Audit Report on the Human Resources Administration’s Monitoring and Disposition of Complaints Made Against Home Care Attendants

EXECUTIVE SUMMARY

The objective of this audit was to determine whether the Human Resources Administration (HRA) has adequate controls over the recording, tracking, and follow-up of complaints against home care attendants. HRA’s Home Care Services Program (HCSP) provides access to Medicaid-funded long-term care programs designed to help elderly or disabled individuals remain safely at home rather than in a nursing home or other institution. One of the long-term care options offered by HCSP is the Personal Care Program, which provides home attendant and/or housekeeping services to clients who are in stable condition but are having difficulty with at least one or more activities of daily life, such as walking, cooking, cleaning, bathing, or using the bathroom.  HRA has contracts with 50 home care vendors to provide personal care services.

HRA’s Complaint Tracking Unit (CTU) is responsible for receiving, evaluating, and monitoring the investigation of complaints against home attendants, and it uses its Medical Assistance Tracking Information System (MATIS)   to record the complaint details.  CTU is responsible for ensuring that the vendor investigates all complaints and takes appropriate corrective action for substantiated complaints.

The total number of Personal Care Program cases under HRA’s jurisdiction is declining as a result of an initiative by the New York State Department of Health (NYSDOH) to transition appropriate cases to Managed Long-Term Care (MLTC) .  Enrollment in a MLTC plan is mandatory for consumers who are; 1) age 21 or older; 2) eligible for both Medicaid and Medicare; and 3) in need of community-based long-term care services for more than 120 days.  HRA stated that by December 2013, the number of clients was reduced to approximately 4,000 .   During Fiscal Years 2012 and 2013, HRA received and recorded in MATIS a total of 935 and 672 complaints, respectively.

Audit Findings and Conclusions

HRA has inadequate controls over the recording, tracking, and follow-up of complaints against home care attendants.  Some of the calls and complaints reported to HRA were not reflected in MATIS and some that were recorded were incorrectly categorized as informational calls.  For more than one quarter of the reviewed complaints that were recorded in MATIS, vendors did not report the investigation results to HRA within the required timeframes. In addition, for less severe complaints identified as Level II, III, and IV complaints, HRA has limited controls in place to verify that the vendors accurately reported their investigation efforts.

Among other issues found, HRA does not consistently take advantage of a feature in MATIS for recording the names and Social Security numbers of home attendants against whom complaints were lodged so that it can identify those home attendants who are the subjects of complaints at a higher rate than the norm.

Audit Recommendations

To address the issues raised in this audit, we made eight recommendations:

• HRA should ensure that all active recipients of Personal Care Program services are recorded in MATIS so that all calls and complaints can be appropriately registered in MATIS to allow for effective complaint tracking and monitoring.
• HRA should track and maintain a record of all deletions in MATIS, including the reason for deletion and the system-generated identification (ID) numbers, and should consider enabling a tracking system in MATIS to maintain an audit trail of deleted records.
• HRA should ensure that accurate data is used to determine a vendor’s compliance with the reporting of the investigation results.
• HRA should review past compliance analyses and determine whether there are additional vendors that were non-compliant and notify those vendors so that any underlying issues can be corrected.
• HRA should follow-up with all vendors regarding the late reporting of their investigation results to ensure that future investigations are completed and reported in a timely manner.
• HRA should investigate any material discrepancies between the vendors’ Forms 2046 and the CTU Forms 2046. This will help to ensure the accuracy of the information in HRA records and help HRA verify that the vendors removed any risk and appropriately addressed the complaint.
• HRA should consider periodically conducting field investigations of a sample of Level II, III, and IV complaints to ensure the accuracy of the vendor-reported information and that the vendor has performed a complete investigation.
• HRA should use the available data fields in MATIS to record home attendant names and Social Security numbers so that it can perform more comprehensive analyses of complaints against home attendants.

Agency Response

HRA officials disagreed with the audit’s findings concerning the accuracy of MATIS complaint records and the tracking of complaints against home attendants to determine whether any are the subject of complaints at a higher rate than normal.  Regarding the audit’s eight recommendations, HRA officials agreed with six of them and disagreed with the recommendations that they: 1) conduct additional analyses to determine whether any other vendors were non-compliant in reporting investigation results to HRA in a timely manner; and 2) perform more comprehensive analysis of complaints against home attendants using the attendants’ names and Social Security numbers.  After carefully reviewing HRA’s arguments, we find no basis to change any of our findings and recommendations