Austin, Texas INTERNAL AUDIT REPORT On Call Center Fiscal Year 2020
OFFICE OF INJURED EMPLOYEE COUNSELAustin, TexasINTERNAL AUDIT REPORTOnCall CenterFiscal Year 2020Garza/Gonzalez & AssociatesCERTIFIED PUBLIC ACCOUNTANTS
OFFICE OF INJURED EMPLOYEE COUNSELAustin, TexasInternal Audit ReportOnCall Center AreaFiscal Year 2020TABLE OF CONTENTSPageInternal Auditor’s Report . 1Introduction . 2Internal Audit Scope and Objectives . 3Executive SummaryCall CenterBackground . 4-6Audit Objective, Scope, and Methodology . 7-8Observations/Findings and RecommendationsSummary and Related Rating of Observations/Findings and Recommendations . 9Observations/Findings and Recommendations . 10-11
Garza/Gonzalez & AssociatesCERTIFIED PUBLIC ACCOUNTANTSMs. Jessica BartaPublic CounselOffice of Injured Employee CounselAustin, TexasWe performed tests of management’s assertion about the effectiveness and efficiency of theinternal control structure over the Call Center Area (Area) of the Office of Injured Employee Counsel(OIEC); and, its compliance with OIEC’s established policies, procedures, and practices, asapplicable to the Area, for the 9 months ended May 31, 2020.The results of our tests disclosed that OIEC’s internal control structure over the Area and itsestablished policies and procedures, were generally adequate and no material instances ofnoncompliance were noted. However, we did identify certain matters that are included in thisreport, that are opportunities for strengthening internal controls and ensuring compliance withOIEC’s established policies and procedures. Based on the degree of risk or effect of these mattersin relation to the audit objective(s), these matters were rated as either Priority, High, Medium, orLow, which is further described in the “Summary and Related Rating of Observations/Findings andRecommendations”, which is included in page 9 of this report.We have discussed the comments and recommendations from the audit of the Area with variousOIEC personnel, and we will be pleased to discuss them in further detail; to perform an additionalstudy of these matters; or, to assist you in implementing the recommendations.October 23, 2020207 Arden GroveSan Antonio, TX 78215210/227-1389Fax 227-07161
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020INTRODUCTIONThe Office of Injured Employee Counsel (OIEC) is a state agency established under the authority ofthe Texas Labor Code, Chapter 404 to represent the interest of workers’ compensation claimants inTexas. Its administrative rules are found in Title 28, Part 6 of the Texas Administrative Code. OIEC’smission is “to assist, educate, and advocate on behalf of the injured employees of Texas.” OIEC providesservices in 20 offices across Texas, with the central office located in Austin, Texas.OIEC is administratively attached to the Texas Department of Insurance, Division of Workers’Compensation (DWC); however, OIEC is independent of direction from the Commissioner of Workers’Compensation, the Insurance Commissioner, and DWC. OIEC is overseen by the Public Counsel,appointed by the Governor, with the advice and consent of the Senate. The Public Counsel serves atwo-year term that expires on February 1 of each odd-numbered year. The Public Counsel isresponsible for administering and enforcing statutory rules and regulations, including preparing andsubmitting a budget to the legislature and approving agency expenses.OIEC offers injured employees of Texas educational materials; assistance in the workers’ compensationadministrative dispute resolution process through OIEC’s Ombudsman Program; customer service; and,provides referral to appropriate local, State, and Federal agencies. As part of OIEC’s OmbudsmanProgram, an ombudsman provides the following services:1) meets with or otherwise provides information to the injured employees;2) investigates complaints;3) communicates with employers, insurance carriers, and health care providers on behalf of theinjured employees;4) assists unrepresented claimants to enable those persons to protect their rights in the workers’compensation system; and,5) meets with an unrepresented claimant privately for a minimum of 15 minutes prior to any informalor formal hearing.2020 Internal Audit PlanFollowing is the internal audit and other functions to be performed, as identified in OIEC’s Internal AuditPlan for Fiscal Year 2020, dated February 7, 2020, and approved by the Public Counsel on February 11,2020: Completion of the Fiscal Year 2020 Risk Assessment and Preparation of the Internal Audit PlanRecords ManagementCall CenterFollow-up of Prior Year Internal Audits and Preparation of the 2020 Annual ReportThis report contains the results of our audit of the Call Center Area. The following reports were previouslyissued:Report No.Report TitleReport Date1Records ManagementApril 30, 2020-Fiscal Year 2020 Annual Internal Audit Report –Follow-up of Prior Year Internal Audits2October 23, 2020
