CONCORD — An ongoing review of nonprofit agencies that collectively receive millions of dollars in state and federal funding to combat the opioid addiction crisis shows that these boot-strap operations have a long way to go to meet state standards for financial controls and contract compliance.
Recently completed site reviews by state officials of two Nashua-based organizations — Harbor Homes and Keystone Hall — resulted in multiple recommendations for improvement if the agencies expect to continue to receive state contracts.
Among other things, reviewers found that in some cases the nonprofits were unable to provide backup documentation for charges to the state; did not adequately document client progress or lack of progress; did not maintain adequate personnel files; and did not have adequate training or personnel policies.
As the addiction crisis worsened over the past five years, new nonprofits were launched and existing ones expanded to meet the ever-growing demand for counseling and recovery services. But some struggled to keep up with patient record-keeping, accounting, human resource policies and the state’s paperwork requirements.
Late last year, Serenity Place, a longtime addiction counseling center, had to be taken over by the state and placed under the control of another nonprofit agency when it ran into financial problems.
HOPE for Recovery New Hampshire, which rapidly expanded from one center in Manchester to five statewide, recently had to retreat from Claremont and Concord.
As concern grew over the ability of these organizations to effectively manage the millions of dollars flowing their way, the state Department of Health and Human Resources stepped up its performance audits of the agencies, and in some cases asked the Executive Council to hold off on further grants until the agency reviews were complete.
“There are a lot of new organizations, and there are existing organizations that had expanded very rapidly. And so, there are issues,” DHHS Commissioner Jeffrey Meyers told the governor and council in late June, as it delayed action on a grant for Harbor Homes.
The site reviews for Harbor Homes and Keystone Hall (Greater Nashua Council on Alcoholism), released on Tuesday, came after the first site review, Hope for NH Recovery, was released in March. More agency reviews are expected in the weeks ahead.
The DHHS team visited Keystone Hall offices on Feb. 15-16. “The reviewer found a lack of internal controls leading to four instances of questioned costs where the contractor did not have or did not submit backup documentation related to charges to state contracts,” according to the report.
The reviewers also examined 14 client files and found some treatment plans that were developed with no client involvement. “All treatment plans must show evidence that the client was involved in identifying, developing and prioritizing goals, objectives and interventions,” according to the state report.
The report also noted, “Of the 14 records reviewed, most had no consent or coordination with the primary care provider, and no coordination with mental health.”
The DHHS team visited Harbor Homes offices on Jan. 24-25, and found a similar lack of backup documentation for “numerous charges” to state contracts.
Two programs managed by Harbor Homes — a Housing Bridge Subsidy Program and a Mobile Crisis Response Team — were cited separately in the report.
In the case of the housing subsidy program, the state found “a lack of documentation in client records to demonstrate that all individuals being served are eligible,” while the Mobile Crisis Response Team suffers from “a lack of coordination with local community partners.”
The agencies are given the opportunity to respond to each recommendation, and in most cases indicate they have already implemented the changes suggested, or plan to in the near future. In some cases, the agency response attributes the problem to a miscommunication or misunderstanding between the agency and the state.
HOPE pushes back
One exception is the HOPE for NH response to the state’s demand in March that it develop billing practices and staff credentials that will enable it to bill Medicaid for services “in accordance with contract provisions.”
That would require HOPE for NH to hire licensed clinicians, which breaks from its “peer counseling” model in which many counselors are themselves in recovery.
“We have unequivocally stated that (Medicaid billing) is wholly inconsistent with the authentic peer-to-peer services that we provide,” according to HOPE officials. “This is one recommendation that HOPE will not be able to accommodate.”