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Invoice Validation Received

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					               SUBSTANCE ABUSE & MENTAL HEALTH
             INVOICE REVIEW OPERATING PROCEDURE
The objective of invoice review is to improve accountability of state funds by providing
reasonable assurances that overpayments and erroneous billings are not occurring with
providers of services.

Purpose and Scope
The purpose of this operating procedure is to provide District/Region contracting staff
with the minimum requirements and procedures for conducting invoice review. This
review is to give the department reasonable assurance that the invoiced service units
billed to the department by the providers have supporting documentation, and are
mathematically correct, in accordance with department rules. Invoice review is to be
conducted on all SAMH model contracts, except for co st reimbursement, Medicaid only,
and Title 21 contracts.

Authority
The primary authority for invoice review includes the following:

   a. Pursuant to section 394.74 (3) (e), F.S., the department may not pay the providers
   unless the required information has been submitted into the department’s data system
   by a date specified in the contract.

   b. Pursuant to 65E-14.021(10) (b) (3), F.A.C., [65E-14.021(4)(b)6.b., F.A.C. ], the
   year-to-date service units reported on a request for payment should be comparable to
   the total number of service units reported and accepted in the department’s data
   systems.
   c. Section 287.057(15), F.S., places the responsibility on the contract manager to
   enforce the performance of the contract terms and conditions; and to ensure that
   contractual services have been rendered.

   d. Section 215.422(1), F.S. requires payment of invoices after receipt, inspection, and
   approval of goods and services.

   e. CFOP 75-2, section 11-4b, the contract manager’s signature on an invoice or
   request for payment attests that the goods and services have been satisfactorily
   provided, and that the expenditures are allowable and in compliance with the terms of
   the contract.

   Definitions
   a. Districts refer to the fourteen (14) geographic service areas and one service region
   of the Department of Children and Families.




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   b. ONE Family SAMH refers to the department’s web-enabled data system for
   substance abuse and mental health in which state-contracted entities (i.e., contractors
   and sub-contractors) report data as specified in the Pamphlet 155-2.

   c. Pamphlet 155-2 refers to Children and Families Pamphlet 155-2 detailing
   department policies and procedures regarding data collection for substance abuse and
   mental health providers.
   d. SAMH refers to the Substance Abuse and Mental Health Program Office.

   e. Unit of Service. A unit of service refers to one unit of measure that is specified for
   a specific cost center, e.g., one contact hour or one direct staff hour. A unit of service
   may consist of multiple service events if the duration of the service event(s) is less
   than the unit of measure.

   f. Discovery Sampling. A sampling used to discover whether the records contain
   critical errors in a providers internal control process. Discovery sampling is designed
   to provide a methodology to test the accuracy of the number of units specified on a
   provider's invoice. Discovery sampling is not intended to give absolute assurance but
   reasonable assurance.

   Roles/Responsibilities
   Accreditation of providers does not preclude the department from performing its
   duties of contract oversight to ensure that payments for services are made in
   accordance with the contract for services, the rules of the department, and applicable
   law. This oversight is considered part of contract managers’ responsibilities and
   should not be considered a substitute for Licensure, Audits, Accreditations, and COU
   monitoring, but rather opportunities for the contract manager to enhance
   communication and verify that providers have provided services identified for
   payment in the invoice.

   Risk Assessment
   Risk assessment is the systematic method for determining the intensity of invoice
   review that is appropriate for each contract. Risk assessment allows the department
   to apply pre-established criteria to all contracts. The invoice review risk assessment
   is based on number of cost centers per contract and additional factors such as total
   dollar amount of the contract, new provider status, and completion of corrective
   action.

   The level of review for each contract is established at the beginning of the each fiscal
   year of the contract or within 15 days of the execution of the contract if during the
   fiscal year. The level of review must be documented in the contract file for each year
   of the contract.




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           Levels of Reviews
           Level I number of cost centers in the contract is 3 or less
           Level II number of cost centers in the contract is 4 through 10
           Level III number of cost centers in the contract is 11 or more

        For the purpose of determining the level of review solely funded Medicaid or
         TANF cost centers are not included in the count of the cost centers. You do count
         each of the cost centers in each program Adult Mental Health, Children Mental
         health, Adult Substance Abuse, and Children Substance abuse.

        The total dollar amount of the contract is based upon the annual state fiscal year.

        If the contract contains three or less cost centers but the contract total dollar
         amount is $500,000 or more it is a level II.

        The contract manager can choose to increase the level of re view. If there are
         noted problems with completion of corrective actions which are related to
         invoice/payments, the contract manager should increase the level of review
         appropriately. The contract manager may not decrease the level of review.

