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.