Responses to the Audit
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California Department of Social Services
February 27, 2017
Ms. Elaine M. Howle, State Auditor
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
SUBJECT: IN-HOME SUPPORTIVE SERVICES: THE STATE COULD DO MORE TO HELP PROVIDERS AVOID FUTURE PAYMENT DELAYS: 2016‑128
This letter provides the California Department of Social Services' (CDSS) initial response to the California State Auditor's Office draft of the above entitled report.
If you have any questions concerning the enclosed CDSS response, please contact me at (916) 657-2598 or Cynthia Fair, Audits Bureau Chief, at (916) 651-9923.
Sincerely,
WILL LIGHTBOURNE
Director
Enclosure
California Department of Social Services (CDSS)
RESPONSES TO AUDIT RECOMMENDATIONS
California State Auditor (CSA).
| Audit #: | 2016-128 |
| Audit Title: | In-Home Supportive Services (IHSS): The State Could Do More to Help Providers Avoid Future Payment Delays |
Recommendations for Social Services:
Recommendation 1:
To ensure that counties are handling timesheet exceptions consistently and minimizing delays, Social Services should develop and issue procedures by July 2017 to require the counties to first attempt to correct timesheet errors for specific types of exceptions before mailing blank replacement timesheets to providers. For example, counties should attempt to correct timesheets with unreadable entries or entries that exceed 24 hours in a day by reviewing the timesheet, contacting the provider if necessary to clarify the intended entry, and making a timesheet correction in Case Management Information and Payrolling System II (CMIPS II). Additionally, Social Services should review a random sample of exceptions at least quarterly to ensure that the counties are following its new procedures.
CDSS Initial Response:
Partially Implemented/Anticipated Implementation Date: April 2017. The California Department of Social Services (CDSS) has released a draft Timesheet Exceptions Report All County Letter (ACL) for stakeholder review in December 2016. It is being finalized and will be released in April 2017. This ACL will also communicate that CDSS will be monitoring the counties’ activities on a quarterly basis to ensure timely resolution is occurring.
Recommendation 2:
To reduce the likelihood of inadvertent errors on replacement timesheets, Social Services should create functionality within CMIPS II to allow replacement timesheets to be printed with data from the original timesheet that has been submitted correctly. Social services should develop a plan by August 2017 that outlines actions, such as seeking funding from the Legislature if necessary, that will be taken to create the functionality.
CDSS Initial Response:
Timesheets are accepted and processed as they are received at the Timesheet Processing Facility. To make the suggested change would be a significant cost and technical effort, at a time when the CDSS and stakeholders are moving to automated solutions that would prevent such errors in the first place. Additionally, pre-printing legible entries on a replacement timesheet would not necessarily lessen provider and recipient confusion about the actual error(s) that was made, and could in fact create future exceptions if a timesheet for a recipient’s different provider is processed before the replacement timesheet is processed.
There also would be interplay with other automated system business rules that are performed on each individual timesheet, to ensure the information on the timesheet is accurate and that the appropriate payment calculations can be completed. Some examples are:
- Validation that the provider and/or recipient were eligible during the specified pay period;
- Validation of remaining recipient authorized hours for the month; and,
- Validation of straight time wage calculations vs. overtime wage calculations, etc.
Recommendation 3:
To ensure that counties follow a consistent and expeditious policy for responding to providers who report lost or stolen paychecks, Social Services should issue a policy by September 2017 that allows providers to request replacement paychecks after five business days from the issue date of the lost or stolen paychecks.
CDSS Initial Response:
CDSS will release an ACL in July 2017 to clarify existing policy, to allow providers to request a replacement paycheck after ten business days from the issue date of a lost or stolen paycheck. CDSS believes the ten-day period more adequately allows time for the US Postal Service mail process and ensures the provider has adequate time to receive their paycheck before requesting a replacement, thereby preventing unnecessary check cancellations.