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020INTERNAL AUDIT OBJECTIVESIn accordance with the International Standards for the Professional Practice of Internal Auditing, theaudit scope encompassed the examination and evaluation of the adequacy and effectiveness of OIEC’ssystems and internal controls, and the quality of performance in carrying out assigned responsibilities.The audit scope includes: Reliability and Integrity of Financial and Operational Information – Review the reliability andintegrity of financial and operating information and the means used to identify, measure, classify, andreport such information. Compliance with Policies, Procedures, Laws, Regulations and Contracts – Review the systemsestablished to ensure compliance with those policies, procedures, laws, and regulations and contractswhich could have a significant impact on operations and reports, and determine whether theorganization is in compliance. Safeguarding of Assets – Review the means of safeguarding assets and, as appropriate, verify theexistence of such assets. Effectiveness and Efficiency of Operations and Programs – Appraise the effectiveness andefficiency with which resources are employed. Achievement of the Organization’s Strategic Objectives – Review operations or programs toascertain whether results are consistent with established objectives and goals and whether theoperations or programs are being carried out as planned.3
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020EXECUTIVE SUMMARYCall CenterBackgroundThe Office of Injured Employee Counsel (OIEC) provides assistance to injured employees who have aTexas workers’ compensation claim and are not represented by an attorney. The Call Center Area (Area)is responsible for answering calls made by injured employees to OIEC’s toll-free number. The Call CenterAgents (CCAs) are the injured employee’s first point of contact.Organizational StructureThe Area is supervised by a Call Center Manager, who reports directly to the Public Counsel; and, consistsof a CCA Team Lead, a Program Specialist, an Intake Specialist, and 7 CCAs located in OIEC’s Austinheadquarters; 2 CCAs located in OIEC’s El Paso field office, 1 CCA located in the San Antonio field office;and, 1 CCA located in the Fort Worth field office. As of this report date, OIEC’s Austin headquarters had4 CCA vacant positions, and one CCA vacant position in its San Antonio field office. OIEC cross trainscertain Customer Service Specialists as CCAs to assist the Area, as needed; such as, when there is a highvolume of calls. In March 2020, the Area’s staff transitioned to 100% telecommuting due to the COVID-19pandemic.TrainingOIEC provides an 8-week training program for all CCA new hires. The training program consists of selfstudy; to include, watching training videos and completing various training worksheets; 2 weeks ofclassroom training at OIEC’s Austin headquarters, and various observations; to include, observation of livecalls. Each trainee is assigned a mentor, who utilizes a Skills Review Checklist (checklist) to monitor anddenote the trainee’s progress and ability to complete the required duties and tasks. The mentor will initialand date each skill in the checklist when the trainee is observed to have successfully performed the task.When the trainee successfully completes all skills, the checklist is approved by the Call Center Managerand then submitted to the Training Department. The trainee is required to observe calls taken by thementor and answer calls while being observed by the mentor. The trainee uses an “Observation Diary” totrack their observations and a “Conducted Diary” to track their calls. These diaries are submitted to theTraining Department on a weekly basis. As of March 2020, training is being provided virtually, since theArea’s staff transitioned to telecommuting.Phone CallsThe Area uses the Avaya Aura Agent Desktop telephone system. Calls to OIEC’s toll free number arerouted by the telephone system to CCAs who have a status of “Ready”, indicating that they are availableto receive calls, versus “Not Ready”. A call for an injured employee (IE) who selects Spanish as theirpreferred language is routed to a bilingual