Department of Justice (DOJ) Inspector General Michael E. Horowitz announced today the release of a report examining a $65 million Federal Bureau of Prisons (BOP) contract with Correct Care Solutions, LLC (CCS) for comprehensive medical services at the Federal Correctional Complex in Coleman, Florida (FCC Coleman).
The DOJ Office of the Inspector General (OIG) found that:
- BOP Should Ensure Prices are Properly Approved Before Authorizing Payment. The FCC Coleman contracting officer’s representative inadvertently approved prices billed for out-of-network services and services not covered by Medicare pricing without the proper authority. As a result, the BOP paid CCS $822,888 for out-of-network services and services not covered by Medicare pricing and $4,125 for unauthorized cancellation fees without proper approval of the prices.
- CCS Used Improper Billing Rates. CCS did not always submit properly priced invoices for onsite optometrist and general physician services as required by the contract. As a result, the BOP made improper payments to CCS totaling $95,358.
- BOP Should Define Proper Invoices and Promptly Return Improper Invoices. FCC Coleman did not return CCS’ improper invoices within 7 days as required by the Prompt Payment Act. Instead, BOP billing clerks reviewed the improper invoices and expended additional time to research the correct rates for services performed before correcting and approving partial invoices for payment. The additional time required to process the improper invoices resulted in missed deadlines under the Prompt Payment Act and triggered penalties on payments not made within 30 days. As a result of this practice, the BOP paid $97,089 in penalty interest to CCS.
- BOP Should Establish a Government Quality Assurance Surveillance Plan for use in Verification of Services Provided. The BOP had not established a government contract quality assurance surveillance plan to monitor the services provided by CCS as required. Consequently, the BOP was not able to ensure that services provided by CCS met the contract requirements.
Today’s report makes 13 recommendations to assist the BOP in establishing controls to prevent and detect CCS’s noncompliance with the terms and conditions of the contract. The BOP agreed with all 13 recommendations.
In December 2018, CCS changed its name to Wellpath, LLC but continued to operate as CCS for all BOP contracts.