Recommendation 4:
To assist counties in resolving exceptions efficiently and in managing their workload, Social Services should by December 2017 develop timesheet exception reports in CMIPS II that enable county staff to categorize common exceptions, identify providers with recurring exceptions, and track timesheet processing workload over a period of time. Social Services should also train county staff on the most effective use of these reports.
CDSS Initial Response:
Partially Implemented/Anticipated Implementation Date: December 2017. CDSS released a draft ACL in January 2017 to the counties providing guidance on the utilization of the existing Timesheet Exceptions Report. This ACL also will communicate that CDSS will be monitoring the counties activities on a quarterly basis to ensure timely resolution is occurring. The final ACL will be released by April 2017.
Additionally, CDSS submitted change requests to the CMIPS II vendor to modify existing data download files to include detailed timesheet and timesheet exception data. These data download files are provided to counties to assist them in the tracking and resolution of timesheet exceptions.
Recommendation 5:
To effectively communicate information to providers and reduce call volumes at counties, Social Services should implement functionality within CMIPS II by December 2017 to provide automated notifications to providers about the status of their timesheets and paychecks, including when the timesheet is received and processed, when paychecks are processed, and whether there are exceptions on timesheets that would delay processing paychecks and whom to contact at the county to address those exceptions.
CDSS Initial Response:
Partially Implemented/Anticipated Implementation Date: May 2017. With the implementation of the electronic timesheets which is scheduled to pilot in May 2017 and targeted to go live statewide in July 2017, this solution will include a feature that automatically sends email notifications to the providers and recipients who opt into this service throughout the timesheet process. Additionally, any provider, including those who do not use the electronic timesheets feature, can set up an account in the application and have the ability to check the status of their timesheets and paychecks. CDSS also is evaluating options that could potentially send an email notification to the providers and/or recipients when the paper timesheet has been received and processes through CMIPS II.
Recommendation 6:
To ensure that Hewlett-Packard Enterprise (HPE) is meeting its contractual requirements, Social Services should review timesheet processing data and reports and follow up with OSI to make sure it is taking corrective action if HPE exceeds the agreed-upon processing time frames.
CDSS Initial Response:
Partially Implemented/Anticipated Implementation Date: May 2017. The Department will continue to work with OSI on monitoring of vendor contract requirements. Additionally, CDSS already has requested that all timesheet processing data and reports are provided to the Department.
Recommendation 7:
To ensure that Office of Systems Integration (OSI) is adequately monitoring HPE, and to allow for more proactive management of the IHSS program, Social Services should work with OSI to enforce the contract provision requiring HPE to submit monthly data on the number of timesheets with exceptions by county and the time taken to resolve those exceptions. Moreover, Social Services should develop a process for regularly reviewing these data to detect any discrepancies among the counties’ processes for handling timesheets with exceptions.
CDSS Initial Response:
Partially Implemented/Anticipated Implementation Date: May 2017. The Department is working with OSI to ensure CDSS also receives the vendor’s monthly data service level agreement statistics. As mentioned in the response to Recommendation 4, CDSS also has submitted change requests to modify data download files, to ensure that the Department and counties can better track the processing of timesheet exceptions.
Recommendation 8:
To enable it to track whether Employment Development Department (EDD) is meeting its contractual time frame for printing and mailing of timesheets, Social Services should either modify its current agreement or require in the renewal of its agreement a method for tracking the time required to print and mail timesheets. Social Services should also perform monthly reviews of the activities performed by EDD and State Controller’s Office (SCO) to ensure compliance with the time frames for each agreement. Additionally, Social Service should implement a process to regularly test EDD and SCO processes to ensure they are within the required time frames.
CDSS Initial Response:
Partially Implemented/Anticipated Implementation Date: December 2017. CDSS agrees with this recommendation. The Department is amending the current Employment Development Department (EDD) and State Controller’s Office (SCO) contracts, to ensure that both EDD and SCO are meeting their obligations for printing and mailing of timesheets and paychecks. CDSS will monitor compliance with the amended agreements. Additionally, CDSS will oversee compliance of EDD and SCO print processes to ensure they are meeting the agreements.
