Audit Preparation

🔍 Audit Overview - What is Needed for Individuals & Your Home When an Audit Occurs

📌 Purpose of Audits and Documentation Reviews

Audits help ensure Sunny Haven remains in full compliance with DBHDS regulations, Medicaid waiver requirements, and internal agency quality standards that govern the delivery of services across both Residential and Community Engagement programs. These audits are not only about regulatory checks—they reflect the agency’s commitment to high-quality, person-centered care that is consistent, documented, and meaningful.

Accurate and timely documentation plays a vital role in this process. It serves as the official record of the services we provide, the needs we address, and the outcomes we help individuals achieve. It also protects the rights of those we support, ensures that services align with each individual’s plan, and provides justification for Medicaid billing. Incomplete or outdated records can result in serious compliance issues, delayed reimbursements, or penalties from oversight bodies.

To remain audit-ready at all times, all required documentation must be uploaded in Lauris under the individual’s Active File for the correct service (Residential Services and/or Community Engagement/Sunny Day).

Consistent review of documentation and routine file maintenance are essential practices that support audit preparedness, service transparency, and accountability. Every staff member and provider has a role in upholding these standards to ensure individuals receive the safe, supportive, and rights-based services they deserve.

🔍 What Are Audits?

Audits are formal evaluations that check whether we are following federal, state, and internal requirements while providing person-centered support.

Types of Audits:

Audit Type                    Conducted By                                Frequency                            Focus                                                                      

DBHDS Licensing Audit     DBHDS Office of Licensing             Every year or as needed   Licensing compliance, documentation, ISPs, safety

HCBS Waiver/MES Audit    DMAS/MCOs/CMS-authorized bodies     Random or Annual                   Billing justification, timeliness, and support documentation

QSR Audit                     DBHDS QSR Team                             Every 2–5 years                           Service quality, health and safety, community inclusion

Corrective Action Review    DBHDS/Internal Leadership             As needed                                   Response to previous concerns or citations

🧾 What Auditors Look For

Regardless of type, audits focus on a core set of documentation standards that apply to all providers and staff. These standards are designed to ensure that records accurately reflect the services being delivered, are aligned with each individual's needs, and comply with all federal, state, and Medicaid requirements. Auditors expect to see a system of organized, up-to-date, and individualized records that validate both quality of care and billing accuracy.

• Timeliness – All documents must be completed and uploaded within required timeframes, including monthly (e.g., MARs, fire drills), quarterly (e.g., reviews, medication error summaries), and annual submissions (e.g., physicals, consents). Delays in documentation raise red flags and can result in corrective action or denied claims.

• Completeness – Every required document must be present. This includes face sheets, emergency medical forms, ISPs, assessments, safety protocols, medical records, and signed consents. Missing items indicate a breakdown in oversight and noncompliance.

• Person-Centeredness – Documentation must be individualized. Notes should reflect each person's unique support needs, choices, preferences, and goals—not general or vague language. Auditors want to see evidence that the individual is receiving supports that matter to them.

• Consistency – All records must align. What is written in the ISP should match what is documented in progress notes, risk assessments, and medical logs. Inconsistencies (such as services being noted that aren't in the ISP) undermine credibility and can jeopardize Medicaid reimbursement.

• Accuracy and Signatures – Forms and notes must be clearly written, complete, and signed or initialed as required. Electronic uploads must be legible, correctly scanned, and categorized under the appropriate section of the individual’s Active File. Any unsigned or outdated forms must be updated.

• Billing Justification – For every billed service, there must be corresponding documentation that proves the service was provided. The documentation must not only exist, but must show what was done, when, by whom, and how it met the individual’s goals. Without this, billing can be denied and funding recouped.

⚠️ Be Ready for Unannounced HCBS Audits

HCBS Waiver/MES audits are random and unannounced. All homes must be audit-ready at all times, without exception.

