UNIVERSITY OF VIRGINIA BOARD OF VISITORS MEETING OF THE AUDIT AND COMPLIANCE COMMITTEE June 11, 2010 AUDIT AND COMPLIANCE COMMITTEE (Open Session) Friday, June 11, 2010 11:30 a.m. – 12:00 noon Board Room, The Rotunda Committee Members: W. Heywood Fralin, Chair Helen E. Dragas Austin Ligon Vincent J. Mastracco, Jr. Don R. Pippin Warren M. Thompson John O. Wynne, Ex-officio AGENDA PAGE I. II. ACTION ITEMS (Ms. Deily) A. Audit Schedule, 2010 – 2011 B. Corporate Compliance Project Schedule, 2010-2011, (Ms. Deily will introduce Ms. Strauss, Chief Corporate Compliance and Privacy Officer, Ms. Strauss to report) INFORMATION ITEM (Ms. Deily) Summary of Findings III. EXECUTIVE SESSION – LIST OF ITEMS IV. APPROVAL OF SUMMARY OF AUDIT FINDINGS 1 7 9 UNIVERSITY OF VIRGINIA BOARD OF VISITORS AGENDA ITEM BOARD MEETING: June 11, 2010 COMMITTEE: Audit and Compliance AGENDA ITEM: I.A. Audit Schedule BACKGROUND: Ms. Deily will present the proposed Audit Schedule for the 2010-2011 Fiscal Year. The Schedule has been developed based on required work from state and external agencies, risk assessment models, requests from management, and analyses of work performed in prior years. ACTION REQUIRED: Approval by the Audit and Compliance Committee and by the Board of Visitors APPROVAL OF THE AUDIT SCHEDULE FOR FISCAL YEAR 2010-2011 RESOLVED, the Audit Schedule for Fiscal Year 2010-2011 is approved as recommended by the Audit and Compliance Committee. 1 UNIVERSITY OF VIRGINIA BOARD OF VISITORS AGENDA ITEM Determination of Hours Available for 2010-2011 Audit Projects Total Total Hours Available 35,360 Less: 4,160 Vacancies Sub-Total 31,200 Professional Development Holidays Other Leave Other Activities Office and Personnel Administration Recruiting Committee & Council Meetings Travel Hours Available for Audit Projects 1,274 1,560 3,896 3,674 20,796 Other Activities 10% Vacancies 12% Audits 59% Holidays 4% Prof. Dev. 4% Other Leave 11% 2 UNIVERSITY OF VIRGINIA BOARD OF VISITORS AGENDA ITEM Allocation of Hours Available for Audit Projects Fiscal Year 2010-2011 Total Hours Available for Audit Projects Less: Wrap-up of FY 09-10 Audit Schedule Unscheduled Audits/Special Requests/Hotline Projects General Systems Development & Consulting External Assistance 20,796 Board Preparation & Mtgs 330 4,875 1,043 611 134 IT Support of Projects/ Activities 1,028 General Project Support/ Supervision/Strategic Planning 3,895 Hours Available for Scheduled Audit Projects 8,880 3 UNIVERSITY OF VIRGINIA BOARD OF VISITORS AGENDA ITEM 2010-2011 Audit Schedule UNIVERSITY DEPARTMENT/DIVISION ADMINISTRATIVE & SUPPORT SERVICES President’s Office College at Wise ARMICS Self Service Time and Leave System ARRA (Federal Stimulus Funds) Financial Administration ATHLETICS NCAA Compliance – (Non major areas) PROVOST ACTIVITIES Art Inventory OTHER ACTIVITIES University Bookstore/Cavalier Computers Inventory Follow-Up Audits - University Compliance Audits UNIVERSITY TOTAL BUDGETED HOURS 250 600 150 600 400 600 400 150 100 150 1,511 4,911 4 UNIVERSITY OF VIRGINIA BOARD OF VISITORS AGENDA ITEM 2010-2011 Audit Schedule HEALTH SYSTEM DEPARTMENT/DIVISION PATIENT CARE ACTIVITIES General Clinical Research Center Outpatient Clinic Charge Captures (Post-Epic) ADMINISTRATIVE & SUPPORT SERVICES Financial Reporting Medical Center Procurement SCHOOL OF MEDICINE Department of Pathology Follow-up Audits OTHER ACTIVITIES Epic System Consulting ARMICS – Medical Center Follow-up Audits – Medical Center Inventory – Pharmacy Services Inventory – Surgical Supply HEALTH SYSTEM TOTAL BUDGETED HOURS 400 400 350 500 350 100 250 100 200 25 25 2,700 5 UNIVERSITY OF VIRGINIA BOARD OF VISITORS AGENDA ITEM 2010-2011 Audit Schedule INFORMATION TECHNOLOGY DEPARTMENT/DIVISION Security Review of External Interfaces (U/HS) Student Information System Review (U/Wise) General Controls Review for end of 3 year cycle (U/HS) GPS Technology Review (U/HS) Incident Response Review BUDGETED HOURS 255 255 252 255 252 INFORMATION TECHNOLOGY