Recommendation 9:
To more effectively address common problems reported by providers and recipients, Social Services should develop a formal process to document and address patterns of concerns conveyed through complaints. Specifically, the process should include a method for Social Services to identify and aggregate the complaints it receives, to analyze that information to determine whether there are common themes or broader issues to address within IHSS, and to obtain sufficient information to substantiate the response to the complaints. The process should also include steps to clarify ambiguous issues raised in the complaints and define clear deadlines and the steps to take when responding to complaints if those deadlines cannot be met.
CDSS Initial Response:
Partially Implemented/Anticipated Implementation Date: May 2017. The Department has developed a central location to maintain and track the concerns reported by recipients and providers. CDSS is improving its procedures to identify and analyze issues in the aggregate and respond accordingly.
Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM SOCIAL SERVICES
To provide clarity and perspective, we are commenting on the response to our audit report from Social Services. The numbers below correspond to the numbers we have placed in the margin of Social Services’ response.
Throughout its response, Social Services indicates that it has taken steps to partially implement a majority of our recommendations. We look forward to reviewing Social Services’ 60‑day response to the audit recommendations and its supporting documentation to learn about the steps it has taken to implement these recommendations, as well as these recommendations and in Table 1, which it did not address in its response.
Social Services’ response is misleading in asserting that moving to an automated solution would prevent timesheet errors from occurring in the first place. We acknowledge that electronic time reporting will allow providers to submit their timesheets using a website and receive immediate notifications regarding whether Social Services has accepted and processed their timesheets for payment. However, as we describe, this solution does not take into account the population of providers who may choose to continue to use paper timesheets after electronic time reporting is implemented and may benefit from the functionality that allows replacement timesheets to be printed with data that had been submitted correctly.
Although reprinting valid data on new replacement timesheets may not necessarily lessen provider and recipient confusion about the actual errors that were made, we note that requiring the provider to complete a blank replacement timesheet increases the potential for the provider to make an inadvertent error on an unrelated portion of the timesheet that was initially correct, which may require the need for completion of yet another replacement timesheet. In addition, it is unclear to us why Social Services believes that preprinting legible entries on a replacement timesheet could create future exceptions if a timesheet for a recipient’s different provider is processed before the replacement timesheet is processed. We show in Figure 3 that 14 percent of the 1.4 million timesheet exceptions causing delays from November 2013 through July 2016 were the result of recipients not having any remaining authorized hours, which signifies that providers have historically submitted timesheets claiming hours that have already been used, even under the current process of completing blank replacement timesheets.
As we state, we believe a more reasonable amount of time for providers to wait before reporting a paycheck lost or stolen is five business days, which allows the average two to three business days for first‑class mail delivery, plus two extra days for any unforeseen circumstances. We acknowledge Social Services’ concern that providers without adequate time to receive their paychecks before requesting replacement checks may result in unnecessary check cancellations. However, we stand by our statement that Social Services should allow providers to request replacement checks expeditiously and inform them of the risk they incur in relinquishing their rights to the original paychecks.
As we state, the chief deputy director at Social Services indicated that implementing automatic status notifications within CMIPS II would soon be irrelevant because of Social Services’ plan to implement electronic time reporting in June 2017. Nevertheless, as we describe, some providers may choose to continue to submit paper timesheets after electronic time reporting is implemented. Therefore, we look forward to its 60‑day response so we can review Social Services’ evaluation of options for sending email notifications to providers when the paper timesheet has been received and processed in CMIPS II.
Office of Systems Integration
February 27, 2016
Ms. Elaine M. Howle, State Auditor
California State Auditor
621 Capitol Mall Suite 1200
Sacramento, CA 95814
SUBJECT: "In-Home Supportive Services: The State Could Do More to Help Providers and Avoid Future Payment Delays," Report No. 2016‑128
The Office of Systems Integration (OSI) appreciates the opportunity to comment on the recommendation outlined in the California State Auditor’s (CSA) Audit Report No. 2016-128, titled “In-Home Supportive Services: The State Could Do More to Help Providers and Avoid Future Payment Delays.”
