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 Memorandum
DATE: October 25, 2011TO: Barry Schumacher, Chief of Employer ServicesTim Wahlin, Chief of Injury ServicesJodi Bjornson, General CounselTim Schenfisch, Director of Information TechnologyKim Ehli, Director of ClaimsTom Solberg, Director of Medical ServicesDarrel Enerson, Application Services SupervisorSteve Vaughan, Technology Services SupervisorDenise Bachler, Director of Office ServicesCade Jorgenson, Decision Review OfficeCC: Bryan Klipfel, DirectorClare Carlson, Deputy DirectorJohn Halvorson, Chief Operating OfficerMichele Blumhagen, Quality Assurance DirectorFROM: Krisi L. Kunz, Internal AuditorMicole Kvas, Internal Audit DirectorRE:
File Maintenance Review
The Internal Audit Department at Workforce Safety & Insurance (WSI) recently completed areview of the maintenance of files for injured workers and employers. The review was conductedat the request of Management.
Purpose
The purpose of this review was to determine the adequacy of internal controls and proceduresutilized in maintaining files for injured workers and employers.
Scope
The scope of the review was from January 1, 2010 through October 14, 2011, and included thefollowing:
 
Notepad entries made within the Claims Management System (CMS), including medicalreviews completed by the WSI Medical Director that are documented within the CMSnotepad.
 
Notepad entries made within the Policyholder Information Computer System (PICS).
Methodology
 
Verified the appropriate procedures are being followed at the time a CMS notepad entry
is deleted, moved or updated in an injured worker‟s claim file.
 
 
Verified medical opinion documentation from the WSI Medical Director is being
included, unaltered, in the injured worker‟s claim file.
 
 
Verified the appropriate procedures are being followed at the time a PICS notepad entry
is deleted, moved or updated in an employer‟s account file.
 
 
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Define Records
The North Dakota Century Code (NDCC) 54-46-
02(2) defines “Record” as
follows:
“„Record‟
means document, book, paper, photograph, sound recording or other material,regardless of physical form or characteristics, made or received pursuant to law or inconnection with the transaction of official business. Library and museum material madeor acquired and preserved solely for reference or exhibition purposes, extra copies of documents preserved only for convenience of reference, and stocks of publications and of processed documents are not included within the definition of records as used in this
chapter.”
 
The Assistant Attorney General primarily addressing open records issues and the Director of the
State‟s Risk Management Division were contacted to obtain a general understanding of an agency‟s
authority relating to the contents of a record. These discussions were consistent with thefollowing basic principle:Each individual state agency has the responsibility to determine the internal use of itsrecords and further has the authority to dictate the format and content to help ensurerecords meet their intended purpose.Injured workers
‟
claim files and employers
‟ account files are included within WSI‟s record
sretention schedule:#190101 Injured Worker Claim File
Description:
This series contains information regarding injured work claims and theaction taken. This includes medical and legal documents and any other generalcorrespondence and documentation relating to the claim.
Confidential:
NDCC 65-05-32#800304 Employer Account File
 – 
Active
Description:
This series contains original application, annual payroll report, annualbilling statements, 2nd, 3rd, 4th request for payment, optional employer contracts, andcorrespondence.
Confidential:
NDCC 65-04-15#800305 Employer Account File
 – 
Canceled
Description:
This series contains the same type of information as active accountsincluding original application.
Confidential:
NDCC 65-04-15
Review Results
Internal Audit separated this review into three sections: CMS notepad entries, WSI Medical
Director‟s medical r 
eviews, and PICS notepad entries. Below you will find the review results foreach of these sections, along with recommendations/suggestions for improvements.
Section 1: CMS Notepad Entries
The Claims Department currently has Claims Procedure #906
“File Maintenance and
 
Documentation”, which indicate
s the following relating to the function of the notepad, alongwith moving, updating and deleting notepad entries:
 
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“Notepad function: The notepad function of the Claims Management System (CMS)
must accurately reflect the status of the claim file to include all claim activity. Summaryof pertinent conversations and developments are also maintained within the notepad.Document precautions:1.
 
Use clear language, without „personal‟
codes so that other users can accuratelyfollow claim activity.2.
 
Notes must reflect FACTUAL OCCURRENCES versus unsubstantiatedopinions.3.
 
Enter notes under your own sign on. Do not us another activated computer or
the note will be attached to that user‟s ID. The system will automatically track 
those individuals entering notes into the system by the user signed onto thenetwork.4.
 
Use of proper punctuation, accepted abbreviations and correct spelling.If an entry does not belong on a claim a clarifying entry should be made. Notepad entriescan be moved if entered on the incorrect claim. Contact the designated supervisory staff to request the move. The category of notepad entries can also be updated by contactingthe designated staff.Notepad entries can only be deleted with the approval of the claims director. Uponreview and approval the claims director
will delete the entry.”
 
The “File Maintenance and Documentation” procedure also
gives examples of notepad entries. Afew of these examples are: summary of claim filed; documentation of progress of the 3-pointcontact for new claims and reapplications; release of information documentation; and claimstaffings.The Information Services (IS) Department indicated there are 375,071 notepad entries withinCMS for Fiscal Year (FY) 2011 (July 1, 2010 through June 30, 2011). Currently, there is noaudit trail for notepad entries that are updated, moved or deleted within the system. However, if the request is received through the Help Desk, a trail of the request/outcome is kept through theInformation Technology Service Management (ITSM) system.The CMS system has the following security roles:Updating NotepadsThe only fields available for updates are the caption, high priority indicator and category.The caption and high priority indicator can be updated by any individual who can viewnotepad entries. The category can only be updated by a select number of individuals with
“override security”. At the start of this review, there were 5 individuals with this security
access: the Claims Director, the Claims Policy & Business Coordinator, 1 ClaimsSupervisor, the Office Services Supervisor, and 1 Claims Technician. The OfficeServices Supervisor and Claims Technician were removed during this review due to notneeding this access for their job duties.Internal Audit did note that in FY 2011, the Help Desk received and completed 4 requestsfor notepad entries to be updated within the CMS system. Two of these requests camefrom an individual within the Legal Department asking for updates to the notepadcategory. The other 2 requests came from an individual within the Decision ReviewOffice asking for updates to the notepad caption.
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