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GAO-10-42R: 

United States Government Accountability Office: 
Washington, DC 20548: 

October 22, 2009:

The Honorable Max Baucus:
Chairman:
Committee on Finance:
United States Senate:

Subject: Indian Health Service: Updated Policies and Procedures and 
Increased Oversight Needed for Billings and Collections from Private 
Insurers:

Dear Mr. Chairman:

The Indian Health Service (IHS), an agency in the Department of Health 
and Human Services (HHS), provides health care services to American 
Indians and Alaskan Natives. For fiscal year 2009, Congress 
appropriated approximately $3.6 billion for health care services to be 
made available through IHS. The agency provides direct medical care, 
including primary care services, ancillary services, and some specialty 
services, through its network of facilities, including hospitals, 
health centers, and clinics.[Footnote 1] IHS also provides funding to 
direct care facilities that are operated by tribes. IHS headquarters 
oversees 12 area offices that cover 161 service units in 35 states.

The Indian Health Care Improvement Act of 1976, as amended, authorizes 
IHS to collect reimbursement for services provided at IHS facilities 
from third-party insurers, including Medicare, the federal health 
insurance program for elderly and disabled individuals; Medicaid, a 
joint federal and state health financing program for certain low-income 
families and individuals; and private health insurers.[Footnote 2] IHS 
is allowed to retain funds collected from these insurers without a 
corresponding offset against its appropriations, so that all revenue 
collected by a facility remains with that facility, supplementing its 
appropriations.[Footnote 3] For fiscal year 2008, IHS reported that it 
collected about $795 million from all third-party insurers, of which 
about $94 million, or 12 percent, was collected from private insurers. 
The remaining 88 percent was collected from the Medicare and Medicaid 
programs. According to IHS, these funds were used to purchase new 
medical equipment and medical supplies, and to provide compensation and 
benefits for IHS employees.

Given the importance of these collections to IHS's mission, you asked 
us to examine several areas related to IHS's billings and collections 
activities. Specifically, you asked us to review IHS's policies and 
procedures for writing off amounts owed to the agency by private 
insurers, internal control procedures related to billing and 
collection, and the amounts and reasons for denied claims and claims 
written off as uncollectible by IHS.[Footnote 4] Because IHS was unable 
to provide much of the information we requested on the amounts of 
denied and adjusted claims and amounts written off for more than 6 
months after our requests for these data, we agreed with your staff to 
provide you a report that examines (1) the design of IHS's policies and 
procedures for billing and collecting revenue from private insurers 
including write-offs of uncollectible claims, and (2) the adequacy of 
IHS headquarters' monitoring of area office and service unit compliance 
with policies and procedures for the billing and collection of revenue 
from private insurers.

To examine the design of IHS's policies and procedures for third-party 
collections, we identified key billing and collection policies and 
procedures related to private insurers contained in IHS's Indian Health 
Manual and its Revenue Operations Manual. We compared these policies 
and procedures to the Financial Systems Integration Office's (FSIO) 
standard business processes for administering and managing federal 
accounts receivables.[Footnote 5] We also obtained written responses to 
questions we developed and submitted to IHS officials in the nine area 
offices and nine nonstatistically selected service units to gain an 
understanding of the types of activities they were undertaking to 
comply with IHS policies and procedures for billing and collection. 
[Footnote 6] As agreed with your office, the scope of our review was 
limited to IHS-administered facilities because under federal law, 
tribally operated facilities are not generally subject to the policies, 
procedures, and reporting requirements established for IHS- 
administered facilities. Because IHS could not provide us with detailed 
transaction-level billing and collection data until more than 6 months 
after our initial data requests due to system limitations that are 
discussed later in this report, we were unable to conduct testing to 
determine whether IHS is actually complying with its policies and 
procedures. As a result and as agreed with your staff, this report 
covers the design of IHS's policies and procedures for billing and 
collecting revenue from private insurers, but does not assess 
implementation. To examine IHS headquarters' monitoring of area 
offices' and service units' compliance with billing and collection 
policies and procedures, we compared IHS headquarters' monitoring 
activities to those described in its policies and procedures and to 
GAO's Standards for Internal Control in the Federal Government. 
[Footnote 7] We interviewed senior IHS officials about the policies and 
procedures and their activities related to monitoring billings and 
collections. We also reviewed IHS's documentation of one of the five 
completed IHS on-site service unit compliance reviews as well as 
components of IHS's new Web-based "Third-Party, Internal-Controls 
Policy, Self-Assessment Audit Program." We did not assess the adequacy 
of monitoring activities performed by IHS's area offices and service 
units. Enclosure I provides additional details on our scope and 
methodology.

We conducted this performance audit from June 2008 through September 
2009 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives.

