Federal Reports

We conducted a limited scope audit of Education Commission of the States (ECS) for the period of December 1, 2015 through October 31, 2018. Limited scope audits involve a limited review of financial and non-financial information of NEA award recipients to ensure validity and accuracy of reported information, and compliance with Federal requirements. Based on our limited scope audit, we concluded that ECS generally did not fully comply with financial management system and recordkeeping requirements established by OMB and NEA. We identified areas requiring improvement. A summary of our findings is as follows, ECS: reported unallowable costs on its Federal Financial Reports (FFRs), did not report actual costs on its FFRs, reported costs outside of the award period, did not submit its required FFR and Final Descriptive Report on time, did not comply with Federal requirements related to record retention, did not have the required Section 504 Self-Evaluation on file, did not have debarment and suspension policies and procedures, and did not have policies and procedures for the management of Federal awards.

Medicare paid about $1.9 billion for psychotherapy services provided to beneficiaries nation-wide from July 1, 2015, through June 30, 2017 (audit period). Prior OIG reviews found that Medicare had made millions in improper payments for mental health services, including psychotherapy services. After analyzing Medicare claim data, we selected for review Oceanside Medical Group (Oceanside). Our analysis indicated that providers from Oceanside billed Medicare an average of 33 individual services per day. In addition, two providers each billed for services on all but 5 days during our audit period.

The Affordable Care Act established the Medicare Shared Savings Program (MSSP). Accountable Care Organizations (ACOs) in the MSSP may be eligible to receive shared savings payments from the Centers for Medicare & Medicaid Services (CMS) if they reduce healthcare costs and satisfy the quality performance standard for their assigned beneficiaries. As part of the standard, ACOs must report to CMS complete and accurate data on all quality measures. For performance year (PY) 2016, ACOs reported more than half of the quality measures using the designated CMS web portal. If the reported data were not complete and accurate, the shared savings payments could have been affected. This vulnerability led us to select two ACOs that had consistently received shared savings payments in order to perform an initial risk assessment of ACOs' reporting of data on quality measures through the CMS web portal. This report covers one of those ACOs.