Recommendation:
To ensure that the reports it receives from the CMIPS II contractor are complete and allow it to better manage CMIPS II and support the IHSS program, OSI should enforce its agreement requiring the contractor to submit monthly data on the number of timesheets with exceptions by county and the time taken to resolve them.
OSI Response:
During the course of the contract, the OSI received and reviewed metrics provided by the contractor to actively monitor and ensure timesheet processing was timely. This included review of the following:
- Daily - Timesheets received and processed
- Daily - Timesheets failing barcode scan
- Daily - Successful batch processing of payroll
- Daily - Successful State Controller’s Office (SCO) transmission and processing
- Daily - SCO wrap back file
- Weekly - Timesheet volume
- Weekly and Monthly - Help desk tickets associated with payroll
- Monthly - Timesheets processed within ten days (contractor and SCO processing)
- Monthly - Number of timesheet exceptions statewide with a breakdown of number by exception type
In addition, the contractor provided an “on-demand” report showing the percentage of timesheets processed within five days. The report sent to the auditor covering the period of October, November, and December 2016 indicated that all timesheets were processed within five days except for those submitted early or held for a 24-hour hold. As of the January 2017 Monthly Operations Management Report (MOMR), the OSI has added three metrics for: 1) percent of timesheets processed by the contractor within five days per month, 2) the number of exception timesheets by county per month, and 3) frequency distribution of the time to resolve exception timesheets on a monthly basis. The OSI will continue to monitor that the contractor processes timesheets within five business days, assess liquidated damages when warranted, and report the results to the California Department of Social Services (CDSS). The MOMR is shared with the CDSS monthly.
We appreciate the opportunity to provide feedback and will continue to collaborate with the CDSS to address these findings. If you have any questions regarding the OSI’s response, please contact Matt Schueller, Deputy Director, Administration Division, by e‑mail at matt.schueller@osi.ca.gov.
Sincerely,
JOHN BOULE
Director
Comment
CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM OSI
To provide clarity and perspective, we are commenting on the response to our audit report from OSI. The numbers below correspond to the numbers we have placed in the margin of OSI’s response.
Although its response includes only one of our two recommendations, OSI addresses both recommendations within its response. Specifically, OSI discusses the steps it plans to take to monitor whether HPE is processing timesheets within five business days, and it also addresses its plan for requiring HPE to submit monthly data on the number of timesheets with exceptions by county and the time taken to resolve them.
OSI’s assertion that it received and reviewed metrics provided by the contractor during the course of the contract to ensure timesheet processing was timely is not entirely accurate. As we describe in this section, OSI has not analyzed key information that could aid in monitoring timesheet exceptions and payments. Specifically, we state that OSI’s contract with HPE requires HPE to process timesheets within five business days of receipt, and for OSI to assess penalties for timesheets that are not processed promptly. However, as we state, the CMIPS II project director at OSI acknowledged that OSI does not review any data on the number of timesheets HPE processed within the five‑day limit. OSI’s contract with HPE also requires HPE to report to OSI and Social Services the number of timesheets with exceptions that were directed to each county and the length of time it took to resolve those exceptions, which we describe. We further state that HPE submits to OSI a monthly operations management report that contains data on other required performance metrics, such as system availability and the total number of exceptions per month. However, the management report does not contain detail on timesheet exceptions by county or the time taken to resolve them. Nevertheless, OSI’s contract with HPE specifically requires timesheet exception data, which is relevant and necessary for assessing the performance of the timesheet and payment process.
OSI states that HPE provided an “on‑demand” report that shows the percentage of timesheets processed within five days for a three‑month period. However, HPE prepared this report in response to our inquiries, rather than as part of any type of ongoing monitoring effort. OSI also states that it has since added specific metrics to its monthly management report to address our recommendations. We look forward to reviewing documentation along with OSI’s 60‑day response to the audit recommendations concerning how it uses this additional information to monitor HPE.