Results in Brief:

IHS has established policies and procedures for billing and collecting 
revenue from private insurers that are generally consistent with 
federal standard business processes for billings and collections. 
However, IHS had not updated them to reflect its recent implementation 
of HHS's new financial management system, Unified Financial Management 
System (UFMS). The new system entirely automated some previous employee-
administered activities. Outdated policy and procedure manuals increase 
the risk that management directives will not be met as well as the risk 
of noncompliance with federal regulations. Also, ORAP officials 
acknowledged that although IHS's debt management policies and 
procedures included some specific requirements for service units and 
area offices to develop debt management plans or programs, they 
provided no guidance on implementation of these requirements. 
Additionally, through interviews with service unit and area office 
officials that addressed debt management activities, we found that none 
of the area offices or service units we spoke with had developed and 
implemented these location-specific debt management plans. Some area 
office and service unit officials told us that they were developing a 
program or plan, while others said that they were using the Indian 
Health Manual, Part 9 "Debt Management" as their debt management 
policies and procedures, rather than developing separate programs or 
plans. Without well-defined debt management plans, area offices and 
service units may not be conducting debt collection activities in 
compliance with IHS's policies and procedures or federal regulations, 
and may not be maximizing collection of the amounts due from private 
insurers.

IHS headquarters' monitoring activities are inadequate to ensure area 
office and service unit compliance with billing, collection, and debt 
management policies and procedures. Although ORAP has been responsible 
for performing policy compliance reviews since 2005, ORAP officials 
reported that due to limited staff and the significant amount of time 
required for each on-site review, they have only completed reviews at 5 
of the 61 IHS-administered service units. They also reported that if 
deficiencies were found, ORAP would communicate their review findings 
to the service units and request corrective actions plans, but did not 
have the authority to ensure that corrective actions were developed and 
implemented. IHS has begun taking additional steps to increase its 
oversight of IHS-wide billing and collection by expanding ORAP's 
compliance review activities by implementing a new Web-based tool to 
monitor service unit policy compliance, ensuring access to billing and 
collection performance data contained in UFMS, and establishing direct 
line authority over area offices through the creation of a Deputy 
Director of Field Operations position. However, as currently designed, 
these initiatives have shortfalls. For example, the Web-based tool does 
not include questions on debt management activities, and IHS has not 
completed development of management reporting capability either through 
the Web-based tool or UFMS database. Full implementation of the current 
initiatives, along with additional data and reporting, would enable 
reporting to IHS management, including the Deputy Director of Field 
Operations, and enhance IHS's monitoring of its billing and collection 
activities. Until then, IHS management's ability to monitor area 
offices and service units will continue to be limited.

We are making four recommendations to the Director of IHS to help 
strengthen its management and oversight of billing and collection 
activities, including updating policies and procedures; developing 
additional debt management guidance, as needed; analyzing available 
data and further developing tools to monitor and manage billings and 
collections; and developing a risk-based approach using the information 
obtained from the new data sources to prioritize which service units 
receive future on-site compliance reviews.

We received written comments from HHS on a draft of this report 
(reprinted in their entirety in enclosure II). HHS agreed with the 
draft report and discussed actions IHS was taking to improve its 
monitoring of billings and collections at IHS headquarters. HHS also 
recognized the need for IHS to update its policies and procedures and 
outlined how IHS would complete this action. IHS also provided separate 
technical comments which we have considered and incorporated into this 
report as appropriate.

Background:

IHS operates a large decentralized health delivery system comprised of 
12 area offices, which include all or part of 35 states where many 
American Indian and Alaskan Native communities are located. The area 
offices provide guidance and technical support to the facilities in 
their area, which are organized into 161 service units. Each service 
unit may include federally or tribally operated hospitals, health 
centers, clinics, and other smaller health facilities.

IHS Business Revenue Cycle:

The IHS business revenue cycle consists of four major phases: patient 
registration, coding, billing and collection, and debt management (see 
figure 1).[Footnote 8] Complete and accurate reporting of data at each 
phase of the cycle is necessary for generating accurate billings, as 
well as collecting payments from insurers in a timely manner. Debt 
management occurs at the end of the business cycle, and refers to IHS's 
activities to collect amounts owed from insurance companies that have 
been outstanding more than 30 days including procedures for when the 
collection attempts are not successful. Typically, facilities perform 
all four phases of the business revenue cycle, while area offices and 
service units have primary responsibility for monitoring these 
processes.

Figure 1: IHS Business Revenue Cycle: 

[Refer to PDF for image: illustration] 

Registration: 
When a patient arrives, registration staff gather information for the 
patient’s record, including the patient’s identification, demographic, 
and third-party insurance coverage information. 

Coding: 
Coding involves documenting the provider’s description of disease, 
injury, and treatment in a standardized form which is used to generate 
a bill. 

Billing and collections: 
IHS bills the insurer for services provided and collects payment from 
the insurer. 

Debt management: 
IHS attempts to collect amounts not paid by insurers by sending follow-
up letters or referring the debt to private collection agencies. If 
collection attempts fail, the amount may be written off as 
uncollectible. 

Source: GAO analysis of IHS policies and procedures. 

[End of figure] 

To assist area offices and service units in managing the business 
revenue cycle, IHS developed and implemented the Resource and Patient 
Management System (RPMS) to provide comprehensive admissions, clinical, 
billing, and collection information on all health services provided at 
IHS facilities. RPMS is a computerized system that captures detailed 
patient-level transaction information, such as amounts owed from 
private insurers, as well as amounts collected. The detailed 
transaction information is then summarized and recorded automatically 
into UFMS, the primary financial management system for HHS. IHS fully 
implemented UFMS in October 2008.

