vendor audit: i can too learning center, llc - dds.ca.gov · department of developmental services...
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DEPARTMENT
OF
DEVELOPMENTAL SERVICES
AUDIT
OF
I CAN TOO LEARNING CENTER LLC
Programs and Services Infant Development Program ndash HS0468 HS0698
ClientParent Support Behavior Intervention Training ndash PS0044
Audit Period July 1 2011 through June 30 2012
Audit Branch
Auditors Michael Masui Chief of Vendor Audits Alton Kitay Supervisor Aaron Lomanto Lead Auditor Pardeep Deol Auditor
I CAN TOO LEARNING CENTER LLC
TABLE OF CONTENTS
Page(s)
Executive Summary 1
Background 2
Objective Scope and Methodology 2-3
Conclusion 4
Views of Responsible Officials4
Restricted Use 4
Findings and Recommendations 5-7
Attachment A-Summary of Unsupported Billings amp Failure to Bill 8-10
Attachment B-Unsupported Billings amp Failure to Bill Adjustments 11-13
Attachment C-Response from Vendor 14-15
Attachment D-Evaluation of Vendor Response 16-17
ii
EXECUTIVE SUMMARY
The Department of Developmental Services (DDS) has audited I Can Too Learning Center LLC (ICT) The audit was performed upon the Infant Development Program and ClientParent Support Behavior Intervention Training for the period of July 1 2011 through June 30 2012
The results of the audit disclosed the following issues of non-compliance
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill the San Andreas Regional Center (SARC) As a result ICT had a total of $49891433 of unsupported billings and a total of $18144562 for which it failed to bill
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill the Regional Center of the East Bay (RCEB) As a result ICT had a total of $12412595 of unsupported billings and a total of $2899726 for which it failed to bill
The total unsupported billing discrepancies identified in this audit amounts to $41259740 and is due back to DDS A detailed discussion of these findings is contained in the Findings and Recommendations section of this report
1
BACKGROUND
DDS is responsible under the Lanterman Developmental Disabilities Services Act for ensuring that persons with developmental disabilities receive the services and supports they need to lead more independent productive and normal lives DDS contracts with 21 private nonprofit regional centers that provide fixed points of contact in the community for serving eligible individuals with developmental disabilities and their families in California In order for regional centers to fulfill their objectives they secure services and supports from qualified service providers andor contractors Pursuant to the Welfare and Institutions (WampI) Code section 46481 DDS has the authority to audit those service providers andor contractors that provide services and supports to persons with developmental disabilities
OBJECTIVE SCOPE AND METHODOLOGY
The audit was conducted to determine whether ICTrsquos Infant Development Program and ClientParent Support Behavior Intervention Training were compliant with the WampI Code California Code of Regulations Title 17 (CCR title 17) and the regional center contracts with ICT for the period of July 1 2011 through June 30 2012
ICT was vendorized by SARC and provided services to RCEB and Golden Gate Regional Center (GGRC) Audit staff reviewed the programs and services provided to SARC and RCEB
The audit was conducted in accordance with the Generally Accepted Government Auditing Standards (GAGAS) issued by the Comptroller General of the United States The auditors did not review the financial statements of ICT nor was this audit intended to express an opinion on the financial statements The auditors limited the review of ICTrsquos internal controls to gain an understanding of the transaction flow and invoice preparation process as necessary to develop appropriate auditing procedures The audit scope was limited to planning and performing audit procedures necessary to obtain reasonable assurance that ICT complied with CCR title 17 Also any complaints that DDSrsquo Audit Branch was aware of regarding noncompliance of laws and regulations were reviewed and followed-up during the course of the audit
Day Programs
During the audit period ICT operated eight Day Programs The audit included the review of two of ICTrsquos Day Programs Testing was done during the period of July 1 2011 through June 30 2012 The programs audited are listed below
bull Infant Development Program Vendor Numbers HS0468 and HS0698 Service Code 805
The procedures performed at SARC the vendoring regional center and ICT included but were not limited to the following
bull Review of SARCrsquos vendor files for contracts rate letters program designs purchase of service authorizations and correspondence pertinent to the review
2
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for SARC billings
bull Review of ICTrsquos serviceattendance records to determine if ICT had sufficient and appropriate evidence to support the direct care services billed to SARC
ClientParent Support Behavior Intervention Training
During the audit period ICT operated one ClientParent Support Behavior Intervention Training The audit included the review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 Service Code 048 Testing was done during the period of July 1 2011 through June 30 2012
The procedures performed at SARC the vendoring regional center and ICT included but were not limited to the following
bull Review of SARCrsquos vendor files for contracts rate letters program designs purchase of service authorizations and correspondence pertinent to the review
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for RCEB billings
bull Review of ICTrsquos serviceattendance records to determine if ICT has sufficient and appropriate evidence to support the direct care services billed to RCEB
3
CONCLUSION
Based upon items identified in the Findings and Recommendations section ICT did not comply with the requirements of CCR title 17
VIEWS OF RESPONSIBLE OFFICIALS
DDS issued a draft audit report on February 11 2014 The findings in the report were discussed at a formal exit conference with Lani Fritts ICTrsquos Managing Director on February 19 2014 Subsequent to the meeting Mr Fritts responded on March 17 2014 that ICT would submit documents to support additional hours of service
RESTRICTED USE
This report is solely for the information and use of DDS Department of Health Care Services SARC RCEB and ICT This restriction is not intended to limit distribution of this report which is a matter of public record
4
FINDINGS AND RECOMMENDATIONS
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to SARC
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to SARC The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill SARC The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 565837 hours of services billed for Vendor Number HS0468 and 131950 hours of services billed for Vendor Number HS0698 The lack of documentation resulted in unsupported billings to SARC in the amount of $42415143 for Vendor Number HS0468 and $7476290 for Vendor Number HS0698 The total unsupported billings amounted to $49891433