   Type, Frequency, and Sample Size of Review
   Due to volume and limitations of the current system, it is not feasible for contract
   managers to physically validate all units billed on every invoice. The contract
   manager will test the accuracy of the number of units being paid two ways: desk
   reviews and on-site reviews, thus verifying receipt of deliverables before approving
   invoice payment.


               Level I -desk reviews semi annually (twice a year), discovery sample size
               on-site review once every two years (If a contract manager has multiple
               level I contract the on-site review can be staggered)

               Level II -desk reviews quarterly, discovery sample size on-site review
               annually

                Level III -desk reviews monthly, discovery sample size on-site review
               annually

        Level II& III If the provider has a positive on-site review for two years in a row;
         the contract manager may choose to not conduct an on-site review in the
         following year (third year). The contract manager must document this decision in
         the contract file.

        Level II “New” providers will get a monthly desk review for the first year of the
         contract.




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        Discovery sampling will be used for the on-site reviews to verify the number of
         service units within a cost centers unless the discovery sampling produces a high
         error rate. If the error rate is high, the contract manager shall conduct a
         statistically valid sample of the cost center(s) in which the high error rate
         occurred. If the provider agrees that corrective actions is needed and or
         repayment of funds warranted the contract managers may choose not to conduct a
         statistical valid sample and follow through with the corrective action or the
         collection of the repayment of funds.

   Invoice submission
   Supporting documentation for a specific cost center shall be requested from the
   provider by the contract manager through e- mail or phone. The provider shall submit
   the documentation with the invoice in order to provide an audit trail. The contract
   managers will use the support documentation to conduct the invoice desk review and
   the on-site invoice reviews.

    To help expedite receiving the requested supporting documentation the contract
   managers through an e- mail should make the request for the supporting
   documentation for the specific cost center a month prior to the invoice due date. The
   cost center should be selected randomly while taking into consideration the majority
   of dollars in the contract and any past or current corrective actions. This creates a
   responsibility on the provider’s part to link client services, data, invoices, and
   payments, thus protecting both public funds and ensuring the delivery of required
   services.

   When requesting supporting documentation from a provider the contract managers
   Request (e- mail) should:

   1. Contain the name of the program, i.e., Adult Mental Health, Children Mental
   health, Adult Substance Abuse, and Children Substance abuse.

   2. Contain the name of the cost center, listed in Appendix C

   3. Request the provider supporting documentation contain client identifiers, date and
   duration of service and a total numbers of units

   4. Request that the provider separate DCF billed units from Medicaid billed units
   when submitting supporting documentation regarding a particular cost center. All
   providers may not be able to fulfill this request.

The SAMH model HC07 invoice includes client names & SS#. The contract manager
does not need to request the provider to submit additional supporting documentation.

Invoices that bill for TANF services include supporting documentation. The contract
manager does not need to request the provider to submit additional supporting
documentation.



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HC09 model contracts and contracts with cost centers (16) and (17) are required to have
the Invoice Support Report from Kit Solutions Prevention data system attached to the
invoice as supporting documentation each month. The contract manager does not need to
request the provider to submit additional supporting documentation.

The provider can submit various documents that support the delivery of services. They
can submit supporting documentation in the form of a print-out of client identifiers or
they could include a hand written document to support units on the invoice worksheet.

If the contract manager requests a cost center which has hundreds-thousands of service
events in one month the contract manager should obtain the support documentation from
the provider electronically on a computer disc or CD. The disc/CD should be reviewed
by the contract manager placed in an envelope and attached to the invoice.

Invoice Desk Reviews

The contract manager can ensure, by carefully reviewing the invoice and supporting
documentation, that the terms of the contract are met and that the department and the
clients we serve receive the services we are paying for. Prior to approval of payment the
contract manager will verify the invoice by using the desk review worksheet. (Appendix
A). The completed invoice validation desk review worksheet shall be kept in the contract
manager’s file to document the contract manager’s review of the supporting
documentation and invoice.

The contract manager crosschecks the selected service units from the invoice worksheet
to the SAMH database by querying the database using the IDS query facility. For
instructions on conducting the database query refer to Appendix C.

Contract managers will not conduct a desk review on invoices that bill for TANF
services. The TANF specialist conducts the review based upon the SAMH data system
verifying the accuracy of the data on a specific client before it can be app roved for
payment. In addition the participant log is checked to verify client ID and provider ID
within the district as well as cost centers in order to avoid duplicate payments.