Monitoring: 

IHS headquarters shares monitoring responsibilities with its area 
offices and service units. Part 5 of the Indian Health Manual delegates 
the primary responsibility for monitoring the day-to-day performance of 
billing and collection activities to the area offices and service 
units. In general, service unit business office staff use RPMS 
reporting to monitor billing and collection activities. They also 
monitor patient registration and coding activities in order to detect 
errors and backlogs that can delay billings and hinder collections.

The service unit Chief Executive Officer, or designee, performs 
evaluations and reviews these reports on a periodic basis. Some 
reports, such as those on patient registration, coding, billing, and 
the status of claims,[Footnote 9] are reviewed weekly while others, 
such as those on outstanding balances and deleted claims, are reviewed 
monthly. The reports are also forwarded to the area office, where 
officials review and summarize them, and provide feedback on 
performance to service unit and facility management, as well as 
recommend periodic follow-up and corrective action when needed. Within 
headquarters, ORAP was established in 2004 to provide leadership and 
direction to the area offices and service units to increase third-party 
revenue collections, and to monitor compliance with IHS policies 
governing business revenue cycle processes. In addition, ORAP is 
involved in providing leadership on payment policy in coordination with 
HHS, Centers for Medicare & Medicaid Services, and area offices. 
Further, ORAP is responsible for technical assistance to the area 
offices, IHS-wide training and consultation, hospital cost report and 
rate development, review of legislation and regulations that may impact 
revenue, and program technical support. As of July 2009, ORAP had five 
staff members.

Design of Policies and Procedures for Billing and Collection Is 
Generally Consistent with Federal Standard Business Processes, but Some 
Are Outdated, and Others Lack Necessary Guidance:

The design of IHS's policies and procedures for billing and collection 
activities--as reflected in Part 5 and Part 9 of the Indian Health 
Manual, and IHS's Revenue Operations Manual--is generally consistent 
with FSIO's standard business processes for managing federal accounts 
receivable, which include key processes related to the four phases of 
IHS's business revenue cycle.[Footnote 10] For example, FSIO specifies 
that there typically are triggering events that require establishing a 
receivable as well as processes for capturing, verifying, and reviewing 
customer information. Consistent with these expectations, IHS's 
policies and procedures include specific guidance on obtaining and 
verifying patient data at registration and for recording these data in 
RPMS.

Another FSIO expectation is that procedures exist for ensuring critical 
data elements are captured in the supporting documentation which are 
necessary to establish a receivable such as dates of performance, 
description of services, and amounts to be billed. Along these lines, 
IHS's polices and procedures include activities for the proper and 
complete coding of medical services and the billing of these services 
to private insurance companies. Another FSIO expectation is that 
agencies, on a periodic basis, determine the age of outstanding 
receivable balances and review the status of these outstanding accounts 
receivable balances. We confirmed that IHS's policies and procedures 
included requirements that periodic review, research, and follow-up 
action must be performed and properly documented. An additional FSIO 
expectation is that procedures exist for determining debts that are 
uncollectible and therefore should be written off. We identified that 
IHS's policies and procedures include a requirement that debts are 
written off when an authorized IHS official has determined, after using 
all appropriate collection tools, that the debt is uncollectible.

While generally consistent with FSIO, we determined that some of IHS's 
policies and procedures did not reflect current operations because they 
were not updated to reflect IHS's recent implementation of its new 
financial management system, UFMS, in October 2008. As a result, IHS 
policies and procedures include requirements that still refer to the 
previous financial management system, CORE, such as:

* area business office coordinators ensure that service unit data to be 
entered into CORE are submitted timely by service units;

* area office financial management officers ensure that all third-party 
accounting transactions are recorded timely in CORE's accounts 
receivable application; and:

* financial management officers should reconcile balances from the RPMS 
accounts receivable system with the CORE general ledger.

However, with the switch to UFMS, these routines have been mostly 
automated. For example, previously, data recorded in RPMS had to be 
summarized by the service units and then forwarded to the area offices 
where the data were manually recorded in CORE. With the implementation 
of UFMS, transaction data recorded in RPMS are automatically uploaded 
to a central UFMS database, then summary data are uploaded from this 
database into the UFMS general ledger and the manual recording is no 
longer necessary.

According to federal internal control standards,[Footnote 11] formally 
documented policies and procedures that are clear and readily available 
are an essential part of an agency's internal control system. They 
provide guidance to staff in the performance of their day-to-day 
activities; help to ensure that activities are performed consistently 
across an agency; communicate management's directives; and help ensure 
that the agency is in compliance with federal laws and regulations. 
These control standards require that policies and procedures be 
reviewed regularly and updated, when necessary. In discussions, the 
Director of ORAP told us that ORAP's goal is to perform in-depth 
reviews of relevant policies and procedures every 3 to 5 years. The 
officials said they plan to update Part 5 of the Indian Health Manual 
by the end of calendar year 2009 to reflect any changes in their 
operations and systems since the manual was implemented in calendar 
year 2005. Similarly, in 2010, they may update Part 9 of the Indian 
Health Manual and the Revenue Operations Manual, which were implemented 
in calendar years 2007 and 2006, respectively.