In addition ICT provided appropriate supporting documentation for 219286 hours of service for Vendor Number HS0468 and 30125 hours of service for Vendor Number HS0698 but was not billed to SARC This resulted in an unbilled amount of $16437676 for Vendor Number HS0468 and $1706886 for Vendor Number HS0698 The total failure to bill amounted to $18144562
As a result $31746871 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
5
Recommendation ICT must reimburse to DDS the $31746871 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to SARC
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to RCEB
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to RCEB The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill RCEB The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 250128 hours of services billed The lack of documentation resulted in unsupported billings to RCEB in the amount of $12412595
In addition ICT provided appropriate supporting documentation for 69693 hours of service but was not billed to RCEB This resulted in an unbilled amount of $2899726
As a result $9512869 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
6
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
Recommendation ICT must reimburse to DDS the $9512869 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to RCEB
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
7
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
I CAN TOO LEARNING CENTER LLC
TABLE OF CONTENTS
Page(s)
Executive Summary 1
Background 2
Objective Scope and Methodology 2-3
Conclusion 4
Views of Responsible Officials4
Restricted Use 4
Findings and Recommendations 5-7
Attachment A-Summary of Unsupported Billings amp Failure to Bill 8-10
Attachment B-Unsupported Billings amp Failure to Bill Adjustments 11-13
Attachment C-Response from Vendor 14-15
Attachment D-Evaluation of Vendor Response 16-17
ii
EXECUTIVE SUMMARY
The Department of Developmental Services (DDS) has audited I Can Too Learning Center LLC (ICT) The audit was performed upon the Infant Development Program and ClientParent Support Behavior Intervention Training for the period of July 1 2011 through June 30 2012
The results of the audit disclosed the following issues of non-compliance
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill the San Andreas Regional Center (SARC) As a result ICT had a total of $49891433 of unsupported billings and a total of $18144562 for which it failed to bill
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill the Regional Center of the East Bay (RCEB) As a result ICT had a total of $12412595 of unsupported billings and a total of $2899726 for which it failed to bill
The total unsupported billing discrepancies identified in this audit amounts to $41259740 and is due back to DDS A detailed discussion of these findings is contained in the Findings and Recommendations section of this report
1
BACKGROUND
DDS is responsible under the Lanterman Developmental Disabilities Services Act for ensuring that persons with developmental disabilities receive the services and supports they need to lead more independent productive and normal lives DDS contracts with 21 private nonprofit regional centers that provide fixed points of contact in the community for serving eligible individuals with developmental disabilities and their families in California In order for regional centers to fulfill their objectives they secure services and supports from qualified service providers andor contractors Pursuant to the Welfare and Institutions (WampI) Code section 46481 DDS has the authority to audit those service providers andor contractors that provide services and supports to persons with developmental disabilities
OBJECTIVE SCOPE AND METHODOLOGY
The audit was conducted to determine whether ICTrsquos Infant Development Program and ClientParent Support Behavior Intervention Training were compliant with the WampI Code California Code of Regulations Title 17 (CCR title 17) and the regional center contracts with ICT for the period of July 1 2011 through June 30 2012
ICT was vendorized by SARC and provided services to RCEB and Golden Gate Regional Center (GGRC) Audit staff reviewed the programs and services provided to SARC and RCEB
The audit was conducted in accordance with the Generally Accepted Government Auditing Standards (GAGAS) issued by the Comptroller General of the United States The auditors did not review the financial statements of ICT nor was this audit intended to express an opinion on the financial statements The auditors limited the review of ICTrsquos internal controls to gain an understanding of the transaction flow and invoice preparation process as necessary to develop appropriate auditing procedures The audit scope was limited to planning and performing audit procedures necessary to obtain reasonable assurance that ICT complied with CCR title 17 Also any complaints that DDSrsquo Audit Branch was aware of regarding noncompliance of laws and regulations were reviewed and followed-up during the course of the audit
Day Programs
During the audit period ICT operated eight Day Programs The audit included the review of two of ICTrsquos Day Programs Testing was done during the period of July 1 2011 through June 30 2012 The programs audited are listed below
bull Infant Development Program Vendor Numbers HS0468 and HS0698 Service Code 805
The procedures performed at SARC the vendoring regional center and ICT included but were not limited to the following
bull Review of SARCrsquos vendor files for contracts rate letters program designs purchase of service authorizations and correspondence pertinent to the review
2
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for SARC billings
bull Review of ICTrsquos serviceattendance records to determine if ICT had sufficient and appropriate evidence to support the direct care services billed to SARC
ClientParent Support Behavior Intervention Training
During the audit period ICT operated one ClientParent Support Behavior Intervention Training The audit included the review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 Service Code 048 Testing was done during the period of July 1 2011 through June 30 2012
The procedures performed at SARC the vendoring regional center and ICT included but were not limited to the following
bull Review of SARCrsquos vendor files for contracts rate letters program designs purchase of service authorizations and correspondence pertinent to the review
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for RCEB billings
bull Review of ICTrsquos serviceattendance records to determine if ICT has sufficient and appropriate evidence to support the direct care services billed to RCEB
3
CONCLUSION
Based upon items identified in the Findings and Recommendations section ICT did not comply with the requirements of CCR title 17
VIEWS OF RESPONSIBLE OFFICIALS
DDS issued a draft audit report on February 11 2014 The findings in the report were discussed at a formal exit conference with Lani Fritts ICTrsquos Managing Director on February 19 2014 Subsequent to the meeting Mr Fritts responded on March 17 2014 that ICT would submit documents to support additional hours of service