 When conducting the desk review on invoices for HC09 model contracts and cost centers
(16) and (17) the contract manager will not have to query the SAMH database, because
the provider is required to submit the Invoice Support Report with their invoice. If the
providers invoice for payment is not submitted with the Invoice Support Report the
contract manager shall notify the provider that the invoice will be returned or that the
portion of the invoice which is for cost center (16) and (17) will not be paid. If after
notification the provider submits the Invoice Support Report the invoice can be processed
for payment. Providers obtain their Invoice Support Report from Kit Solutions database.
Kit Solutions contact person is Jodi-Kiser-Beichner at (888) 600-4777 or at
jbeichner@kitsolutions.net

Advanced Payments: After the initial advance period, the provider will request payment
based on actual units of services delivered up to the prorated share of the budget,
beginning with the first month that was advanced. Invoices for the initial month's


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advances will not require supporting documentation. However, the department and the
Office of the Comptroller reserve the right to request supporting documentation on
particular invoices at any time after expenditures have occurred. The provider's final
invoice which is due 45 days after the contract, must reconcile the actual units, provided
during the contract period with the number of units the department paid.

As the Contract Manager reviewing the invoice and the invoice worksheet you will
determine that:
        The invoice is mathematically correct, complete, and submitted on time as
         defined by the contract.
        The unit rate is the same as that specified in the contract and that date of services
         are within the contract billing period.
        The provider has not billed for more service units than allo wed by the contract or
         for units not in the contract.

        The cost center supporting documentation sent by the provider is reflective of the
         cost center units on the invoice worksheet.

        The provider has reported data to the SAMH database monthly. (query facility)

If no data has been entered in the SAMH database for 3 months or more the contract
manager should request that the provider give a written explanation as to their inability to
enter data. If no data has been entered in the SAMH database for a period of three
months or more with no explanation as to why, the frequency of the desk reviews will
automatically go to monthly for the remainder of the year. If no data is present in the
SAMH database, the first step should be for the provider to verify that they are using the
current year contract number for data entry.
The providers continued failure to enter data into the SAMH database without an
explanation or the failure to submitted supporting documentation can result in the
withholding of payments. The decision to withhold payment will be that of the contract
manager in conjunction with the program supervisor. These instances should be reported
to the Central SAMH Program Office.
        The selected units on the invoice worksheet are reflective of the cost cente r data
         in the SAMH database. (query facility)

If the supporting documentation is not reflective of the SAMH database the contract
manager shall request, preferably through e- mail that the provider coordinate with the
SAMH data liaisons to reconcile the two elements.

        The Non- TANF units on the invoice worksheet are reflective of the SAMH
         database. (query facility)

If a Non-TANF cost center invoice worksheet units are not reflective of the SAMH
database, the next desk review the contract manager shall req uest supporting
documentation for that cost center.


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        If applicable, the interest earned from advances is identified and returned to the
         department on a monthly basis.

If the invoice is disapproved, the contract manager shall return it to the provider wit h an
explanation for the disapproval and request that the provider correct the invoice.

Invoice On-Site Reviews

These visits are considered part of contract management and should not be considered
monitoring visits, but rather opportunities for the contract manager to enhance
communication and verify SAMH providers are complying with the terms and conditions
of the contract and providing services identified for payment in the invoice. These visits
should promote open communication between the contract manager and providers. Visits
should be viewed as opportunities for learning and exchanging information.

Site visits are scheduled visits to the provider. When contract managers conduct onsite
reviews they interview provider staff to ascertain their unde rstanding of program goals,
interview clients about services received, review client case records, review provider
records, and observe operations. The results of these visits should be documented.

              While on site contract managers may:
               Interview provider staff
               Observe service delivery sites
               Verify service delivery in client files or provider records
               Talk to clients about service quality

Cost Centers, units of measure, and the service documentation requirements are related
on a one-to-one basis. In other words, for every cost center there is one unit of measure
and a required set of source documents. Each unit of service must be documented so that
it provides a clear and distinguishable audit trail. At a minimum, this must include a
handwritten or automated source document. Examples of source documents: service
tickets, census log, time sheet, and duty roster. Each provider agency may develop or
modify their source documentation forms. Rule 65-E14, FAC Cost Center Service
Descriptions and Models specifies the documentation requirements for each service cost
center. It is also included in Appendix B.

Pre-site visit preparation

Select the service period to be reviewed, e.g. a specific month, then choose a cost center/s
by program area to be reviewed specifically, one that resulted in areas that needed
correction during the desk review.

Notify the provider by telephone or in writing of the dates that the on-site review will be
done and the cost centers and programs that will be sampled. The contract manager shall
request documentation of service records, timesheets, time logs, etc to be made available
for on site review.


