Review of Mutual of Omaha's Internal Controls to Prevent PIP Providers From Receiving Dual Payments

The objective of our review was to determine whether Mutual had adequate controls to ensure PIP providers had not received dual payments.  Dual payments occur when a provider receives PIP and claims payments from the Medicare program for the same services, resulting in an overpayment to the provider.  We found that the quarterly procedures to detect dual payments were adequate.  However, we did not always find evidence that Mutual's auditors had performed the dual payment detection procedure.  We recommended that Mutual follow their procedures to detect dual payments and complete the dual payment verification worksheet for all cost report settlements of PIP providers.  Mutual acknowledges that the cost report settlement files did not consistently contain documentation which verified that the dual payment detection procedure was performed.   The dual payment verification worksheet has been added to Mutual's tentative settlement worksheet templates.  Additionally, Mutual has incorporated the dual payment verification worksheet into the standardized interim payment worksheets.