RESTRICTED USE
This report is solely for the information and use of DDS Department of Health Care Services SARC RCEB and ICT This restriction is not intended to limit distribution of this report which is a matter of public record
4
FINDINGS AND RECOMMENDATIONS
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to SARC
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to SARC The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill SARC The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 565837 hours of services billed for Vendor Number HS0468 and 131950 hours of services billed for Vendor Number HS0698 The lack of documentation resulted in unsupported billings to SARC in the amount of $42415143 for Vendor Number HS0468 and $7476290 for Vendor Number HS0698 The total unsupported billings amounted to $49891433
In addition ICT provided appropriate supporting documentation for 219286 hours of service for Vendor Number HS0468 and 30125 hours of service for Vendor Number HS0698 but was not billed to SARC This resulted in an unbilled amount of $16437676 for Vendor Number HS0468 and $1706886 for Vendor Number HS0698 The total failure to bill amounted to $18144562
As a result $31746871 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
5
Recommendation ICT must reimburse to DDS the $31746871 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to SARC
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to RCEB
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to RCEB The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill RCEB The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 250128 hours of services billed The lack of documentation resulted in unsupported billings to RCEB in the amount of $12412595
In addition ICT provided appropriate supporting documentation for 69693 hours of service but was not billed to RCEB This resulted in an unbilled amount of $2899726
As a result $9512869 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
6
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
Recommendation ICT must reimburse to DDS the $9512869 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to RCEB
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
7
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
EXECUTIVE SUMMARY
The Department of Developmental Services (DDS) has audited I Can Too Learning Center LLC (ICT) The audit was performed upon the Infant Development Program and ClientParent Support Behavior Intervention Training for the period of July 1 2011 through June 30 2012
The results of the audit disclosed the following issues of non-compliance
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill the San Andreas Regional Center (SARC) As a result ICT had a total of $49891433 of unsupported billings and a total of $18144562 for which it failed to bill
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill the Regional Center of the East Bay (RCEB) As a result ICT had a total of $12412595 of unsupported billings and a total of $2899726 for which it failed to bill
The total unsupported billing discrepancies identified in this audit amounts to $41259740 and is due back to DDS A detailed discussion of these findings is contained in the Findings and Recommendations section of this report
1
BACKGROUND
DDS is responsible under the Lanterman Developmental Disabilities Services Act for ensuring that persons with developmental disabilities receive the services and supports they need to lead more independent productive and normal lives DDS contracts with 21 private nonprofit regional centers that provide fixed points of contact in the community for serving eligible individuals with developmental disabilities and their families in California In order for regional centers to fulfill their objectives they secure services and supports from qualified service providers andor contractors Pursuant to the Welfare and Institutions (WampI) Code section 46481 DDS has the authority to audit those service providers andor contractors that provide services and supports to persons with developmental disabilities
OBJECTIVE SCOPE AND METHODOLOGY
The audit was conducted to determine whether ICTrsquos Infant Development Program and ClientParent Support Behavior Intervention Training were compliant with the WampI Code California Code of Regulations Title 17 (CCR title 17) and the regional center contracts with ICT for the period of July 1 2011 through June 30 2012
ICT was vendorized by SARC and provided services to RCEB and Golden Gate Regional Center (GGRC) Audit staff reviewed the programs and services provided to SARC and RCEB
The audit was conducted in accordance with the Generally Accepted Government Auditing Standards (GAGAS) issued by the Comptroller General of the United States The auditors did not review the financial statements of ICT nor was this audit intended to express an opinion on the financial statements The auditors limited the review of ICTrsquos internal controls to gain an understanding of the transaction flow and invoice preparation process as necessary to develop appropriate auditing procedures The audit scope was limited to planning and performing audit procedures necessary to obtain reasonable assurance that ICT complied with CCR title 17 Also any complaints that DDSrsquo Audit Branch was aware of regarding noncompliance of laws and regulations were reviewed and followed-up during the course of the audit
Day Programs
During the audit period ICT operated eight Day Programs The audit included the review of two of ICTrsquos Day Programs Testing was done during the period of July 1 2011 through June 30 2012 The programs audited are listed below
bull Infant Development Program Vendor Numbers HS0468 and HS0698 Service Code 805
The procedures performed at SARC the vendoring regional center and ICT included but were not limited to the following
bull Review of SARCrsquos vendor files for contracts rate letters program designs purchase of service authorizations and correspondence pertinent to the review
2
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for SARC billings
bull Review of ICTrsquos serviceattendance records to determine if ICT had sufficient and appropriate evidence to support the direct care services billed to SARC
ClientParent Support Behavior Intervention Training
During the audit period ICT operated one ClientParent Support Behavior Intervention Training The audit included the review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 Service Code 048 Testing was done during the period of July 1 2011 through June 30 2012
The procedures performed at SARC the vendoring regional center and ICT included but were not limited to the following
bull Review of SARCrsquos vendor files for contracts rate letters program designs purchase of service authorizations and correspondence pertinent to the review
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for RCEB billings
bull Review of ICTrsquos serviceattendance records to determine if ICT has sufficient and appropriate evidence to support the direct care services billed to RCEB
3
CONCLUSION
