Pago Pago, AMERICAN SAMOA — The American Samoa Medicaid State Agency “needs additional policies and procedures” to be put in place as it currently “does not have an established policy review process,” according the agency’s Performance Audit report following an audit of fiscal years ending Sept. 30, 2022 by the Territorial Audit Office.

However, the Medicaid Agency — better known as the ASG Medicaid Office — agrees in part that “office operations” policies needed completion but argued that medical policies are in place as required by the federal government.

In part three of the audit report, Samoa News looks at this finding, in which TAO explained that the purpose of established policies is to ensure that: there’s no deviation from the planned course of action; lays out the framework and ensures that the segregation of duties is in place; and policies are very important for future planning.

“Such policies need to be supported by procedural guidance so that expectations of controls within the established policies and procedures are clear to staff,” TAO report explained.

It also says that the TAO audit found that the Medicaid Agency, which is part of the Governor’s Office - has not updated nor reviewed some of its policies. For instance:

•           Agency has an outdated and incomplete procurement policy.

•           There are no clear and documented policies for the administration of payroll-related activities.

•           There is no clear and documented policy on managing of the Agency's assets.

“The absence of formally approved policies and procedures exposes the Agency's operations to potential risks of self-dealing, potential misuse of authority and power and abuse going undetected,” TAO points out.

“As with many of the issues noted with the Agency, the common cause is shortage of staff to administer a multi-million-dollar program as well as unplanned shift in priorities due to government COVID-19 response efforts,” TAO auditors said.

TAO recommends that the Medicaid Agency's management prepare and establish written policies and procedures. Where necessary, the Agency can request training from relevant departments to confirm the alignment of internal policies to relevant ASG policies.

“These policies shall be reviewed and updated to ensure they are consistent with best business practices,” said TAO.

In its response, Medicaid management said it agrees “in part” with this finding “but wishes to distinguish some facts.”

Medicaid explained that there are two categories of policies and procedures that the Medicaid Office have put into place; policies and procedures for the execution of "program administration" and "office operations."

Additionally, there are program administration policies and procedures focused on medical services that are currently in place and reviewed by the U.S Centers for Medicaid and Medicare Services (CMS) as part of ensuring the effective delivery of services covered under the Medicaid State Plan.

For example, the Off-island Medical Referral service has rigorous policies and procedures in place to effectuate the allowable provisions under the Medicaid StatePlan.

And the principles behind these policies and procedures are to prevent fraud, waste and abuse and to ensure equitable access to Medicaid services.

“We agree in part that it is the "office operations" policies and procedures that are in need of completion — these focus on the overall operations of the office administration like facilities, equipment, personnel, purchasing, although they are defined and are functionally in use--the office needs to update these documents, finalize and adopt them officially. Staff need to be informed and regularly trained on these office policies and procedures,” said Medicaid management.

Medicaid also said that it agrees that the shortage of staff, external demands on the office and low-level priority on these tasks have contributed to their incompletion.

“Medicaid will prioritize the completion of these internal policy development tasks and we welcome collaboration with other agencies including the Auditors Office to align our internal policies to the applicable ASG policies,” said management.