Because Parts 5 and 9 of the Indian Health Manual had not been updated, 
ORAP officials told us they conducted regional accounts receivable 
training during fiscal year 2009 to help address the differences 
between the guidance in the unrevised policies and procedures and 
actual practice due to switching to UFMS. We reviewed the training 
slides used in the sessions and noted that they covered the activities 
involved in IHS's business revenue cycle (registration, coding, 
billings and collections, and debt management), RPMS management 
reports, compliance with policies related to accounts receivable, debt 
management, and third-party internal controls. Nonetheless, policies 
and procedures that are not updated increase the risk that management 
directives will not be followed, as well as the risk that the agency 
may not be in compliance with federal regulations. For example, billing 
and collection data, if submitted to an area office, could potentially 
be recorded twice, which could affect the agency's financial records 
and financial statements.

We also found that while Part 9 of the Indian Health Manual included 
policies and procedures for managing and collecting debts owed to IHS, 
it also included requirements for area offices to develop area debt 
management programs and for each service unit to develop location- 
specific debt management plans. However, the policies and procedures 
did not include guidance on what should be included in either the debt 
management programs or plans, or how the area offices and service units 
would implement them. Additionally, the training provided by ORAP 
included guidance on debt management policies and procedures, but did 
not include guidance on what is expected or required in the location- 
specific debt management programs or plans. Location-specific debt 
management programs and plans help ensure that agencywide policies and 
procedures are implemented at specific locations with special 
considerations for the various operating environments of the area 
offices and service units.

When we discussed these particular requirements with ORAP officials, 
they agreed that the policies and procedures lacked the necessary 
guidance to allow the area offices and services units to implement 
location-specific programs or plans required by the policies and 
procedures. When we discussed debt management activities with officials 
from the nine IHS-administered area offices and nine of IHS's service 
units, none of them indicated that they had location-specific programs 
or plans in place. Some area office and service unit officials told us 
that they were developing a program or plan, while others said that 
they were using the Indian Health Manual, Part 9 "Debt Management" as 
their debt management policies and procedures, rather than developing 
separate programs or plans. Without well-defined debt management plans, 
area offices and service units may not be conducting debt collection 
activities in compliance with IHS's policies and procedures or federal 
regulations, and may not be maximizing collection of the amounts due 
from private insurers.

IHS Headquarters' Monitoring of Area Office and Service Unit Compliance 
with Billing and Collection Policies and Procedures Is Inadequate, but 
Initiatives are Under Way to Increase Oversight:

IHS headquarters' monitoring activities of area office and service unit 
compliance with billing and collection policies and procedures are 
inadequate, but agency officials told us they are taking steps to 
increase oversight. Federal internal control standards require agency 
management to conduct monitoring of program quality and 
performance.[Footnote 12] Part 5 of the Indian Health Manual requires 
the Director of ORAP to monitor area office and service unit compliance 
with IHS policies and procedures for billing and collecting revenue 
through IHS-wide policy compliance reviews and internal audits. Before 
implementing the Web-based tool, ORAP's monitoring of policy compliance 
had consisted of a small number of on-site compliance reviews at IHS 
service units and through regular meetings with field staff.[Footnote 
13]

Since the policy was implemented in 2005, ORAP has not conducted any 
area office reviews, and has conducted on-site compliance reviews of 
only 5 of the 61 IHS-administered service units--all of which were 
completed in 2007 and 2008. During the on-site reviews, ORAP assessed 
service unit compliance with key policies and procedures included in 
Part 5 of the Indian Health Manual. For example, ORAP determined 
whether the service unit was billing for outpatient services within 6 
business days from the date of service as required by obtaining and 
reviewing the data from specific RPMS reports to identify items of 
noncompliance. If there were any deficiencies noted during the review, 
ORAP communicated its findings and requested the service unit to 
develop and submit a corrective action plan to address them. However, 
ORAP officials told us they lacked direct authority over the service 
units to ensure that the corrective action plans were prepared or 
implemented. Additionally, ORAP officials told us that they were only 
able to accomplish the 5 on-site reviews because these reviews are time 
consuming and require significant staff resources to perform. These on- 
site reviews also did not assess compliance with IHS's debt management 
policies and procedures contained in Part 9 of the Indian Health 
manual. Therefore, ORAP lacked assurance that the service units were 
taking all required actions to collect outstanding debts from private 
insurers.

Federal internal control standards require that agency management 
conduct effective monitoring to assess program quality and performance 
over time and work to address any identified deficiencies.[Footnote 14] 
While ORAP had some limited processes for reviewing compliance with 
policies and procedures, we found that ORAP does not monitor actual 
performance of billing and collection activities. ORAP officials told 
us that IHS headquarters does not have access to RPMS to routinely 
monitor IHS-wide billing and collection data. This is a major 
limitation because they also have not been able to readily obtain 
detailed reports on area offices' and service units' performance on key 
business revenue cycle activities, such as amounts billed, amounts 
collected, amounts outstanding, and amounts adjusted or written off. 
However, Part 5 of the Indian Health Manual does not include 
requirements for ORAP, or any other office in headquarters, to collect 
billing and collection data from area offices and service units, and 
ORAP officials have not developed a process for routinely collecting 
and analyzing data on amounts billed, amounts outstanding, as well as 
debts that have been written off. On occasion, when prompted by 
internal or external requests, ORAP has called upon area offices and 
service units to submit detailed billing and collection data; however 
it does not request these data on a routine basis. In addition, ORAP 
cannot ensure that data are submitted in a timely manner because of 
system limitations and lack of authority. For example, when we asked 
ORAP officials for data on billing, adjustment, write-off, and 
collections related to private insurers covering all IHS facilities for 
fiscal years 2006 through 2008, officials told us they would need to 
contact each area office and service unit, who would then need to 
access the data from RPMS and forward them to IHS headquarters. For 
most of the requested data, ORAP required several months to provide the 
information to us.[Footnote 15]