Based upon items identified in the Findings and Recommendations section ICT did not comply with the requirements of CCR title 17
VIEWS OF RESPONSIBLE OFFICIALS
DDS issued a draft audit report on February 11 2014 The findings in the report were discussed at a formal exit conference with Lani Fritts ICTrsquos Managing Director on February 19 2014 Subsequent to the meeting Mr Fritts responded on March 17 2014 that ICT would submit documents to support additional hours of service
RESTRICTED USE
This report is solely for the information and use of DDS Department of Health Care Services SARC RCEB and ICT This restriction is not intended to limit distribution of this report which is a matter of public record
4
FINDINGS AND RECOMMENDATIONS
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to SARC
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to SARC The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill SARC The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 565837 hours of services billed for Vendor Number HS0468 and 131950 hours of services billed for Vendor Number HS0698 The lack of documentation resulted in unsupported billings to SARC in the amount of $42415143 for Vendor Number HS0468 and $7476290 for Vendor Number HS0698 The total unsupported billings amounted to $49891433
In addition ICT provided appropriate supporting documentation for 219286 hours of service for Vendor Number HS0468 and 30125 hours of service for Vendor Number HS0698 but was not billed to SARC This resulted in an unbilled amount of $16437676 for Vendor Number HS0468 and $1706886 for Vendor Number HS0698 The total failure to bill amounted to $18144562
As a result $31746871 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
5
Recommendation ICT must reimburse to DDS the $31746871 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to SARC
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to RCEB
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to RCEB The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill RCEB The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 250128 hours of services billed The lack of documentation resulted in unsupported billings to RCEB in the amount of $12412595
In addition ICT provided appropriate supporting documentation for 69693 hours of service but was not billed to RCEB This resulted in an unbilled amount of $2899726
As a result $9512869 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
6
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
Recommendation ICT must reimburse to DDS the $9512869 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to RCEB
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
7
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
BACKGROUND
DDS is responsible under the Lanterman Developmental Disabilities Services Act for ensuring that persons with developmental disabilities receive the services and supports they need to lead more independent productive and normal lives DDS contracts with 21 private nonprofit regional centers that provide fixed points of contact in the community for serving eligible individuals with developmental disabilities and their families in California In order for regional centers to fulfill their objectives they secure services and supports from qualified service providers andor contractors Pursuant to the Welfare and Institutions (WampI) Code section 46481 DDS has the authority to audit those service providers andor contractors that provide services and supports to persons with developmental disabilities
OBJECTIVE SCOPE AND METHODOLOGY
The audit was conducted to determine whether ICTrsquos Infant Development Program and ClientParent Support Behavior Intervention Training were compliant with the WampI Code California Code of Regulations Title 17 (CCR title 17) and the regional center contracts with ICT for the period of July 1 2011 through June 30 2012
ICT was vendorized by SARC and provided services to RCEB and Golden Gate Regional Center (GGRC) Audit staff reviewed the programs and services provided to SARC and RCEB
The audit was conducted in accordance with the Generally Accepted Government Auditing Standards (GAGAS) issued by the Comptroller General of the United States The auditors did not review the financial statements of ICT nor was this audit intended to express an opinion on the financial statements The auditors limited the review of ICTrsquos internal controls to gain an understanding of the transaction flow and invoice preparation process as necessary to develop appropriate auditing procedures The audit scope was limited to planning and performing audit procedures necessary to obtain reasonable assurance that ICT complied with CCR title 17 Also any complaints that DDSrsquo Audit Branch was aware of regarding noncompliance of laws and regulations were reviewed and followed-up during the course of the audit
Day Programs
During the audit period ICT operated eight Day Programs The audit included the review of two of ICTrsquos Day Programs Testing was done during the period of July 1 2011 through June 30 2012 The programs audited are listed below
bull Infant Development Program Vendor Numbers HS0468 and HS0698 Service Code 805
The procedures performed at SARC the vendoring regional center and ICT included but were not limited to the following
bull Review of SARCrsquos vendor files for contracts rate letters program designs purchase of service authorizations and correspondence pertinent to the review
2
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for SARC billings
bull Review of ICTrsquos serviceattendance records to determine if ICT had sufficient and appropriate evidence to support the direct care services billed to SARC
ClientParent Support Behavior Intervention Training
During the audit period ICT operated one ClientParent Support Behavior Intervention Training The audit included the review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 Service Code 048 Testing was done during the period of July 1 2011 through June 30 2012
The procedures performed at SARC the vendoring regional center and ICT included but were not limited to the following
bull Review of SARCrsquos vendor files for contracts rate letters program designs purchase of service authorizations and correspondence pertinent to the review
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for RCEB billings
bull Review of ICTrsquos serviceattendance records to determine if ICT has sufficient and appropriate evidence to support the direct care services billed to RCEB
3
CONCLUSION
Based upon items identified in the Findings and Recommendations section ICT did not comply with the requirements of CCR title 17
VIEWS OF RESPONSIBLE OFFICIALS
DDS issued a draft audit report on February 11 2014 The findings in the report were discussed at a formal exit conference with Lani Fritts ICTrsquos Managing Director on February 19 2014 Subsequent to the meeting Mr Fritts responded on March 17 2014 that ICT would submit documents to support additional hours of service
RESTRICTED USE
