If you received your 2015 desk audit questions, you may have noticed that your RSU accountant is asking more questions than in the past, especially for agencies that were previously audited by the OSC. Providers should understand that the OSC audits are not just an audit of the provider, they are also a commentary on SED’s oversight process. With all the findings in the past, SED is focusing more energy into ensuring that the CFR’s filed by agencies have been properly reviewed and vetted. For those agencies that have had issued OSC reports, we have seen an increase in questions in the areas where the OSC had past findings so that SED can determine if the past issues have been resolved. For those that have not, you can still see the influence of the OSC audits in the questions that are asked.
While it is very difficult to completely eliminate desk audit questions, there are ways that you can mitigate the questions asked and, more important, eliminate surprises. We encourage our clients to perform certain edit checks during the CFR preparation phase to ensure that the document makes sense.
- Reconcile the care days/units of service per the CFR to the filed STAC’s. SED will do this, so you want to make sure up front that it reconciles so you don’t have a change in your rate after the fact because SED modifies the care days on your CFR.
- If you add a new position title code, you need to be able to support the need for the new position. You may want to discuss the need for the new position with your RA so that your RA is behind the new position programmatically.
- If you utilize a 290, 390, 590, or 690 code, be prepared to explain who is charged to the code, what their title is, and make sure you have a job description for them.
- Calculate average salary per FTE and determine if the average salary makes sense compared to the prior year. Be prepared to explain significant fluctuations to SED.
- Utilizing your approved classroom ratios outlined on SED-1, determine if your classroom staffing levels by program on CFR-4 make sense. If you have 5 classrooms and each classroom has 1 teacher, you should have about 4.43 teachers for that program on CFR-4 (5 classrooms x 1 teacher per classroom x 46 weeks the program is open/52 weeks in a year). You can do the same calculation for teacher assistants and 1:1 aides.
- If you charge any costs to a miscellaneous or “other” category (e.g. other insurance, other contracted services, etc.), expect questions from SED as to what is included in this category.
- If you have staff that have an SAS or other administrative designation that are not charged to a 500 or 600 level position title code, there is a good chance these individuals will be questioned and re-classed.
- Does the offsetting revenue make sense with respect to the typically functioning children outlined on SED-1 lines 100 and 101.
- Are staff split between position title codes. If so, are their job descriptions to substantiate the work they performed, and time studies to support the charges to the various position title codes.
If you pre-audit your CFR, ensure that all aspects of your CFR are consistent and in compliance with the RCM and the CFR claiming manual, you can greatly reduce the number and severity of desk audit questions.
Albert Borghese, CPA
Albert is a member of Cerini & Associates’ audit and consulting practice where he focuses on serving the firm’s special education and nonprofit clients. Albert is also involved in the marketing and development of the firm, and frequently participates in recruiting efforts, and research.