TOTAL 1,269 UNIVERSITY, HEALTH SYSTEM & INFORMATION TECHNOLOGY TOTALS 8,880 6 UNIVERSITY OF VIRGINIA BOARD OF VISITORS AGENDA ITEM BOARD MEETING: June 11, 2010 COMMITTEE: Audit and Compliance AGENDA ITEM: I.B. Corporate Compliance Project Schedule BACKGROUND: Ms. Strauss will present the proposed Corporate Compliance Project Schedule for the 2010-2011 Fiscal Year. The Schedule has been developed based on required work from state and external agencies, risk assessment models, requests from management, and analyses of work performed in prior years. ACTION REQUIRED: Approval by the Audit and Compliance Committee and by the Board of Visitors APPROVAL OF THE CORPORATE COMPLIANCE PROJECT SCHEDULE FOR FISCAL YEAR 2010-2011 RESOLVED, the Corporate Compliance Project Schedule for Fiscal Year 2010-2011 is approved as recommended by the Audit and Compliance Committee. 7 UNIVERSITY OF VIRGINIA BOARD OF VISITORS AGENDA ITEM UVA Health System Corporate Compliance and Privacy Office Determination of Hours Available for 2010-2011 Compliance and Privacy Activities Fiscal Year 2010-2011 TOTAL Total Hours Available 6,240 Less: Vacancies 0 Sub-Total 6,240 Professional Development 240 Leave and Holidays 880 Other Activities: Office and Personnel Administration 320 Hours Available for Compliance & Privacy Activities 4,800 Allocation of Hours Available for Compliance & Privacy Activities Fiscal Year 2010-2011 Hours Available for Compliance & Privacy Activities Consulting Education Special Projects Hours Available for Compliance & Privacy Projects Total 4,800 600 800 800 2,600 Corporate Compliance & Privacy Projects Fiscal Year 2010-2011 Projects Outpatient Department Coding, Billing, & Documentation Privacy Monitoring and Auditing End Stage Renal Disease Dialysis Governmental Payors (RAC, MIC, ZPIC) Inpatient Medicare Severity Diagnosis Related Groups Total 8 HOURS 400 800 400 400 600 2,600 UNIVERSITY OF VIRGINIA BOARD OF VISITORS AGENDA ITEM BOARD MEETING: June 11, 2010 COMMITTEE: Audit and Compliance AGENDA ITEM: II. Summary of Findings ACTION REQUIRED: None BACKGROUND: Ms. Deily will present a summary of findings on the following audit reports: the Medical Center Financial Screening Process and the Phantom Systems Review. The summary does not require formal action, but is information of which the Board should be made aware. 9 AUDIT DEPARTMENT EXECUTIVE SUMMARY Financial Screening Process January 21, 2010 BACKGROUND The Verifications Unit of Patient Financial Services (PFS) is responsible for processing financial screenings for patients who have no health insurance and do not qualify for local, state, or federal healthcare programs; or for patients who anticipate having difficulty paying their portion of the bill. The qualifications for financial assistance or charity care are based upon income and asset guidelines set by the Virginia Department of Medical Assistance Services (DMAS) each fiscal year in accordance with Federal Poverty Income Limits established by the Department of Health and Human Services. AUDIT OBJECTIVES The objectives of the audit were to determine whether the Medical Center (MC) was: (1) accurately evaluating and applying financial assistance criteria to patients’ applications; and (2) complying with new State legislation, Posting of Charity Care Policies, which became effective on July 1, 2009. OPINION ON AUDIT OBJECTIVES In our opinion, financial assistance criteria were being accurately evaluated and applied to patients’ applications in a timely manner. The average response time for the applications tested during the audit was three business days from receipt of all required documentation to disposition of the application. AREAS NOTED FOR IMPROVEMENT 1) 2) The Medical Center was not fully in compliance with recently enacted State legislation concerning the posting of charity care policies by all hospitals. Financial Verification Working Guidelines did not provide guidance about expectations on scanning or document review of financial screening related documents; as a result, documentation inconsistencies were noted in patients' verification files. 