This report is solely for the information and use of DDS Department of Health Care Services SARC RCEB and ICT This restriction is not intended to limit distribution of this report which is a matter of public record
4
FINDINGS AND RECOMMENDATIONS
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to SARC
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to SARC The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill SARC The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 565837 hours of services billed for Vendor Number HS0468 and 131950 hours of services billed for Vendor Number HS0698 The lack of documentation resulted in unsupported billings to SARC in the amount of $42415143 for Vendor Number HS0468 and $7476290 for Vendor Number HS0698 The total unsupported billings amounted to $49891433
In addition ICT provided appropriate supporting documentation for 219286 hours of service for Vendor Number HS0468 and 30125 hours of service for Vendor Number HS0698 but was not billed to SARC This resulted in an unbilled amount of $16437676 for Vendor Number HS0468 and $1706886 for Vendor Number HS0698 The total failure to bill amounted to $18144562
As a result $31746871 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
5
Recommendation ICT must reimburse to DDS the $31746871 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to SARC
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to RCEB
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to RCEB The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill RCEB The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 250128 hours of services billed The lack of documentation resulted in unsupported billings to RCEB in the amount of $12412595
In addition ICT provided appropriate supporting documentation for 69693 hours of service but was not billed to RCEB This resulted in an unbilled amount of $2899726
As a result $9512869 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
6
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
Recommendation ICT must reimburse to DDS the $9512869 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to RCEB
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
7
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for SARC billings
bull Review of ICTrsquos serviceattendance records to determine if ICT had sufficient and appropriate evidence to support the direct care services billed to SARC
ClientParent Support Behavior Intervention Training
During the audit period ICT operated one ClientParent Support Behavior Intervention Training The audit included the review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 Service Code 048 Testing was done during the period of July 1 2011 through June 30 2012
The procedures performed at SARC the vendoring regional center and ICT included but were not limited to the following
bull Review of SARCrsquos vendor files for contracts rate letters program designs purchase of service authorizations and correspondence pertinent to the review
bull Interview of SARCrsquos staff for vendor background information and to obtain prior vendor audit reports
bull Interview of ICTrsquos staff and management to gain an understanding of its accounting procedures and processes for RCEB billings
bull Review of ICTrsquos serviceattendance records to determine if ICT has sufficient and appropriate evidence to support the direct care services billed to RCEB
3
CONCLUSION
Based upon items identified in the Findings and Recommendations section ICT did not comply with the requirements of CCR title 17
VIEWS OF RESPONSIBLE OFFICIALS
DDS issued a draft audit report on February 11 2014 The findings in the report were discussed at a formal exit conference with Lani Fritts ICTrsquos Managing Director on February 19 2014 Subsequent to the meeting Mr Fritts responded on March 17 2014 that ICT would submit documents to support additional hours of service
RESTRICTED USE
This report is solely for the information and use of DDS Department of Health Care Services SARC RCEB and ICT This restriction is not intended to limit distribution of this report which is a matter of public record
4
FINDINGS AND RECOMMENDATIONS
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to SARC
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to SARC The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill SARC The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 565837 hours of services billed for Vendor Number HS0468 and 131950 hours of services billed for Vendor Number HS0698 The lack of documentation resulted in unsupported billings to SARC in the amount of $42415143 for Vendor Number HS0468 and $7476290 for Vendor Number HS0698 The total unsupported billings amounted to $49891433
In addition ICT provided appropriate supporting documentation for 219286 hours of service for Vendor Number HS0468 and 30125 hours of service for Vendor Number HS0698 but was not billed to SARC This resulted in an unbilled amount of $16437676 for Vendor Number HS0468 and $1706886 for Vendor Number HS0698 The total failure to bill amounted to $18144562
As a result $31746871 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
5
Recommendation ICT must reimburse to DDS the $31746871 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to SARC
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to RCEB
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to RCEB The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill RCEB The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 250128 hours of services billed The lack of documentation resulted in unsupported billings to RCEB in the amount of $12412595
In addition ICT provided appropriate supporting documentation for 69693 hours of service but was not billed to RCEB This resulted in an unbilled amount of $2899726
As a result $9512869 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
6
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
Recommendation ICT must reimburse to DDS the $9512869 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to RCEB
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
7
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
CONCLUSION
Based upon items identified in the Findings and Recommendations section ICT did not comply with the requirements of CCR title 17
VIEWS OF RESPONSIBLE OFFICIALS
DDS issued a draft audit report on February 11 2014 The findings in the report were discussed at a formal exit conference with Lani Fritts ICTrsquos Managing Director on February 19 2014 Subsequent to the meeting Mr Fritts responded on March 17 2014 that ICT would submit documents to support additional hours of service
RESTRICTED USE
This report is solely for the information and use of DDS Department of Health Care Services SARC RCEB and ICT This restriction is not intended to limit distribution of this report which is a matter of public record
4
FINDINGS AND RECOMMENDATIONS
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to SARC
