July 31, 2009

MEMORANDUM FOR ALL RSB STAFF

FROM: Mike Merrick, Assistant Deputy Director

SUBJECT:  Backdated Authorizations

During the district supervisor meeting in May the practice of back-dating authorizations was raised by the bill-paying unit at State Office. It was reported that some authorizations were being submitted as backdated that were written several months after the approval was given for the expense, some were being co-signed by the district supervisor, some were not and some seemed to be written to authorize services that were not known to RSB at the time the service began (without even verbal authorization by the counselor).  There seemed to be considerable confusion as to what constitutes a "backdated" authorization.  With the coming implementation of System 7 this confusion could become an enormous problem, as there will be limits on how long a counselor may authorize a service after the date the service begins.

The first principle of authorizations is that a service must be authorized before it begins.  Chapter 5 of the VR Policy Manual specifies that RSB will not pay for any service that is not authorized in advance.  In many cases that authorization will be done verbally (for example, in the instance of a counselor authorizing a specific service on behalf of a client over the telephone with a PVA facility) but it should immediately be recorded in the case narrative so there is a record of what was actually (verbally) authorized. The authorization form should then be completed as soon as possible, but must have an issue date prior to the actual start date of services. 

Next, authorizations should not be written after the fact in order to match a specific invoice amount. It is sometimes impossible to be absolutely accurate in estimating service costs while completing the authorization, as invoiced amounts may vary from projections done prior to the service.  In those cases, the authorization should be as accurate as possible, but completed with the understanding that it serves as an estimate.     

Following a verbal authorization, or when any authorization is given that must be typed and processed prior to providing to a vendor, allowances must be made for processing time that is necessary to get the authorization form typed, printed and signed by the staff member responsible. These are NOT back-dated authorizations; they are simply "post-dated" authorizations in that they are being typed up after the authorization has been given (i.e. verbally). In our current paper-based system, the rehabilitation assistant typically types the authorization form from information provided by the counselor or teacher. 

In order to prepare our system of authorizations for the switch over to System 7 (which will have a time limit on how many days after the fact an authorization may be entered), we would like to establish the following procedures and limits for preparing authorizations:

1.  A counselor or teacher may sign an authorization for up to 15 calendar days following the service start date (with the exception of services started just prior to the end of a federal fiscal year, September 30th…in order to authorize these services, the authorization must be submitted to State Office prior to COB on September 30th).   

2.  Any authorization that exceeds the normal processing time (15 calendar days following the service start date) will require an approval signature by the district supervisor.

3.  Any authorization written more than 30 calendar days after the service start date will require an approval signature by both the district supervisor and the supervisor of field operations. 

A final category of authorizations must be discussed here; authorizations done for services that RSB was not aware of at the time the service started.  As several supervisors noted, sometimes a client does not keep his/her counselor informed about their schedule or registration, leading to the client’s attending classes, sometimes for several weeks/months prior to informing the counselor.  These are not "post-dated" authorizations...they are authorizations without prior approval. 

In the event that a client requests that you authorize a service that was begun without prior approval, that authorization must go through the exception process outlined in Chapter 26 of the VR policy manual (for approval by the Deputy Director). Such an exception must contain information that shows that: 1) the service requested is a planned IPE service; and, 2) that the case manager agrees that the service would have been provided if they were informed by the client in a timely manner. 

The procedures outlined above will be included in the appropriate policy manuals on-line within the next 30 days; however, they should be implemented immediately upon receipt of this memorandum. 

Please direct any questions regarding this matter to Mike Merrick by reply e-mail or phone at (573) 751-4989.

MM