To increase its oversight, IHS headquarters officials told us they have 
begun taking steps to expand ORAP's compliance review activities, 
ensure access to billing and collection performance data, and establish 
direct line authority over area offices. In April 2008, ORAP developed 
the "Third-Party, Internal-Controls Policy, Self-Assessment Audit 
Program," a Web-based tool to assess service unit compliance with the 
IHS's internal control policy and procedures on a more frequent basis 
than the on-site reviews allowed. The tool, modeled after the on-site 
review, contains questions on policies and procedures related to 
billing and collection. Each service unit is required to complete the 
tool on a quarterly basis and upload supporting documentation with its 
responses. Supporting documentation includes detailed billing and 
collection information, such as the aging account summary report used 
by the service unit to monitor outstanding accounts. ORAP officials 
told us that they plan to produce management reports from the Web-based 
tool to enhance operations and assess compliance with policies and 
procedures for billings and collections. As of August 2009, ORAP 
officials had not developed or produced these reports. Additionally, 
the Web-based tool does not include questions on key policies and 
procedures from IHS's debt management policy, Part 9, which includes 
procedures for following up on delinquent debt and writing off balances 
deemed uncollectible. As a result, ORAP's ability to monitor service 
unit compliance with IHS's debt management policy is limited.

To further increase its oversight, ORAP plans to monitor billing and 
collection data that are now captured in UFMS since its implementation 
in October 2008. According to IHS officials, the integration of RPMS 
with UFMS permits the consolidation of financial data across all IHS 
facilities to support timely and reliable financial reporting to IHS 
headquarters. ORAP officials told us that by the end of calendar year 
2009, they expect to begin producing management reports from the UFMS 
database to help them monitor performance of billing and collection 
activities. As of July 2009, ORAP had engaged a contractor to help it 
develop a plan for producing management reports from UFMS.

Additionally, IHS has established a Deputy Director of Field Operations 
position, which reports directly to the Director of IHS, to oversee 
area offices' compliance with policies and procedures for billing and 
collection by monitoring the performance of the area directors. 
Recognizing the need for increased oversight of the area offices, IHS 
gave the new Deputy Director of Field Operations position a direct line 
of authority over area office directors. As part of this 
responsibility, the new Deputy Director of Field Operations is expected 
to evaluate area office directors' performance. We verified that the 
area office directors' performance contracts contain performance 
measures related to compliance with policies and procedures for billing 
and collection and some contained performance measures for area 
offices' collection performance. While ORAP does not report directly to 
the new Deputy Director of Field Operations, IHS officials expect that 
the new Deputy Director of Field Operations will work closely with ORAP 
to communicate and enforce service unit corrective action plans for 
deficiencies, if any, identified by ORAP through its utilization of the 
Web-based tool. Per the Deputy Director of Field Operations position 
description, a major responsibility of the position will be to provide 
direction to area offices to ensure IHS policies are consistently 
applied in the field and that field operations and programs do not 
conflict with laws and regulations and HHS/IHS policy. As of August 
2009, IHS had not permanently filled this position, although there is 
currently an acting Deputy Director in place performing these functions.

Full implementation of the current initiatives, along with additional 
data and reporting, would enable reporting to IHS management, including 
the Deputy Director of Field Operations, and enhance IHS's monitoring 
of its billing and collection activities. Until then, IHS management's 
ability to monitor area offices and service units will continue to be 
limited.

Conclusions:

While the design of IHS's policies and procedures relating to its 
billings and collections from private insurers is consistent with 
federal standards, to remain useful these policies and procedures must 
be periodically evaluated to ensure that they are still relevant and up 
to date. Policies and procedures that include outdated processes that 
do not reflect IHS's current operating environment could lead to 
operational inefficiencies and errors in recording transactions that 
negatively impact IHS's program management and financial reporting. 
Further, the lack of complete guidance related to the location-specific 
debt management plans increases the risk that IHS offices and 
facilities will not consistently implement the debt collection actions 
necessary to comply with federal law or maximize the amounts collected 
and used to provide needed services.