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to SARC The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill SARC The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 565837 hours of services billed for Vendor Number HS0468 and 131950 hours of services billed for Vendor Number HS0698 The lack of documentation resulted in unsupported billings to SARC in the amount of $42415143 for Vendor Number HS0468 and $7476290 for Vendor Number HS0698 The total unsupported billings amounted to $49891433
In addition ICT provided appropriate supporting documentation for 219286 hours of service for Vendor Number HS0468 and 30125 hours of service for Vendor Number HS0698 but was not billed to SARC This resulted in an unbilled amount of $16437676 for Vendor Number HS0468 and $1706886 for Vendor Number HS0698 The total failure to bill amounted to $18144562
As a result $31746871 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
5
Recommendation ICT must reimburse to DDS the $31746871 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to SARC
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to RCEB
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to RCEB The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill RCEB The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 250128 hours of services billed The lack of documentation resulted in unsupported billings to RCEB in the amount of $12412595
In addition ICT provided appropriate supporting documentation for 69693 hours of service but was not billed to RCEB This resulted in an unbilled amount of $2899726
As a result $9512869 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
6
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
Recommendation ICT must reimburse to DDS the $9512869 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to RCEB
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
7
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
FINDINGS AND RECOMMENDATIONS
Finding 1 Infant Development Program ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos Infant Development Program Vendor Numbers HS0468 and HS0698 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to SARC
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to SARC The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill SARC The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 565837 hours of services billed for Vendor Number HS0468 and 131950 hours of services billed for Vendor Number HS0698 The lack of documentation resulted in unsupported billings to SARC in the amount of $42415143 for Vendor Number HS0468 and $7476290 for Vendor Number HS0698 The total unsupported billings amounted to $49891433
In addition ICT provided appropriate supporting documentation for 219286 hours of service for Vendor Number HS0468 and 30125 hours of service for Vendor Number HS0698 but was not billed to SARC This resulted in an unbilled amount of $16437676 for Vendor Number HS0468 and $1706886 for Vendor Number HS0698 The total failure to bill amounted to $18144562
As a result $31746871 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
5
Recommendation ICT must reimburse to DDS the $31746871 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to SARC
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to RCEB
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to RCEB The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill RCEB The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 250128 hours of services billed The lack of documentation resulted in unsupported billings to RCEB in the amount of $12412595
In addition ICT provided appropriate supporting documentation for 69693 hours of service but was not billed to RCEB This resulted in an unbilled amount of $2899726
As a result $9512869 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
6
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
Recommendation ICT must reimburse to DDS the $9512869 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to RCEB
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
7
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
Recommendation ICT must reimburse to DDS the $31746871 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to SARC
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
Finding 2 ClientParent Support Behavior Intervention Training ndash Unsupported Billings and Failure to Bill
The review of ICTrsquos ClientParent Support Behavior Intervention Training Vendor Number PS0044 for the period of July 1 2011 through June 30 2012 revealed that ICT had both unsupported billings as well as appropriate support for services that it failed to bill to RCEB
Unsupported billings occurred due to a lack of appropriate documentation to support the units of service billed to RCEB The failure to bill occurred when ICT had appropriate supporting documentation but it did not bill RCEB The following are the discrepancies identified
ICT was not able to provide appropriate supporting documentation for 250128 hours of services billed The lack of documentation resulted in unsupported billings to RCEB in the amount of $12412595
In addition ICT provided appropriate supporting documentation for 69693 hours of service but was not billed to RCEB This resulted in an unbilled amount of $2899726
As a result $9512869 is due back to DDS for the unsupported billings (See Attachment A)
CCR title 17 section 54326(a)(3) and (10) states
ldquo(a) All vendors shall
(3) Maintain records of services provided to consumers in sufficient detail to verify delivery of the units of service billed
(10) Bill only for services which are actually provided to consumers and which have been authorized by the referring regional centerhelliprdquo
6
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
Recommendation ICT must reimburse to DDS the $9512869 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to RCEB
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
7
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
Also CCR title 17 section 50604(d) and (e) states
ldquo(d) All service providers shall maintain complete service records to support all billinginvoicing for each regional center consumer in the programhellip
(e) All service providersrsquo records shall be supported by source documentationrdquo
Recommendation ICT must reimburse to DDS the $9512869 for the unsupported billings In addition ICT should develop and implement policies and procedures to ensure that proper documentation is maintained to support the amounts billed to RCEB
ICTrsquos Response Lani Fritts ICTrsquos Managing Director stated via letter to Edward Yan DDSrsquo Audit Manager dated March 17 2014 that ICT had additional documentation to provide that would support some of the billings A copy of the letter is enclosed as Attachment C
7
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
Attachment A
Finding 1
Vendor Svc
Code Description Infant Development Program HS0468 805
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Sample Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
A
Rate
$ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496 $ 7496
B C=AB
Units Amount
54825 4109682 $ 76357 5723721 $ 57808 4333288 $ 46574 3491186 $ 45232 3390592 $ 17533 1314274 $ 21192 1588552 $ 47033 3525594 $ 42742 3203940 $ 42058 3152668 $ 49075 3678662 $ 65408 4902984 $