CCA.CCAs are trained to answer general and claim specific questions and educate the IEs about their rightsand responsibilities in the workers’ compensation system. However, if a call becomes escalated, the CCAmay transfer the call to the Team Lead to resolve the matter; and, if needed, the Team Lead may transferthe call to the Call Center Manager to address the IE’s questions/concerns.The CCA enters every contact with an IE into the Dispute Resolution Information System (DRIS) databasewithin the COMPASS software, using inquiry codes and notes to denote the purpose of the call and otherrelevant information. The Team Lead or Call Center Manager will complete entry of information, as needed,into the DRIS database for those calls that are transferred to them. All calls are recorded for qualityassurance and recordings are maintained for 60 days before they are permanently deleted.4
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020The Area’s Minimum Production Standards are as follows: A CCA should answer, at a minimum, 30 calls per day;The duration of each call should be no more than 8 minutes; and,A CCA should take no longer than 7 minutes to perform administrative tasks; such as, updatingthe COMPASS software, between calls.The phone system has the ability to count the number of calls received, answered, the length of each call,the wait time, the length of time the CCA was logged as “Not Ready”, and various other indicators. Dailyand weekly reports, referred to as performance benchmark reports, are generated from the system by theCall Center Manager and are provided to the Public Counsel for her review of the Area’s performance.The following table represents the total number of calls offered, number of calls answered, the averagecall/talk time, and average wait time, during the audit period, which was compiled from the performancebenchmark reports generated from the phone yFebruaryMarchAprilMay(09/01/19 - 09/28/19)(09/30/19 - 10/26/19)(11/04/19 - 11/30/19)(12/01/19 - 12/13/19)*(01/27/20 - 01/31/20)*(02/03/20 - 02/28/20)(03/02/20 - 03/27/20)(03/30/20 - 04/24/20)(05/04/20 - 05/29/20)TOTALTotal CallsOfferedTotal ,6304,12231,906Avg Total 0:06:010:05:420:05:150:05:15Avg Wait :130:07:440:07:560:03:03* Performance benchmark reports were not being generated between 12/14/19 – 1/26/20; therefore, this time period is not included.Dispute ReferralsWhen an IE contacts OIEC in reference to a potential dispute regarding the IE’s workers’ compensationclaim, the CCA will determine if it can assist the IE through OIEC’s dispute resolution process byobtaining and documenting the IE’s email address in the COMPASS software, sending the IE an intakepacket through email or by mail, and setting up a folder in OIEC’s internal drive by the IE’s name andworker’s compensation claim number. The CCA does not refer a dispute to a field office until a completeintake packet has been received, unless it is a time sensitive issue. A time sensitive issue involves adispute that will result in an IE permanently losing rights and benefits if not handled promptly; such as,a dispute of a maximum medical improvement and impairment rating. In these cases, the CCA will firstrefer the dispute to the applicable field office by sending a “high priority” email, before sending an intakepacket to the IE. The Intake Specialist is responsible for reviewing intake packets received forcompleteness, scanning those that are received by mail, uploading the scanned and/or emailed packetsto the IE’s folder, updating the COMPASS software by denoting receipt of the intake packet, andreferring the dispute to the appropriate field office.During the audit period, the Area referred 3,251 disputes to the various field offices.5
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020Quality ReviewsWeekly quality reviews are conducted by the Quality Assurance Department on at least one recordedcall per CCA, using a Customer Service Quality Monitoring Evaluation form. The Area’s goal is toreceive above 90% on every quality review. The individual results of the quality reviews are documentedin the Workforce Optimization system (system), used by the Quality Assurance Department; and, sentto the Call Center Manager and Team Lead for review, then provided to the respective CCA. Acomprehensive list of results for all quality reviews performed can be generated from the system;however, this report is not typically used.6