Until recently, IHS headquarters had largely delegated its monitoring 
responsibilities for billing and collection activities to the area 
offices and service units and did not have direct or timely access to 
performance data to effectively manage the program. IHS headquarters 
has now focused increased attention on monitoring the billing and 
collection activities of its area offices and service units and has 
recently developed tools for collecting compliance and performance 
data. While these tools provide more data to IHS headquarters on 
billing and collection activities, the data captured by these new tools 
have not yet been analyzed and communicated back to management in a 
manner that would assist in monitoring compliance with IHS policies and 
procedures and improving agency operations and collection activity. 
Moreover, IHS has an opportunity to enhance the tools by considering 
other data sources and performance metrics to provide a more 
comprehensive assessment of service unit and area office debt 
management activities. Such enhancements could also be used to 
prioritize the on-site compliance reviews to focus on the units with 
the most risk using the data captured in these tools. These efforts can 
help IHS make decisions regarding the resources expended in its 
monitoring efforts based on the potential benefits of those activities 
based on risk.

Recommendations:

We recommend that the Director of IHS strengthen IHS's management and 
oversight of billing and collection activities by updating and 
providing additional guidance in the agency's policies and procedures 
for billing and collection from private insurers. As part of this 
effort, the Director of IHS should direct IHS officials to take the 
following actions:

* Review and update the outdated parts of the Indian Health Manual to 
reflect IHS's implementation of UFMS.

* Develop and establish location-specific guidance for implementing the 
requirements in Part 9 of the Indian Health Manual for area offices and 
service units to individually develop and implement debt management 
programs and operational plans, and direct the Area Office Directors 
and Service Unit CEOs to provide training at the local level to ensure 
the programs and plans are effectively implemented.

* Develop specific tools and reporting mechanisms to monitor and manage 
the business revenue cycle, including billing and collection, and debt 
management activities.

* Develop a risk-based approach using the information obtained from the 
new data sources (i.e., the UFMS database and Web-based tool) to 
prioritize which service units receive future on-site compliance 
reviews.

Agency Comments and Our Evaluation:

In written comments on a draft of this report (reprinted in their 
entirety in enclosure II), HHS stated that it agreed with the draft 
report and offered some comments that focused on steps being taken by 
IHS to improve its oversight over billings and collections. In 
particular, the letter discussed IHS's plans to use revenue reports 
from its new financial management system, UFMS, in conjunction with the 
new Web-based "Third-Party, Internal Controls Policy, Self-Assessment 
Audit Program" tool to improve monitoring of the third-party revenue 
program at IHS headquarters. HHS also recognized the need for IHS to 
update its policies and procedures and stated that IHS wanted to allow 
time to train staff on the new UFMS system, test new processes, 
evaluate those results, and make any additional changes that may be 
necessary before undertaking revisions to the policies and procedures 
in 2010. This is a reasonable approach and we encourage IHS to move 
forward expeditiously. Finally, HHS acknowledges that IHS had some 
initial implementation issues with UFMS and stated that the issues have 
now been resolved, which will allow IHS to focus on developing and 
producing the planned management reports. IHS provided separate 
technical comments which we considered and incorporated into this 
report as appropriate.

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution of it until 30 
days from the date of this report. We will then send copies to the 
Director of the Indian Health Services, appropriate congressional 
committees, and other interested parties. In addition, the report will 
be available at no charge on GAO's Web site at [hyperlink, 
http://www.gao.gov].

If you or your staff have questions about this report, please contact 
Kay L. Daly at (202) 512-9095 or at dalykl@gao.gov or Kathleen M. King 
at (202) 512-7114 or at kingk@gao.gov. Contact points for our Office of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made major contributions to this 
report are listed in enclosure III.

Sincerely yours, 

Signed by: 

Kay L. Daly: 
Director, Financial Management and Assurance:

Signed by: 

Kathleen M. King:
Director, Health Care: 

[End of section] 

Enclosure I: Scope and Methodology:

To examine the design of Indian Health Service's (IHS) key policies and 
procedures for billing and collecting revenue from private insurers, we 
obtained and reviewed the following sections of the Indian Health 
Manual:

* Part 5, Chapter 1 "Third-party Revenue Accounts Management and 
Internal Controls" dated March 3, 2006, which provides policies and 
procedures for establishing, documenting, and monitoring IHS's accounts 
receivable; and:

* Part 9, Chapter 4 "Debt Management" dated December 13, 2007, which 
establishes IHS policy, responsibilities, procedures to be followed for 
collecting debts owed to IHS, and writing off debts when they are 
determined to be uncollectible.

We also reviewed IHS's Revenue Operations Manual dated July 2006 which 
provides standardized policies, procedures, and guidelines for each 
task associated with the business revenue cycle activities of IHS 
facilities.