Unsupported Billings
D E=AD
Units Amount
3125 234250 $ 10225 766466 $
4367 327350 $ 20067 1504222 $ 21642 1622284 $ 42092 3155216 $ 20008 1499800 $ 23317 1747842 $ 20592 1543576 $ 19125 1433610 $ 19717 1477986 $ 15009 1125074 $
Failure to Bill Amount
Due to DDS
Net
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
Subtotal 565837 42415143 $ 219286 16437676 $ 25977467 $
1 Infant Development Program HS0698 805 Jul-11
Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
$ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666 $ 5666
8750 10625 13050 13000 10800 10600 16875 12675 11450
8100 9575 6450
495775 $ 602012 $ 739413 $ 736580 $ 611928 $ 600596 $ 956138 $ 718166 $ 648758 $ 458947 $ 542520 $ 365457 $
3675 2800
300 2400 3350 1175 1225 2400 3425 5375 2375 1625
208226 $ 158648 $
16998 $ 135985 $ 189812 $
66576 $ 69408 $
135984 $ 194061 $ 304548 $ 134568 $
92072 $
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
Subtotal 131950 7476290 $ 30125 1706886 $ 5769404 $
Infant Development Program Total 697787 49891433 $ 249411 18144562 $ 31746871 $
8
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
A
Rate
B C=AB
Units Amount
Unsupported Billings
D E=AD
Units Amount
Failure to Bill Amount
Due to DDS
Net
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11
Jan-11 Total
$ 9369 $ 4931 $ 3452
3200 8951
10051 22202
299810 $ 441376 $ 346961 $
1088147 $
525 2066 3691 6282
49188 $ 101873 $ 127413 $ 278474 $
250622 $ 339503 $ 219548 $ 809673 $
Aug-11
Aug-11 Total
$ 9369 $ 4931 $ 3452
2408 4774
14301 21483
225607 $ 235413 $ 493670 $ 954690 $
750 3275 8842
12867
70268 $ 161489 $ 305226 $ 536983 $
155339 $ 73924 $
188444 $ 417707 $
Sep-11
Sept-11 Total
$ 9369 $ 4931 $ 3452
3266 6899
13141 23306
305994 $ 340193 $ 453627 $
1099814 $
1050 1075 3810 5935
98375 $ 53007 $
131520 $ 282902 $
207620 $ 287185 $ 322107 $ 816912 $
Oct-11
Oct-11 Total
$ 9369 $ 4931 $ 3452
2683 9997 6743
19423
251372 $ 492953 $ 232769 $ 977094 $
775 675
4017 5467
72610 $ 33284 $
138667 $ 244561 $
178762 $ 459669 $
94102 $ 732533 $
Nov-11
Nov-11 Total
$ 9369 $ 4931 $ 3452
2075 10608 22418 35101
194409 $ 523083 $ 773871 $
1491363 $
850 2991
12066 15907
79636 $ 147486 $ 416518 $ 643640 $
114773 $ 375597 $ 357353 $ 847723 $
Dec-11
Dec-11 Total
$ 9369 $ 4931 $ 3452
2675 10249
7968 20892
250623 $ 505380 $ 275056 $
1031059 $
125 991
2431 3547
11711 $ 48867 $ 83918 $
144496 $
238912 $ 456513 $ 191138 $ 886563 $
Jan-12 $ 9369 $ 4931 $ 3452
5241 8368 3291
491033 $ 412626 $ 113605 $
100 200
1841
9369 $ 9862 $
63551 $
481664 $ 402764 $
50054 $
9
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
Attachment A
I Can Too Learning Center LLC Summary of Unsupported Billings amp Failure to Bill Audit Period July 1 2011 through June 30 2012
Finding Vendor Svc
Code Description Sample Months
Jan-12 Total
A
Rate
B C=AB
Units Amount
Unsupported Billings
16900 1017264 $
D E=AD
Units Amount
Failure to Bill
2141 82782 $
Amount Due to DDS
Net 934482 $
Feb-12
Feb-12 Total
$ 9369 $ 4931 $ 3452
4192 8075
11567 23834
392750 $ 398179 $ 399293 $
1190222 $
633 766
4016 5415
59306 $ 37771 $
138632 $ 235709 $
333444 $ 360408 $ 260661 $ 954513 $
Mar-12
Mar-12 Total
$ 9369 $ 4931 $ 3452
4600 6751 3117
14468
430976 $ 332893 $ 107599 $ 871468 $
033 975
4791 5799
3091 $ 48077 $
165385 $ 216553 $
427885 $ 284816 $ (57786) $
654915 $
Apr-12
Apr-12 Total
$ 9369 $ 4931 $ 3452
3058 8193 3225
14476
286506 $ 403997 $ 111327 $ 801830 $
-333
2075 2408
-$ 16420 $ 71629 $ 88049 $
286506 $ 387577 $
39698 $ 713781 $
May-12
May-12 Total
$ 9369 $ 4931 $ 3452
2925 7426 4575
14926
274046 $ 366178 $ 157929 $ 798153 $
008 534
1408 1950
749 $ 26331 $ 48604 $ 75684 $
273297 $ 339847 $ 109325 $ 722469 $
Jun-12
June 12 Total
$ 9369 $ 4931 $ 3452
2550 9642
10925 23117
238913 $ 475447 $ 377131 $
1091491 $
-116
1859 1975
-$ 5720 $
64173 $ 69893 $
238913 $ 469727 $ 312958 $
1021598 $
Subtotal 250128 12412595 $ 69693 2899726 $ 9512869 $
TOTAL UNSUPPORTED BILLINGS 947915 62304028 $ 319104 21044288 $ 41259740 $
10
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0468 805
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12
Hrs Per Initial Draft Report
55425 69407 53441 26507 24990
(24559) 1184
Amount Per Initial Draft Report
4154658 $ 5202749 $ 4005938 $ 1986964 $ 1873252 $
(1840942) $ 88752 $
Additional Hrs Allowed
3725 3275
--
1400 --
Adjusted Hours
51700 66132 53441 26507 23590
(24559) 1184
Adjusted Amount
279226 $ 245494 $
--
104944 $ --
Amount Due DDS (Final Audit Report)
3875432 $ 4957255 $ 4005938 $ 1986964 $ 1768308 $
(1840942) $ 88752 $
SubTotal
Feb-12 Mar-12 Apr-12 May-12 Jun-12
24266 22225 23483 31258 51299
358926
1818980 $ 1665986 $ 1760286 $ 2343100 $ 3845374 $
26905097 $
550 075 550
1900 900
12375
23716 22150 22933 29358 50399
346551
41228 $ 5622 $
41228 $ 142424 $
67464 $ 927630 $
1777752 $ 1660364 $ 1719058 $ 2200676 $ 3777910 $
25977467 $
11
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Finding 1
Vendor Svc
Code Description Infant Delopment Program HS0698 805
SubTotal
Audited Months
Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12
Hrs Per Initial Draft Report
5075 7825
12750 10600
7450 9425
15650 10275
8025 2725 7200 4825
101825
Amount Per Initial Draft Report
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
Additional Hrs Allowed
Adjusted Hours
Adjusted Amount
Amount Due DDS (Final Audit Report)
287549 $ 443364 $ 722415 $ 600595 $ 422116 $ 534020 $ 886730 $ 582182 $ 454697 $ 154399 $ 407952 $ 273385 $
5769404 $
12
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
I Can Too Learning Center LLC Attachment B Unsupported Billings Failure to Bill Adjustments
Audit Period July 1 2011 through June 30 2012
A B C D = A-C E F
Audited Hrs Per Initial Amount Per Initial Additional Adjusted Adjusted Amount Due DDS Svc Months Draft Report Draft Report Hrs Allowed Hours Amount (Final Audit Report) Finding Vendor Code Description
2 ClientParent Support Behavior Intervention Training PS0044 048 Jul-11 15920 $ 809673 - 15920 - $ 809673
Aug-11 8966 $ 434965 350 8616 $ 17258 $ 417707 Sep-11 18746 $ 911341 1375 17371 $ 94429 $ 816912 Oct-11 14656 $ 775926 700 13956 $ 43393 $ 732533 Nov-11 21044 $ 963355 1850 19194 $ 115632 $ 847723 Dec-11 17345 $ 886563 - 17345 - $ 886563 Jan-12 14759 $ 934482 - 14759 - $ 934482 Feb-12 19444 $ 1027247 1025 18419 $ 72734 $ 954513 Mar-12 9019 $ 677721 350 8669 $ 22806 $ 654915 Apr-12 12968 $ 780350 900 12068 $ 66569 $ 713781 May-12 14151 $ 793722 1175 12976 $ 71253 $ 722469 Jun-12 22142 $ 1091989 1000 21142 $ 70391 $ 1021598
SubTotal 189160 $ 10087335 8725 180435 $ 574466 $ 9512869
Grand Total Due To DDS $ 41259740
13
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
Attachment C
March 172014
Edward Y an Manager Department of Developmental Services Audit Branch 1600 9th St Room 230 MS 2-10 Sacramento CA 95814
Re Official Response to I Can Too Learning Center LLC Draft Audit Report
Dear Mr Yan
Thank you for the release of the draft audit report and the review conducted February 19 2014 with the I Can TooTrumpet Behavioral Health team
We have three fonnal responses to the draft report
bull For sessions in which some clinical documentation andor parent verification was