Audit readiness extends beyond proper documentation; it includes the overall physical condition, cleanliness, and organization of the home environment. Auditors frequently assess whether individuals are being supported in clean, safe, and respectful living conditions that reflect the quality of care outlined in the Individual Service Plan (ISP).

• Homes must never be dirty, cluttered, or disorganized—inside or outside. Floors should be swept, trash should be emptied regularly, and no visible messes should be present in any part of the home.

• Yards and exterior spaces must be neatly maintained. Grass should be mowed, walkways clear, and outdoor clutter or debris removed.

• Bathrooms and kitchens must be hygienic, sanitized, and odor-free. This includes clean sinks, countertops, floors, and appliances. Toilets and tubs should be scrubbed regularly.

• Bedrooms and personal spaces should be neat and organized, with fresh linens and clothing stored appropriately.

• If a Provider or House Manager is experiencing difficulty maintaining a clean environment, it is the agency's expectation that a housekeeper be hired or other supports be arranged to meet basic cleanliness standards.

• Under no circumstances will poor or unsanitary conditions be excused or overlooked during state or federal audits.

Auditors will interpret the condition of the home as a direct indicator of the respect and dignity afforded to the individuals who live there. Keeping the home environment safe, clean, and welcoming is a core part of compliance and a vital component of high-quality, person-centered care.

👁️ QSR Audit Details

The Quality Service Review (QSR) is a comprehensive, person-centered audit conducted by DBHDS to evaluate the individual's full service experience—not just the completion of forms. The QSR is designed to determine whether the supports and services being delivered are meaningful, outcome-driven, and consistent with the individual’s unique needs and preferences. This review focuses heavily on how services are perceived by the individual and whether they feel empowered, safe, and engaged.

Reviewers will look for:

• Implementation of the ISP and clear evidence that goals are actively being pursued and tracked through progress notes and staff interactions

• Person-centered documentation that goes beyond compliance, showcasing individualized routines, choices, preferences, and demonstrated progress toward outcomes

• Accurate, current safety and health protocols, including risk assessments, emergency medical plans, and signed safety strategies

• The individual’s satisfaction with their daily schedule, staff relationships, access to the community, and overall quality of life

• Interviews with both staff and individuals to verify understanding, communication, and alignment between documented plans and actual supports provided

QSR auditors will often compare documentation in Lauris with what they observe or hear during interviews. Therefore, all entries must reflect real-time, authentic support and clearly demonstrate how the services being provided connect back to the individual’s goals, health, safety, and personal development. Lauris must be kept accurate, complete, and reflective of day-to-day service delivery at all times.

✅ Required Documentation for All Individuals

DSPs and Providers must ensure the following are completed and uploaded correctly in Lauris:

• MARs (Monthly)

• Controlled Medication Count Sheets (Monthly)

• Medication Orders (if included with the MAR from the pharmacy every month then monthly; otherwise, when there are changes or at least annually!)

• Medication Disposal Forms (monthly if applicable)

• Medical Appointments Uploaded (within the same week of the appointment; same day is preferred so you don't forget)

• Monthly Fire Drill Reports (completed as a form under the home profile - Fire/Emergency Safety Drill Form)

• Annual Physical Exam (upload once a year)

• Annual Dental Exam (upload once a year at least, unless the individual has no teeth)

• Medication Side Effects (once a year, or if there are changes)

• Legal Guardian documentation if applicable (legal documents - one time)

• PRN/OTC Medication List (Signed annually by prescribing physician – Residential only - once a year)

• Weekly Activity Forms (Required for billing – one per person per week; This is a Lauris form)

• Annual Employee Evaluations (Providers/House Managers are responsible for tracking when these are due, and complete them on time, once a year, after the first year of employment. This is a form in Lauris you will complete under the employee's Lauris profile)

If you need assistance with uploading or correcting documentation, please click here.
Maintaining compliance and a safe, clean environment is a team effort—thank you for doing your part.