Audit Report - Hillsborough CHD

Mark H. Boehmer, C.P.A.

Informations

• Publié par: Shiem
• Nombre de lectures: 39
• Langue: English

Extrait

OFFICE OF THE INSPECTOR GENERAL
INTERNAL AUDIT

Purchases, Distributions, and
Dispensing of Pharmaceuticals at
Hillsborough County Health Department

AC-07-006 November 7, 2007

the Status of Prior Review Findings SUMMARY
section of this report). DOH’s executive
office at that time took a stern approach We performed an audit of controls
to address identified weaknesses in the established by Hillsborough County
internal control system over Health Department (CHD) related to the
pharmaceuticals. Generally, DOH movement of controlled substances
management placed responsibility of during the period July 1, 2005 through
such controls and processes squarely June 30, 2006.
with CHD upper level management,
including the pharmacy manager and Our objective was to determine the
CHD business manager. DOH’s written extent to which controls are in place at
policy was subsequently updated to the Department of Health (DOH)
reflect these responsibilities and (including CHDs) so that sites under its
processes. Issues identified by the Office control can accurately account for
of the Auditor General in 2004 were still controlled substances.
found during this examination.
DOH’s public health system includes
The following issues should receive dispensing pharmaceuticals to CHD
additional review by Hillsborough CHD clients by medical staff, a licensed
management: pharmacy operated by the CHD or
● Some pharmaceuticals were missing contracted provider. Some CHDs with a
and unaccounted for; licensed pharmacy also dispense
● Actual ending inventories did not pharmaceuticals to persons that are not
agree with amounts reported and CHD clients for prescriptions written by 1input into FLAIR ; licensed physicians not related to the
● Adjustments to inventory were not CHD or DOH.
supported by sufficient
documentation; Central Pharmacy, CHDs, and A.G.
● Pharmaceuticals were not timely Holley Hospital purchased
counted at some pharmacies; and, pharmaceuticals totaling $129,569,929
● Purchases of Pharmaceuticals were from Cardinal Health, Inc. during the 2not coded to correct OCAs in fiscal year ended June 30, 2006. 1FLAIR , and did not accurately reflect
the programs for which these We conducted this audit in part, because
pharmaceuticals were purchased. we wanted to update the agency on the
status of corrective action taken by
CHDs as a result of a 2004 audit
performed by the Office of the Auditor
1 Florida Accounting Information Resource General, Pharmaceuticals at County
Subsystem Health Departments (You may refer to 2 Other Cost Accumulators
Page 1 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

during the period July 1, 2005 through INTRODUCTION
June 30, 2006.
3 Florida law charges DOH’s Office of the
Our objective was to determine the Inspector General responsibility to
extent to which controls are in place at provide a central point for coordination
DOH (including its CHDs) so that sites for activities that promote accountability,
under its control can accurately account integrity and efficiency in government.
for all purchases, transfers, returns, and Audits are conducted to review and
the filling of prescriptions of controlled evaluate internal controls necessary to
substances. ensure the fiscal accountability of DOH.

