Report 2016-128 Recommendation 14 Responses

Report 2016-128: In‑Home Supportive Services: The State Could Do More to Help Providers Avoid Future Payment Delays (Release Date: March 2017)

Recommendation #14 To: Social Services, Department of

If the Legislature amends state law as we recommend, Social Services should modify the timesheet format to incorporate the weekly authorization for services and the new two-workweek pay period. Social Services should also reconfigure its timesheet to require that all information be entered on one side of the document, including the signatures of the provider and recipient.

Annual Follow-Up Agency Response From November 2020

CDSS will not implement. No change to previous response.

California State Auditor's Assessment of Annual Follow-Up Status: Resolved

This recommendation is resolved because Social Services has implemented the use of electronic timesheets. The timesheet system includes an automated notification to inform the provider if he or she exceeds the weekly maximum number of service hours.

Annual Follow-Up Agency Response From November 2019

No change to previous response.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

Annual Follow-Up Agency Response From November 2018

CDSS will not implement.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

1-Year Agency Response

CDSS continues to successfully process over 1 million timesheets each month and the trend of exceptions is consistently decreasing. (see Attachment I). The Department has conducted several timesheet webinar trainings (see Attachment J) for the IHSS recipients and providers, and have posted recorded webcasts on the CDSS website that are available to view at any time. Additionally, with the statewide implementation of the Electronic Timesheet System (ETS), CDSS continues to see the enrollment increase daily. With the use of ETS, the providers will not be able to submit a timesheet with errors, and they will be prompted if/when they attempt to submit a timesheet that will exceed their expected overtime limits.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

Although Social Services cites the efforts it has undertaken to educate recipients and providers, we continue to maintain our belief that the State should reconsider an earlier proposal to simplify the use of timesheets, as we state on page 34 of our report. We directed our recommendation to the Legislature to amend state law to define the pay period as two workweeks. Social Services expressed concerns that a two-week pay period would result in frequent situations in which the pay period crosses months. However, a similar situation already exists under the current timesheet format in instances when a workweek crosses over between two pay periods, as we state on page 32 of our report. Despite this concern and other issues that Social Services cites, we believe that the State should consider the extent to which the current timesheet format has caused confusion among providers, particularly in not adhering to workweek limits and being at jeopardy of suspension from the IHSS program.

6-Month Agency Response

Remains Not Implemented/Disagree with Recommendation. See 60-day response.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

We continue to maintain our belief that it may be time for the State to reconsider an earlier proposal to simplify the use of timesheets, as we state on page 34 of our report. We directed our recommendation to the Legislature to amend state law to define the pay period as two workweeks. Although Social Services is concerned that a two-week pay period would result in frequent situations in which the pay period crosses months, a similar situation already exists under the current timesheet format in instances when a workweek crosses over between two pay periods, as we state on page 32 of our report. Despite this concern and other issues that Social Services cites, we believe that the State should consider the extent to which the current timesheet format has caused confusion among providers, particularly in not adhering to workweek limits and being at jeopardy of suspension from the IHSS program.

60-Day Agency Response

While moving to a two-workweek pay period and weekly authorization may benefit providers when completing timesheets, it creates other issues. Nearly one-hundred percent of IHSS recipients receive IHSS as a Medi-Cal benefit. Each IHSS recipient is associated with one of the four IHSS programs: Personal Care Services Program (PCSP), IHSS Plus Option (IPO), Community First Choice Option (CFCO) or the IHSS Residual Program (IHSS-R), each of which are a separate funding source, and the first three are Federal Financial Participation (FFP) Medi-Cal programs. Each month a recipient is associated with one of the four programs/funding sources. Recipients may change programs/funding source from month to month depending on their circumstances. If a two-week pay period were utilized, it would create an alignment issue with Medi-Cal which would impact both program claiming of federal funding and the Medi-Cal share-of-cost spend down process. Utilizing a two-week pay period results in frequent situations where the pay period crosses months, so if a recipient changes program/funding source from one month to the next, then the pay period would be associated to two different funding sources creating significant claiming complexities. The second challenge is with the Medi-Cal share-of-cost spend down. When a provider submits a timesheet for a recipient with a Medi-Cal share-of-cost, the CMIPS system does an automated call to the MEDS system to look for any remaining share-of-cost amount and makes the appropriate deduction from the provider payment. For each call, the MEDS system can only look for a single month's remaining share-of-cost for both months. This would require a system change to the MEDS system. Since IHSS is a Medi-Cal benefit, these are critical issues.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

As we state on page 34 of our report, we believe that it may be time for the State to reconsider an earlier proposal to simplify the use of timesheets. We directed our recommendation to the Legislature to amend state law to define the pay period as two workweeks. Although Social Services is concerned that a two-week pay period would result in frequent situations in which the pay period crosses months, a similar situation already exists under the current timesheet format in instances when a workweek crosses over between two pay periods, as we state on page 32 of our report. Despite this concern and other issues that Social Services cites, we believe that the State should consider the extent to which the current timesheet format has caused confusion among providers, particularly in not adhering to workweek limits and being at jeopardy of suspension from the IHSS program.

All Recommendations in 2016-128

Agency responses received are posted verbatim.