Continuing Care Retirement Communities
Learn how the AI-generated research projects were createdOverall Conclusion
The audit identifies significant non-compliance with state statutes governing CCP registrations and continuum-of-care verification, resulting in substantial revenue losses to the Quality Care Assessment fund and increased reliance on State General Funds. It recommends substantial governance reforms, stronger verification of continuum of care, improved data sharing across KDADS, KDOI, and CMS, and updated statutory language to prevent improper CCP registrations and misapplication of QCA rates.
Source Document
Audit Scope
The scope included all CCP registrations processed by the Kansas Department of Insurance (KDOI) from July 1, 2020 through August 31, 2023, with subsequent analysis of Quality Care Assessment (QCA) rates applied to CCRCs by KDADS for SFYs 2021-2024. The audit compared CCP registrations to QCA rates, reviewed CCP application files (including disclosures, continuing care contracts, annual CPA audits, and ownership changes), analyzed bed occupancy and Medicaid bed-day data, and cross-referenced KDADS bed tax/QCA data with KDADS Adult Care Directory, KDADS Bed Assessment, KOTA, CASPER, CMS data, and KDADS’ reporting. The analysis was organized into three population groups: Population 1 – incomplete CCP applications approved; Population 2 – registered CCPs with no evidence of continuing care services; Population 3 – resident capacity changes resulting in reduced QCA rates. The audit period for CCP registrations was 7/1/2020–8/31/2023, and QCA rate determinations covered SFYs 2021-2024 (7/1/2021–6/30/2024 to match fiscal year calendars). It also included estimated financial losses from incomplete CCP registrations, reduced QCA rates, and associated interest, totaling tens of millions of dollars.
Key Findings Summary
Non-Compliance with State Statutes by CCP Registrations (K.S.A. 40-2231 through 40-2238) leading to misissued CCP registrations and substantial loss of Quality Care Assessment (QCA) revenue and related interest earnings; instances include missing CPA audits, backdated certificates, and late filings during 7/1/2020–8/31/2023.
KDADS missed opportunities to verify continuum of care for CCRCs; reliance on CCP registrations without verifying actual continuum of care; recommendations to update statutes and verification processes.
Discrepancies between KDADS reporting of CCRCs and CMS reporting; SNFs identified as CCRCs to KDADS but not to CMS; recommendation to integrate data across KDOTS/KOTA/CASPER/CMS data systems to ensure consistency.
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AI-Assisted
AI Scope Summary
The audit aimed to determine whether (1) the legislative framework permits CCRCs to falsely claim CCP status, (2) procedures exist to monitor CCP registrations and renewals, and (3) practical measures can reduce fraud, waste, and abuse of state funds and preserve federal matching funds, focusing on CCP registrations processed from July 1, 2020 through August 31, 2023 and QCA rate determinations for SFY 2021-2024.
AI-Generated Insight
This Kansas OMIG audit highlights systemic governance and data-integrity gaps across Medicaid program oversight, revealing that misclassification of CCRCs and weak verification of continuing care arrangements allow substantial mispayments under the Quality Care Assessment. The findings underscore the importance of cross-agency data integration (KDADS, KDOI, CMS) and clear statutory definitions to prevent fraud, waste, and abuse, and to safeguard federal matching funds. The report also demonstrates how outdated or ambiguous statutes can enable improper billing and revenue losses, suggesting a path toward reform through statute updates, governance realignment, and enhanced audit controls.
Audit Objectives
Are there currently issues within the legislative language that are allowing these facilities to falsely claim they are a part of a CCRC?
Are there currently proper procedures in place to monitor compliance within the CCRC and CCP registrations and renewals?
Are there measures that can be taken to stop potential fraud, waste, and abuse of State funds and loss of potential Federal matching funds?
Audit Findings (7)
Non-Compliance with State Statutes by CCP Registrations (K.S.A. 40-2231 through 40-2238) leading to misissued CCP registrations and substantial loss of Quality Care Assessment (QCA) revenue and related interest earnings; instances include missing CPA audits, backdated certificates, and late filings during 7/1/2020–8/31/2023.
KDADS missed opportunities to verify continuum of care for CCRCs; reliance on CCP registrations without verifying actual continuum of care; recommendations to update statutes and verification processes.
Discrepancies between KDADS reporting of CCRCs and CMS reporting; SNFs identified as CCRCs to KDADS but not to CMS; recommendation to integrate data across KDOTS/KOTA/CASPER/CMS data systems to ensure consistency.
Economic analysis showing SNFs at the reduced QCA rate may still incur greater annual costs than expected; recommendation to adjust QCA rate structure and define small SNF parameters to encourage maintaining beds.
Centralized bed count responsibility at KDADS raises risk of inaccuracies; recommendation for onsite inspections within 30 days of bed count changes and to document in KOTA and CMS.
Unnecessary CCP registrations processed due to statutory language; recommendation to limit CCP registrations to SNFs not defined as small or high Medicaid volume and that participate in CCRCs with continuum of care.
Increasing reliance on SGF as QCA revenue declines; recommendation for yearly QCA revenue/expenditure analyses and enhanced QCIP reporting.
Recommendations (7)
Reassign CCP registration oversight from KDOI to KDADS Survey Certification & Credentialing (SCC) and update statutes accordingly; continue QCA processing within KDADS LTSS.
Require CCP registration processing staff to have CPA or equivalent accounting expertise to identify red flags in financial documentation.
Update KDADS SNF change-of-ownership procedures to verify continuum of care and route CCP registrations appropriately; ensure 90-day filing for ownership changes and share information across KOTA, Bed Assessment, and CASPER.
Allocate sufficient staff for CCP processing and ensure access to KOTA, Bed Assessment, and CASPER databases to manage QCAs accurately; provide cross-agency data sharing.
Implement quality controls to review incomplete CCP applications and ensure accurate annual QCA determinations for all SNFs.
Align CCP registration timelines with cost reporting cycles to minimize year-round CCP maintenance and ensure documentation aligns with QCA periods.
Conduct annual analyses of QCA revenue and expenditures and incorporate findings into QCIP reporting to guide policy adjustments.