OMIG - does regular audits. • State Comptroller audits with emphasis on revenue maximization. • Federal OIG audit of State with aim to recover funds – this time you will be in it. • Your own employees, contractors, and parents.

  10. Who is Watching You – Continued • The Federal False Claims Act makes the last group the most dangerous. • They get paid 15 – 25% or more of the proceeds. • Proceeds are the cumulative total of the statute provides that one who is liable must pay a civil penalty of between $5,500 to $11,000 and treble the amount of the government’s damages.

  11. False Claims Act • The knowledge requirement: • A person does not violate the False Claims Act by submitting false claims to the government; to violate the FCA a person must have: • Submitted or caused the submission of a false claim. • Made a false statement or record with knowledge of the falsity.

  12. False Claims Act • The knowledge requirement: • In § 3729(b)(1), knowledge of false information is defined as being • (1) actual knowledge, • (2) deliberate ignorance of the truth or falsity of the information, or • (3) reckless disregard of the truth or falsity of the information. Source - http://www.justice.gov/civil/docs_forms/C-FRAUDS_FCA_Primer.pdf

  13. Record Retention • Not having records for review when requested can be considered a false claim. • Not having complete records and claiming anyway can be considered a false claim.

  14. Recap • Claim all the services your District or County is legitimately entitled to. • Keep all service documentation for at least 7 years from the final settlement – or longer. • Include only allowable costs and if you are not sure, ask the State representatives and PCG and get it in writing.

  15. Questions • Contact information • Karen Shoemaker Kshoemaker@kinneyassoc.com 518-371-0176 Ext. 106 • Joe Kinney jkinney@kinneyassoc.com 518-371-0176 Ext. 101

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