10 AUDIT DEPARTMENT EXECUTIVE SUMMARY Financial Screening Process January 21, 2010 MANAGEMENT’S RESPONSE Management concurs and has agreed to correct the identified condition. FINANCIAL IMPACT Implementation of suggested actions will position the MC to be in full compliance with enacted charity care legislation and improve efficiencies in the Verifications Unit. 11 AUDIT DEPARTMENT EXECUTIVE SUMMARY Phantom Systems Review January 21, 2010 BACKGROUND There are a large number of information technology (IT) systems in use at the departmental and school level at the University of Virginia and the UVA Health System. These IT systems are comprised of software and hardware, as well as ongoing support and maintenance. Paying for all of these various systems and services is very complex due to the large number of computers and software applications in use, as well as the variant lengths of service and support contracts in place. Some organizations around the country have determined through audits that they have been paying for IT resources that were either retired or little used. IT resources such as these are often referred to as phantom systems. AUDIT OBJECTIVES The Audit Department has completed an audit of phantom systems at the University and Health System for the fiscal year 2010 audit schedule. Our original audit objective was to determine whether or not UVA was paying for systems that were either sparingly used, or unused altogether. As the audit progressed, a second audit objective was added as the complexity of IT purchasing became apparent. This audit objective was to evaluate the policies and procedures for purchasing of system components, including hardware, software and services at UVA and the Health System. OPINION ON AUDIT OBJECTIVES Overall, the University and Health System appeared to do a sufficient job of removing systems from the books as the systems themselves are retired or removed. The only identified payments issued for unused systems in the audit were for telephone lines and this situation will be addressed in the next IT audit. However, there were several areas for improvement in the way that hardware, software, and related support services are procured at the University. Perhaps due to the decreased complexity of the purchasing process for a centralized environment, the Health System appeared to be less affected by the concerns noted in this audit. The Health System should however, take note of the weaknesses identified and the proposed improvements to avoid similar weaknesses and to participate in the improvement process when pertinent. 12 CRITICAL AREAS NOTED FOR IMPROVEMENT 1) 2) 3) Purchasing cards were not an accepted form of payment in UVA Marketplace. Employees were circumventing purchasing card controls by purchasing hardware or software from local-area businesses with personal cash or credit and then seeking reimbursement. An Information Technology Manager was paying approximately $13,000 per year for MacAfee antivirus software when a suitable alternative, Symantec Antivirus, was funded centrally at no cost to schools and departments. AREAS NOTED FOR IMPROVEMENT 4) 5) 6) Of the software available through ITC, there was no single repository to obtain it, with several disparate sources available. One school was maintaining their own Microsoft Campus Agreement, when strong consideration should be given to adjoining with the University’s Microsoft Campus Agreement. There was no ITC vendor presence within UVA Marketplace. MANAGEMENT’S RESPONSE Management concurs and has agreed to correct the identified conditions. FINANCIAL IMPACT TO THE UNIVERSITY AND HEALTH SYSTEM Inefficiencies in purchasing of hardware, software, support and maintenance could result in unrealized savings or revenue for the University and Health System. 13
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