Day Program Audit Trail Guidance

Helping Families. Supporting Communities. Empowering Individuals.

Purpose

The Illinois Department of Human Services/Division of Developmental Disabilities (ILDHS/DDD) must conduct ongoing annual reviews of Medicaid Waiver programs per the approved Medicaid Waiver Application. Through this notice, it is DDD's intention to provide additional guidance on the billing process and what constitutes an adequate audit trail for Day Program Services. Day Program Services include: Supported Employment (group or individual setting), Community Day Services, and Adult Day Care Services.

Background

The Bureau of Program Development & Medicaid Administration (BPDMA) reviewed billings that were selected via a statistically valid random sample of individuals that received waiver services that were provided between July 16-31, 2016, and later billed and claimed. The findings of the review can be viewed at http://www.dhs.state.il.us/page.aspx?item=97722. It is the provider's responsibility to take steps to ensure the accuracy of their bills. Dates of services, number of hours billed, and the programs being billed must be accurate. The service provider is responsible for submitting complete and accurate billings and maintaining appropriately detailed supporting documentation. Agencies are responsible for keeping hourly attendance reports for day services. These reports must be kept on file to establish an audit trail for individuals receiving Medicaid waiver community based services. Audit trail documentation must be maintained for at least five years from the date of services.

A January 26, 2006 memo was issued which provided detail to providers regarding their responsibility to take steps to ensure the accuracy of their bills. DDD has worked with DHS internal auditors to determine what constitutes as an adequate trail and provides the following dot points for reference.

  • "Core hours" which include beginning and end times ( travel times are not billable)
  • Time out for lunch, unless it is part of active programming
  • Any time spent away from the program - for example, a person leaves for a doctor's appointment and then returns.

Process

Attendance forms should be competed daily at the day program to ensure accuracy.

Form number IL462-1303 - Day Program Daily Attendance Record (pdf) - (N-12-07)  is a sample of an attendance form that may help you to ensure adequate and accurate data collection to support day program bills submitted.

The Bureau of Program Development & Medicaid Administration (BPDMA) will continue to conduct compliance reviews to ensure the integrity of paid bills and Medicaid claims.

Effective Immediately