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The contract manager shall select a sample for review based upon the number of
projected service units within a specific program cost center contracted for within the
fiscal year. (The number of projected cost center units must be obtained during
negotiations and contained in the memorandum of negotiation) See chart below. This is
what you will start with for the review, but you may need to expand your review if errors
are noted. For errors, you will need to use judgment about the type of errors.

A minimum of five (5) client files or the actual number served if less, for direct services
units must be reviewed during the on-site review. There is no minimum for non-direct
service units. For HC07 model contracts a minimum of five (5) client files or the actual
number served if less, must be reviewed for the month.

FOR EACH DIRECT COST CENTER IDENTIFIED FOR REVIEW
  Number of Units within a Specific               Unit Sample Size
         Program Cost Cente r
1-1000                                                    10
1001 to 5000                                              20
5001 to 10,000                                            40
10,001 and up                                             60

You may use a judgmental sample or a random sample. The following website can be
used to select a non statistical random sample. http://randomizer.org/

The service units will be verified by sampling unless the sampling produces a high error
rate. If the error rate is high, the contract manager shall conduct a statistically valid
sample of the cost center(s) in which the high error rate occurred.

To conduct a statistically valid sample of the cost center(s), you will need to select a
sample to review using the Random Sample Calculator. The calculator is located at:
http://ewas.dcf.state.fl.us/asc/monitoring/calc.asp

Using the calculator, select a 90% confidence level and a 15% confidence interval. Next
you must type in your population size

   The screen will now display your sample size as shown below.

                    Random Number Table for Population Size
                                    50
                          Confidence Level 90, Confidence Interval 15
                                       Sample Size 19
                          1    2    3   4    5     6    7     8     9    10


                    0    18    50   47   3   32      48   2    1    19   36
                    10    5    41   17   8   9       28   10   22   35




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Conducting the On-Site Review

For contracts involving the provision of direct client services, the contract manager shall
periodically, at a minimum annually, visit the physical location where the services are
delivered and speak directly to clients receiving the services and the staff responsible for
delivering the services. The contract manager should use the client & provider interviews
worksheets to conduct the interviews.

On site reviews for invoiced TANF funds are conducted by TANF specialist. The
contract manager is not required to conduct an on-site review of TANF funds.

The contract manager should start with the supporting documentation which was
submitted with the invoice and work backwards through the detailed information to the
source documentation. The contract manager should not accept summary of the
information drawn from the source information but insist on seeing the document that
initiated the transaction. From the sample, verify whether required source documentation
such as time sheets, vendor receipts, and treatment records and individual actually
performing the service. (van driver, therapist, trainer, etc) are available at the provider
site. Review the source documents to identify the individual service provided. For
example, you should be able to tie together a therapist’s notes about clients with time
sheets that show the therapist was in the office on the day that the clients were seen. The
contract manager should utilize on-site review worksheets (See Appendix B) to compare
actual service records with units billed.

The contract manager shall conduct an exit interview with the provider’s primary point of
contact in order to report on general results of the on-site invoice review. Contract
managers shall discuss likely findings with the provider during the exit interview. They
should also use this meeting to ask questions or request explanations of the preliminary
findings. The exit interview allows the provider an opportunity to explain or provide
documentation to clear up minor or easily correctable errors.

The contract manager is responsible for preparing the invoice review summary report and
providing a copy to the provider. The summary report shall be used by the contract
manager to communicate any deficiencies and the request for the provider to take
corrective action.

The on-site requirement portion of the invoice review can be satisfied by the contract
manager completing the Contract Oversight Unit (Monitor) Form (Appendix D) and
providing it to the contract monitor (COU). This can only occur in conjunction with the
COU’s scheduled monitoring of a provider.

 For example, if a mental health provider gets monitored every three years then two of the
three years the contract manager is required to conduct the on-site invoice review. If a
providers contract includes both substance abuse and mental health services which
contain substance abuse block grant funds the substance abuse portion of the contract will
be monitored every year by the COU. The contract manager is required to conduct t he
on-site invoice review for the mental health portion of the contract. In this situation it is
recommended that you coordinate the date and time of your on-site invoice review of the


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mental health portion with the COU monitoring the substance abuse portion to minimize
the number of times a provider has to prepare and participate in a review process.
Contract managers should form working relationships with district/region/zone
monitoring staff (COU) which will allow for open exchanges of relevant information
including monitoring report findings. In addition, contract managers should work with
COU staff to assess repeat findings and follow up on provider corrective action plan.