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020Audit Objective, Scope, and MethodologyObjectiveTo determine whether the Area’s processes, and applicable policies and procedures are consistentlyapplied; and, established internal controls are operating effectively.ScopeThe scope of the audit was for the 9-month period from September 1, 2019 to May 31, 2020 (auditperiod).MethodologyThe audit methodology included a review of OIEC’s established policies and procedures, and otherinternal and external documentation; interviewing and corresponding with selected OIEC employees;and, observation of a sample of physical and electronic records.We obtained and/or reviewed the following internal and external documentation:A. OIEC’s policies and procedures related to the Area.B. The Area’s organizational chart.C. The Area’s training manuals, training exercise worksheets, and training checklists.D. Samples of the Area’s CCA training “Conducted Diary” and “Observation Diary”.E. List of calls identified as potential disputes for referral to field offices during the audit period.F. A comprehensive list of Quality Evaluations scores of evaluations performed during the auditperiod.G. Sample Performance Benchmark reports.H. Print screens of sample common entries in the COMPASS software.I. Sample of email templates used for referrals.7
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020We performed various procedures to achieve the objective of our audit, to include the following:1. Obtained and reviewed OIEC’s written policies and procedures, and conducted interviews, toobtain an understanding of controls, processes, and current practices in place over the Area ,and to evaluate whether such controls adequately ensure compliance with OIEC’s policiesand procedures.2. Reviewed the Area’s organizational structure to assess whether the Area is adequatelystaffed and structured to handle the volume of calls.3. Obtained and reviewed the following training records for 3 selected CCAs as indication thatthe CCA completed the training program:a. Skills Review Checklist completed by mentor;b. Completed training worksheets; and,c. Weekly Conducted and Observation Diaries were properly completed.4. Haphazardly selected 10 Evaluation Forms from the list of evaluations for review and testingof the following attributes:a.b.c.d.Agreement of score on Evaluation Form and listing;Score was above the Area’s goal of 90%;Recomputed the total points on the Evaluation Form; and,Ensured at least one call was evaluated per week for 4 selected CCA’s.5. Reviewed a sample of performance benchmark reports to determine whether thebenchmarks capture information useful in achieving the Area’s objectives.6. Selected 20 claim disputes and reviewed the DRIS entries to ensure the records wereproperly updated and correct inquiry codes were used.8
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020SUMMARY AND RELATED RATING OF OBSERVATIONS/FINDINGS AND RECOMMENDATIONSAs OIEC’s internal auditors, we used our professional judgment in rating the audit findings identified inthis report. The rating system used was developed by the Texas State Auditor’s Office and is based onthe degree of risk or effect of the findings in relation to the audit objective(s). The table below presentsa summary of the observations/findings in this report and the related rating, as applicable.Finding No.1123Summary of Observations/Findings & RecommendationsandRelated RatingsTitleQuality Evaluation FormsObservationsLive Call MonitoringCall ReportsQuality Evaluation Policy & ProceduresRatingLow-Description of RatingA finding is rated Priority if the issues identified present risks or effects that if not addressed could criticallyaffect the audited entity’s ability to effectively administer the programs(s)/function(s) audited. Immediateaction is required to address the noted concern(s) and reduce risks to the audited entity.A finding is rated High if the issues identified present risks or effects that if not addressed couldsubstantially affect the audited entity’s ability to effectively administer the programs(s)/function(s) audited.Prompt action is essential to address the noted concern(s) and reduce risks to the audited entity.A finding is rated Medium if the issues identified present risks or effects that if not addressed couldmoderately affect the audited entity’s ability to effectively administer programs(s)/function(s) audited.Action is needed to address the noted concern(s) and reduce risks to a more desirable level.A finding is rated Low if the audit identified strengths that support the audited entity’s ability to administerthe programs(s)/function(s) audited or the issues identified do not present significant risks or effects thatwould negatively affect the audited entity’s ability to effectively administer the programs(s)/function(s)audited.9