We compared IHS's documented policies and procedures with the Financial 
Systems Integration Office's (FSIO) standard business processes for 
administering and managing federal accounts receivables.[Footnote 16] 
We selected the FSIO standard business processes because they were 
developed to standardize common financial business activities and 
processes to ensure that financial managers assess programs and make 
decisions with timely and accurate data.[Footnote 17] We also 
considered GAO's Standards for Internal Control in the Federal 
Government.[Footnote 18] Further, we interviewed relevant IHS officials 
about the agency's policies and procedures for billing and collection 
including the Director of Office of Resource Access and Partnerships 
(ORAP), and the Director of the Division of Business Office 
Enhancement. We limited the scope of our review to IHS-administered 
facilities because under federal law, tribally operated facilities are 
not generally subject to the policies, procedures, and reporting 
requirements established for IHS-administered facilities. Due to 
systems limitations, IHS could not provide us with detailed transaction-
level billing and collection data in a timely manner. IHS required more 
than 6 months to provide the data we requested on the amounts of claims 
written off and adjusted and the reasons for those adjustments. As a 
result, we were unable to conduct testing to determine whether IHS is 
actually complying with its policies and procedures. Accordingly and as 
agreed with your staff, we limited our review to the design of IHS's 
policies and procedures over billing and collecting from private 
insurers, not their implementation. At the area office and service unit 
levels, we obtained written responses to questions we developed and 
submitted, and conducted follow-up interviews with 9 of the 12 IHS area 
offices, as well as the Chief Executive Officers, or their designees, 
of 9 of the 61 service units.[Footnote 19] At each level, we asked 
officials about the types of activities they typically undertake to 
comply with IHS's policies and procedures related to billing and 
collection.

To examine the adequacy of IHS headquarters monitoring of area office 
and service unit compliance with IHS policies and procedures for the 
billing and collection of revenue, including debt management, we 
evaluated IHS headquarters' monitoring activities using the policies 
and procedures contained in Parts 5 and 9 of the Indian Health Manual 
and GAO's Standards for Internal Control in the Federal Government. 
[Footnote 20] At IHS headquarters, we interviewed the Director and 
other officials within ORAP--whose responsibilities include developing 
policies and procedures for the agency--to ask them about the 
availability of billing and collection data and their monitoring 
activities. We also interviewed the acting Deputy Director of Field 
Operations. In addition, we reviewed IHS's documentation of one of the 
five completed IHS on-site service unit policy compliance reviews as 
well as components of IHS's new Web-based "Third-Party, Internal-
Controls Policy, Self-Assessment Audit Program." We also reviewed the 
performance contracts of area office directors for fiscal year 2009 to 
identify performance measures related to billing and collection 
activities. We examined the adequacy of monitoring activities at IHS 
headquarters, but did not examine the adequacy of monitoring at the 
area office or service unit levels.

We requested comments on a draft of this report from IHS. We received 
written comments from HHS on October 19, 2009, and have summarized 
those comments and our responses in the Agency Comments and Our 
Evaluation section of this report. We conducted this performance audit 
from June 2008 through September 2009 in accordance with generally 
accepted government auditing standards. Those standards require that we 
plan and perform the audit to obtain sufficient, appropriate evidence 
to provide a reasonable basis for our findings and conclusions based on 
our audit objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

[End of section] 

Enclosure II: Comments from the Department of Health and Human 
Services: 

Department Of Health & Human Services: 
Office Of The Secretary: 
Assistant Secretary for Legislation: 
Washington, DC 20201: 

October 19, 2009: 

Kay L. Daly: 
Director, Financial Management and Assurance: 
U.S. Government Accountability Office: 
441 G Street N.W. 
Washington, DC 20548: 

Dear Ms. Daly: 

Enclosed are comments on the U.S. Government Accountability Office's 
(GAO) report entitled: Indian Health Service: Updated Policies and 
Procedures and Increased Oversight by IHS Headquarters Needed for 
Billings and Collections from Private Insurers (GAO 10-42R). 

The Department appreciates the opportunity to review this report before 
its publication. 

Sincerely, 

Signed by: 

Andrea Palm: 
Acting Assistant Secretary for Legislation: 

Enclosure: 

[End of letter] 

HHS Comments to the Draft GAO Report GAO-10-42R: 

The Department of Health and Human Services agrees with the subject 
Draft Report. We offer the following general comments: 

1. In reference to the need for "Increased Oversight by IHS 
Headquarters," we are making improvements. The current initiative to 
access the Unified Financial Management System (UFMS) database will 
provide IHS wide revenue reports that Headquarters can use to monitor 
the revenue program in conjunction with the online Internal Controls 
Policy reporting tool. IHS will consider the development of a risk-
based approach to using the information obtained from the new data 
sources (i.e., the UFMS database and the Web-based "Third-Party, 
Internal-Controls Policy, Self-Assessment Audit Program" tool) to 
prioritize which Service Units receive future onsite compliance 
reviews. 

2. IHS recognizes that its policies and procedures must be updated. The 
accounts Receivable Module in UFMS and Subsidiary link to RPMS were not 
interfaced until October 1, 2008. With any transition of this 
magnitude, there is always a specified amount of time it takes to 
stabilize the new environment, train on new processes, test new 
processes, monitor and evaluate those results, and make any changes 
that may be necessary to ensure the validity of the data and outcome 
are stable. 

We are working expeditiously to update policies and operations affected 
by the implementation of this new system. This will be accomplished 
once implementation and testing of new processes are fully designed, 
and training is provided to all sites. The new policies are scheduled 
to be completed in 2010. Development and implementation of centralized 
reporting capabilities using the UFMS database is also scheduled to be 
completed in 2010. 