Corrective Actions
At any level of the invoice review process the contract manager could identify an area of
concern that may require corrective actions. The following is guidance on how to
address the concerns with corrective actions.
If the contract manager finds irregularities in any stage of the invoice review process that
require immediate attention or action or indicate questionable financial and managerial
practices, he or she shall immediately report these to their supervisor
Desk Review: When a provider has not met data submission requirements for three
consecutive months and has not provided a written explanation or has continued to not
submitted supporting documentation with their invoice they must be placed on a formal
corrective action plan. Depending on the presenting issue, payment may be reduced or
withheld.
On-Site Review: The contract manager will provide a copy of the invoice review report
to the provider which will contain the area/s of concern. Then the contract manager will
request from the provider a written response to the concerns which will address what
corrective actions the provider will take and the timeframe in which they will be
completed. If a provider has not or is not completing the activities of the corrective
action plan in full and on time, payment may be reduced or withheld. Refer to CFPO 75-
2 Section 11-6 Financial Penalties for a Provider’s Failure to Comply with Requirements
for Corrective Actions.

If a deadline is missed or corrective action is otherwise not completed, the contract
manager should follow up in writing immediately. Notify the provider that a deadline
has been missed and ask the provider when the action will be completed. Advise the
provider that failure to comply with the corrective action plan could lead to termination
of the agreement. If the corrective action is successful in resolving problems, notify the
provider in writing that resolution has been achieved. Remember to document these
actions in the contract file.

Payback of Payment
Paragraph I. J. Return of Funds, of the Florida Department of Children and Families
Standard Contract, requires the following action by the provider in the case of any
overpayment by the department:

To return to the department any overpayments due to unearned funds or funds disallowed
pursuant to the terms and conditions of this contract that were disbursed to the provider
by the department. In the event that the provider or its independent auditor discovers that



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an overpayment has been made, the provider shall repay said overpayment immediately
without prior notification from the
department. In the event that the department first discovers an overpayment has been
made, the contract manager, on behalf of the department, will notify the provider by letter
of such findings. Should repayment not be made forthwith, the provider will be charged
at the lawful rate of interest on the outstanding balance after department notification or
provider discovery.

Although the Standard Contract requires immediate recoupment of an overpayment, in
exceptional or unusual circumstances, it is possible to amend the contract in writing to
allow the provider to repay over time. The contract manager shall first seek immediate
repayment in all instances. In the event that the provider cannot make immediate
repayment in full to the department, upon discovery by the provider or the department of
an overpayment, the provider may propose a repayment plan. It is the responsibility of
the contract manager to ensure that any proposed plan for recoupment of funds (other
than direct and immediate reimbursement) has prior approval by the Department of
Financial Services (DFS) before implementation, in accordance with the provisions of
section 17.03, Florida Statutes.

The proposed plan may involve the provision of additional services that are valued at the
contracted rate, a schedule of payments or other repayment method which are agreed
upon by the department and the provider. The provider will be charged at the lawful rate
of interest on the outstanding balance on any approved plan for repayment.

Per CDA 05-08 the written details of the intended payback plan shall be submitted by the
contract manager to the District/Region legal office and the District Administrator (DA)
for approval. After approval by the DA, the repayment plan will be sent through the
Administrative Services Support Center (ASSC) for review and forwarding to the
department's Comptroller. The department's Comptroller will review the plan and, if
approved, forward it to the Department of Financial Services, Bureau of Auditing, for
final approval, at the following address:

In addition to CDA 05-08 the SAMH program office SAMH PD 05-02 emphasize that
the department does not have authority to approve paybacks from providers EXCEPT in
those situations in which the provider makes immediate 100% cash payment or 100% of
the payback is recouped via a reduction in the next month’s billing invoice.

For purposes of repayment, it is not acceptable to adjust unit or utilize excess units. This
is NOT a 100% payback if the units were not contracted for (if they were, then a payback
situation would not have been determined). The only consideration is adjusting the dollar
amount owed to the provider.

The providers’ payback plan shall include a corrective action statement addressing how
the circumstances that led to the payback situation will be remedied. The district shall
also include a statement outlining the action that the district will take to ensure that the
proposed repayment plan will be executed as proposed and how the district will ensure
that circumstances that led to the payback will be remedied.



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 Withhold or Reduce Payment: If a provider is determined to be out of compliance
with the terms of the contract the department may reduce the advancement or withhold
payment.. The department's decision to reduce or withhold funds shall be in writing and
submitted to all involved parties. The written notice will specify the manner and extent
to which the provider has failed to comply with the terms of the contract. When the
situation identified as problematic is corrected, payment may be reinstated to the
provider.




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