To obtain an understanding and This audit was initiated as the result of a
document the components of internal prior internal audit in which we identified
control related to controlled substances, a number of contracts where CHDs
we interviewed appropriate personnel at appeared to be selling pharmaceuticals
Headquarters and Hillsborough CHD. to outside entities, including hospitals.
We reviewed applicable law and DOH We also wanted to update the agency on
policies and procedures. We the status of corrective action taken by
documented our understanding of CHDs as a result of an Operational Audit
internal controls and tested selected performed by the Office of the Auditor
controls to determine whether the General in 2004, Pharmaceuticals at
controls were in place and working County Health Departments, (Please
effectively. refer to the Status of Prior Review
Findings section of this report).
COMPLIANCE WITH GENERALLY ACCEPTED
GOVERNMENT AUDITING STANDARDS Audit fieldwork took place December
2006 through May 2007 at DOH
headquarters in Tallahassee, and We conducted this performance audit in
included on-site examination at accordance with generally accepted
4Hillsborough County Health Department government auditing standards, in
5in February 2007. The audit was accordance with Florida law . Those
conducted by Office of the Inspector standards require that we plan and
General audit staff Mark H. Boehmer, perform the audit to obtain sufficient,
C.P.A., Management Analyst, Level 4, appropriate evidence that provides a
Lead Auditor, under the supervision of reasonable basis for our findings and
Lynn H. Riley, C.P.A., Director of conclusions based on our audit
Auditing. objectives. We believe that the evidence
obtained provides a reasonable basis for
our findings and conclusions based on SCOPE, OBJECTIVES, AND METHODOLOGY
our audit objectives.
We examined controls established by
BACKGROUND the Bureau of Statewide Pharmaceutical
Services, and Broward, Duval, and
Hillsborough CHDs related to the DOH’s public health system includes
movement of controlled substances, dispensing pharmaceuticals to CHD
(which may include purchases, transfers,
returns, and the filling of prescriptions)
4 2007 revision of Government Auditing
Standards, Comptroller General of the
United States
3 5 Section 20.055, Florida Statutes Section 20.055(5)(a), Florida Statutes
Page 2 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

clients. This may include prescriptions data obtained from Cardinal Health, Inc.,
dispensed by Central Pharmacy in the following purchases of Schedule 2
Tallahassee and shipped to a specific pharmaceuticals were made by these
client at the CHD. Pharmaceuticals are entities for the period July 1, 2005
also received by CHDs in bulk from through December 31, 2006:
Central Pharmacy to be dispensed by
Entity Purchase of medical staff at the CHD.
Schedule 2 Pharmaceuticals are typically also
Controlled purchased at the CHD level and
Substances from
dispensed by either medical staff at the Cardinal Health, Inc.
CHD or (in larger CHDs) a licensed Duval CHD $25,211
pharmacy operated by the CHD or a Hillsborough CHD 8,831
CHD contracted provider. Some CHDs TOTAL $34,042
with a licensed pharmacy also dispense
No instances of fraud, illegal acts, pharmaceuticals to persons who are not
CHD clients for prescriptions written by violations of provisions of contracts or
grant agreements, or abuse were noted. licensed physicians not related to the
CHD or DOH.
We concluded that controls are not
sufficiently in place at the selected CHDs We obtained data from Cardinal Health,
Inc. (a wholesale distributor of examined so that sites under its control
can accurately account for purchases, pharmaceuticals) documenting all
purchases made related to the State of distributions, and dispensing of
prescriptions of controlled substances. Florida’s contract with that vendor for the
period July 1, 2005 through June 30, There are specific controls that were
previously identified by the Office of the 2006. Total purchases of
Auditor General that continue to not be pharmaceuticals and related supplies
(this includes federal, state, and local sufficiently addressed by CHDs.
funding) made by DOH and its CHDs
from Cardinal Health, Inc. are detailed The following findings and
recommendations address issues that below:
have not been appropriately addressed
Facility Purchases of and should receive additional review by
pharmaceuticals and management.
related supplies from
Cardinal Health, Inc.
FINDINGS, RECOMMENDATIONS, AND Central Pharmacy $98,643,510
Hillsborough CHD $5,436,379 MANAGEMENT’S RESPONSES AND
Broward CHD $5,201,390 CORRECTIVE ACTION PLANS
Duval CHD $3,035,325
All other CHDs $16,455,054
FINDING 1 – Some pharmaceuticals were A.G. Holley Hospital $798,271
missing and unaccounted for. TOTAL $129,569,929

We focused our examination on Central There should be documentation to
Pharmacy in Tallahassee, and 3 CHDs support every transaction of a Controlled
which operate licensed pharmacies. Substance, including purchases,
Each of these entities handled Schedule dispensing, returns to the Reverse
3 through Schedule 5 Controlled Distributor, transfers to/from entities
Substances. Only 2 entities handled a under common control, and other
material quantity of Schedule 2 adjustments (as required). Those
Controlled Substances. According to transactions should reconcile from the
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