available I Can Too was given only partial credit for sessions In total this represented
1050 hours of credit Ve believe pay record data associated with those sessions in which we can tie an employees schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessions This will significantly
increase the number of hours accepted Per a follow-up meeting withAl Kitay and Pardeep D eol on Tuesday March 41
h (prior to which we submitted significant data backshy
up regarding one specific consumer) we were given approval to submit that
documentation as back-up and receive credit for the additional hours VIe will provide a
separate addendum to this letter Nith the total ofhours consumers and $s that we plan to submit for which we are requesting inclusion
bull During the audit exit meeting Al and Pardeep indicated that we had documentation that
counted toward supported billing for several consumers during the months of the audit period but a purchase of service (PO S) was not in the Sand Andreas Regional Center (SARC) system to bill these services Per Aland Pardeeps suggestion Ve have found a
copy of the POS andor initial referral email for the consumer from the SARC service coordinator Ve intend to contact SARC directly to bill these services per A1 and Pardeeps advice but have also submitted these documents to you for review as well
bull More generally we b elieve that DDS should all ow payroll records (pay-stubs V-2s
etc) to substantiate that sessions took place even when clinical source documentation cmmot be produced A record ofpayment to an employee for the same hours associated with a consumers services in a given month is a reasonable indication that a staff was paid for time (documented in our schedulingpayroll systems) as billable time spent with that particular consumer We believe this is a fair and reasonable proxy to those billable
14services havin g been provided
T
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
Attachment C
In the 14 days foll owing the March 3rd follmv-up meeting we have been pulling together extensive payroll schedule and pay stub documenta6on to support the follow-up Ve request a 30 day extension of response (to April 19 20 14) to allow us to provide all remaining documentation By its nature thi s is a very time and energy intensive process- pulling data on hundreds of staffmembers hundreds of consumers across the 1-year audit time-frame and from several different source data systems We appreciate your consideration
J Frankli~ Managing Director I Can Too Learning CenterTrumpet Behavioral Health
15
1401 Parkmoor Ave Suite 208 San Jose CA 95126
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
As part of the audit process I Can Too Learning Center LLC (ICT) was afforded the opportunity to respond to the draft audit report and provide a written response to each finding identified therein The draft audit report was issued on February 11 2014 The Audit Branch received ICTrsquos response on March 17 2014
DDS evaluated ICTrsquos written response to the draft audit report upon receipt and determined that ICT disagreed with the audit findings DDS determined that although ICTrsquos response did not identify which programs were being discussed the comments were all in relation to Vendor Number HS0468 Provided below are excerpts from ICTrsquos response and DDSrsquo evaluation of the response (See Attachment C to the final audit report for the full text of ICTrsquos response)
Finding 1 Infant Development Program - Unsupported Billings and Failure to Bill
ICT argues the following in response to this finding
Unsupported Billing ldquoFor sessions in which some clinical documentation andor parent verification was available I Can Too was given only partial credit for sessions In total this represented 1050 hours of credit We believe pay record data associated with those sessions in which we can tie an employeersquos schedule to billed hours to their payroll stubs should constitute full allowance for the entirety of those sessionsrdquo
In instances where service billings were considered to be unsupported by DDS due to inadequate source documentation DDS did consider payroll records as support and gave ICT credit when it could tie the payroll to services provided to specific consumers An example is when source documentation included a date employee name and consumer name but no length of time for the session In this instance payroll was used to determine length of time for the session
ldquoDuring the audit exit meeting Al and Pardeep indicated that we had documentation that counted toward supported billing for several consumers during the months of the audit period but a purchase of service (POS) was not in the Sand [sic] Andreas Regional Center (SARC) system to bill those servicesrdquo
DDS determined that there was evidence that services were provided for which payment was not made by the regional center Further analysis revealed that the reason the payment was not received was that there was no authorization in the system CCR title 17 requires that before payments can be made the services must be authorized and the services must be provided Since the services were not authorized at the time of the audit DDS was unable to net those services against the unsupported services DDS suggested that ICT discuss those services with the regional center
16
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
Attachment D
DEPARTMENT OF DEVELOPMENTAL SERVICES EVALUATION OF
I CAN TOOrsquoS RESPONSE
ldquoMore generally we believe that DDS should allow payroll records (pay-stubs W-2rsquos etc) to substantiate that sessions took place even when clinical source documentation cannot be producedrdquo
Billings are consumer specific while payroll is employee specific Payroll does not indicate whether a service was provided to a consumer Therefore without collaborating evidence it is unknown if direct consumer services were provided
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 12375 hours for Vendor Number HS0468 These adjustments are reflected in this report (See Attachment B Page 11) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
Finding 2 ClientParent Support Intervention Training - Unsupported Billings and Failure to Bill
ICT did not provide an argument in response to this finding however the supporting documentation provided subsequently included support for finding 2 DDS accepted the additional documentation
DDSrsquo Conclusion
Subsequent to the receipt of this response ICT provided DDS with documents to support billings that were previously unsupported DDS accepted documents that supported an additional 8725 hours for Vendor Number PS0044 These adjustments are reflected in this report (See Attachment B Page 13) However ICTrsquos response did not address its policies and procedures going forward DDS recommends that ICT develop and implement policies and procedures to ensure that proper documentation is maintained to support its billings to the regional centers A future audit may be conducted by DDS to ensure that DDSrsquo recommendation has been fully implemented
17
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