3. On page 14, paragraph 2, last sentence, "however, as of July 2009, 
ORAP had only taken an initial step of engaging a contractor to help 
them develop a plan for producing management reporting." IHS had on-
going discussions between the Finance Office and the UFMS contractor 
back in FY 2007 and FY 2008 regarding UFMS implementation and reporting 
capabilities. Challenges with UFMS implementation have been ongoing 
because the UFMS system required numerous changes and adjustments 
throughout the implementation process. We were unable to interface the 
billing program with UFMS in October of 2007 as planned because the 
system did not have the capacity to handle the volume. This issue has 
now been resolved as of October 1, 2009. 

[End of section] 

Enclosure III: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Kay L. Daly, (202) 512-9095 or dalykl@gao.gov:

Kathleen M. King, (202) 512-7114 or kingk@gao.gov:

Staff Acknowledgments:

In addition to the individuals named above, key contributions were made 
to this report by Phillip McIntyre, Assistant Director; Catina Bradley, 
Assistant Director; Carolyn Yocom, Acting Director; Jehan Abdel-Gawad; 
Devin Barnas; William Brown; Anthony Eason; Michael Grimes; Darryl 
Joyce; Drew Long; Kevin Milne; and Jasleen Modi.

[End of section] 

Footnotes: 

[1] Primary care services include medical, dental, and vision; 
ancillary services include laboratory, diagnostic imaging, and pharmacy 
services; and specialty care includes services provided by 
cardiologists, surgeons, and other physician specialists.

[2] 25 U.S.C. § 1621e(a). The act authorizes IHS to collect 
reimbursement for reasonable expenses incurred to the same extent that 
an individual or nongovernmental provider would be eligible to receive 
reimbursement. 

[3] 25 U.S.C. § 1621(b).

[4] A write-off is an accounting action that results in reporting a 
debt as having no value on IHS's financial statements and internal 
management reports. However, a write-off does not waive IHS's right to 
the amount in question and does not preclude IHS from pursuing debt 
collection. IHS also makes accounting adjustments to claims to reduce 
the outstanding balance for amounts that are not collectible from the 
private insurance companies such as for copayments, deductibles, and 
other amounts.

[5] FSIO, Financial Management Systems Standard Business Processes for 
U.S. Government Agencies (Washington D.C.: November 2008). FSIO assumed 
the standards-setting function of the Joint Financial Management 
Improvement Program, and has been tasked with developing standard 
business processes, data specifications, and business rules for core 
financial management functions to be adopted by all federal agencies to 
help federal agencies meet the objectives of the Federal Financial 
Management Improvement Act of 1996 and Office of Management and Budget 
Circular A-127.

[6] IHS is organized into 12 area offices, 9 of which support a total 
of 61 IHS-administered service units. Of the 3 remaining area offices, 
California and Alaska support only tribally administered service units. 
The Nashville area office supports tribally administered service units 
and one recently converted IHS-administered service unit for which IHS 
did not have data at the time of our request. 

[7] GAO, Standards for Internal Control in the Federal Government 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington 
D.C.: November 1999).

[8] GAO, Standards for Internal Control in the Federal Government 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington 
D.C.: November 1999).

[9] IHS's business revenue cycle policies and procedures cover revenue 
from both private insurers and government programs such as Medicare and 
Medicaid.

[10] Claims for medical services provided by IHS facilities are 
submitted to private insurance companies for payment. The private 
insurance companies make a determination on which services they cover 
and how much the reimbursement will be. In addition, in some cases they 
may decide not to reimburse the IHS facility for some or all of the 
billed items for various reasons such as the claim was not submitted 
within the allowed period of time as defined by the insurance company. 

[11] FSIO, Financial Management Systems Standard Business Processes for 
U.S. Government Agencies (November 2008).

[12] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].

[13] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].

[14] The Director of ORAP told us the office routinely facilitated 
monthly teleconferences and quarterly meetings with business office 
staff from the area offices and service units to discuss issues related 
to business revenue cycle activities. These meetings allow ORAP to 
disseminate information, discuss RPMS issues, and obtain service units' 
collection reports. However, the reports from these meetings have not 
been used to produce annual performance reports or used for programwide 
decision making. 

[15] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].

[16] In order to provide the requested data, ORAP officials designed a 
software program to extract the data from RPMS and instructed each of 
the 61 service units to install the software as it could not be done 
centrally. After installation, each service unit generated the required 
reports and submitted data to ORAP where they were summarized for our 
use.

[17] FSIO, Financial Management Systems Standard Business Processes for 
U.S. Government Agencies (Washington D.C.: November 2008).

[18] We did not assess the extent to which the FSIO standard processes 
reflect the appropriate implementation of applicable laws, regulations, 
or standards.

[19] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].

[20] IHS is organized into 12 area offices, 9 of which support a total 
of 61 IHS-administered service units. Of the 3 remaining area offices, 
California and Alaska support only tribally administered service units. 
The Nashville area office supports tribally administered service units 
and 1 recently converted IHS-administered service unit for which IHS 
did not have data at the time of our request. We interviewed IHS 
officials at the 9 IHS-administered area offices, including Aberdeen, 
Albuquerque, Bemidji, Billings, Navaho, Oklahoma, Phoenix, Portland, 
and Tucson area offices. Within each of the 9 areas, we generally 
selected on a nonstatistical basis the service unit with the largest 
outstanding accounts receivable balance and interviewed cognizant 
officials in these service units. 

[End of section] 

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