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020OBSERVATIONS/FINDINGS and RECOMMENDATONSReportNo.ReportDateName ofReport210/23/20Call CenterObservations/Findings and Recommendations1.Quality Evaluation FormsOur review of 10 quality evaluation forms disclosed the following: In 3 instances the forms were not retained; therefore, we wereunable to test these forms for completeness and accuracy; and, Our recalculation of the evaluation score differed by 5 points in all10 forms, where the evaluation form reflected a higher score.Fiscal Impact/Other ImpactTo strengthenthe internalcontrols overthe Area.RecommendationWe recommend the following: OIEC establish a retention period for the quality evaluation formsto ensure they are retained as required; and, OIEC determine why scoring, as reflected in the evaluation form, is 5points more than the recalculated score.Management’s ResponseOIEC will work with the Records Retention Manager to establish a retentionperiod for quality evaluation forms and will work with the Quality AssuranceManager to ensure scores are calculated accurately.OBSERVATIONS1.Live Call MonitoringQuality reviews are performed on recorded calls by the Quality AssuranceDepartment; however, other than during a CCA’s initial training, the Area hasnot implemented a process, for the Call Center Manager, Team Lead, or otherassigned individual, to monitor CCA’s live calls to provide them with immediatefeedback or assistance.To improvequality ofcustomerservice.RecommendationWe recommend that OIEC consider implementing a process where live callscan be periodically monitored in real time, to ensure CCAs are providingexcellent customer service.Management’s ResponseOIEC will establish a schedule and process for monitoring calls in real time.2.Call ReportsThe Area’s phone system has the ability to report the time the CCA’s status is“Not Ready” and therefore not available to accept phone calls; however, thereport does not specify whether the “Not Ready” status is due to the CCA beingon break or out to lunch, versus performing administrative tasks.Although the Area’s minimum production standards state the CCA shouldperform administrative tasks in 7 minutes or less between calls, the Call CenterManager is unable to adequately monitor this standard since such time is notdisaggregated.We also noted the phone system does not provide the CCA the informationneeded to comply with the minimum production standards in real time, suchas, number of calls answered, time spent with status “Not Ready.”10Ensure theArea’s minimumproductionstandards arebeing met.
OFFICE OF INJURED EMPLOYEE COUNSELInternal Audit ReportFiscal Year 2020ReportNo.ReportDateName ofReport210/23/20Call CenterObservations/Findings and RecommendationsFiscal Impact/Other ImpactRecommendationWe recommend that OIEC determine if the phone system has the capabilityof generating a report that disaggregates the CCA’s “Not Ready” time bybreak, lunch, and administrative task to allow the Call Center Manager tobetter monitor compliance with the Area’s minimum production standards;OIEC should also determine if the phone system has the capability toprovide the CCAs with real time information to allow them to track theirprogress of being compliant with the minimum production standards.Management’s ResponseThis information is available in multiple reports. We will coordinate with OIEC’SReporting Analyst to see if it can be combined in a single report.3.Quality Evaluations Policy & ProceduresThere currently are no written policies and procedures for conducting qualityevaluations, or on taking action in those instances where scores are less thanthe Area’s goal of 90%.RecommendationWe recommend that OIEC develop written policies and procedures for thequality evaluations process to ensure they are performed in a uniformmanner and CCAs are held accountable when scoring less than the Area’sgoal.Management’s ResponseOIEC is currently reviewing and revising all of its policies and procedures.11To improvequality ofcustomerservice.
Call Center Follow-up of Prior Year Internal Audits and Preparation of the 2020 Annual Report This report contains the results of our audit of the Call Center Area. The following reports were previously issued: Report No. Report Title Report Date 1 Records Management April 30, 2020 - Fiscal Year 2020 Annual Internal Audit Report -
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