Information obtained by the Republic-Times on Monday detailing a forensic audit of Oak Hill’s Medicare billing practices answered some questions but raised several more.

In fact, a document created by Monroe County officials in response to a request for audit information  related to the county-owned senior care facility indicates a final report will never be provided.

On Monday, the Republic-Times received an 11-page document created by county officials which reveals auditing firm Armanino LLP indicated “no such finalization would be performed given the passage of time,” the county document adding that “no approval to release the information would be provided.”

Due to the position of Armanino LLP, a Freedom of Information Act request submitted Feb. 13 seeking a copy of a forensic audit report was denied, although the summary was eventually provided.

“I disagree with the position that it was not subject to public disclosure,” Monroe County State’s Attorney Ryan Webb said. “I believe it is. I believe $250,000 plus in taxpayer revenue was expended, there was information gathered from that expenditure and it is the property of the public.”

The document does contain an “executive summary” and other details of  a “phase one period” provided by Armanino, although the information suggests this auditing firm offered its opinion without receiving all requested documentation.

The suggested “overpayment” total is based on a review of 1,932 total Medicare transactions from 2016 through 2022 with indicated “irregularities.”

Of those 614 such “negative-amount transactions” totalling $547,024, there were 152 “supported with an explanation of benefits.”

The remaining 462 transactions totalled $354,606 – the amount authorized by the Monroe County Board last month for potential repayment to Medicare – according to the audit summary.

While that total was the result of Armanino’s 19-month analysis performed from April 2023 through October 2024, the firm reported that “further analysis of these observations is outside of our scope of work.”

In the “next steps” section of the document received Monday, Armanino reiterated its “recommendation that (Monroe County) retain the services of an attorney who specializes in Medicare law,” also advising county officials to “observe their guidance concerning any additional analysis that may be warranted.”

The cause of Armanino’s concern is found in the footnotes of the final page of the report.

A majority of the audit appears to have been conducted using paper copies of records, leading to the risk of information not being “captured” in the analysis.

In a disclaimer on the final page, the report sites “scope constraints,” suggesting “additional information… may exist that provides additional context, corroborating information or contradictory information to our work.”

In addition to Oak Hill staff being unable to locate the “explanation of benefits” for December 2021, auditors state additional documentation that was requested, but not provided, “may provide additional support for the $354,606 in unsupported negative transactions.”

The final paragraph of the document indicates the audit report should not be considered a definitive resource.

“We offer no opinions, as that term may be used by a court or any regulatory body regarding the financial condition or internal controls of (Oak Hill) or Monroe County,” the auditing firm noted.       

Throughout the document, indefinite phrases such as “could be related,” “could reflect” and “appear to be” were used in addition to the assertion the audit was “not based on a complete review.”

However, the seemingly incomplete findings of the audit were the basis for a controversial decision to seek an outside entity to assume operations at the senior living and rehabilitation center.

Oak Hill, formerly the Monroe County Nursing Home, was owned and operated by Monroe County for more than seven decades until December 2025, when a lease-to-purchase agreement was formalized between Monroe County and Accolade Healthcare. The county remains the owner of this facility for the time being.

During the county board’s announcement of the lease agreement in August, an apparent major factor in the decision was the result of a “forensic audit” of Oak Hill’s Medicare billing practices.

Armanino was hired to audit those practices at Oak Hill from 2016 through 2022 following a “whistleblower” report of suspected irregularities submitted to Webb and former Monroe County Board Chairman Dennis Knobloch in February 2023.

As was later described via a Feb. 12 press release and at a subsequent meeting of the Monroe County Board, that Armanino audit came at a cost of $265,624.09 and was substantially more thorough than a standard audit, with the board emphasizing several times that information revealed in the forensic audit simply wouldn’t have been uncovered in a regular annual audit.

Commissioners said at the time the audit revealed a “pattern of severe billing irregularities,” including hundreds of thousands of dollars in excess Medicare payments being transferred between resident accounts, unusual and unexpected billing and payment entries in the billing software to allow excess payment to be moved between resident accounts, inaccurate quarterly reports filed with Medicare falsely stating no excess payments had been received by Oak Hill and several “blank record” entries in the billing software that had no supporting documentation.

Additionally, after the meeting, Monroe County Clerk Jonathan McLean clarified that the aforementioned outside legal counsel is a Washington, D.C. attorney with substantial experience preparing self-disclosures for healthcare organizations – though not necessarily with a government body.

In speaking further on this situation, McLean remarked that Armanino was hired by the county simply to conduct and provide the forensic audit, not to serve as a spokesperson for the audit.

Although, as previously mentioned, the audit appears to have been conducted by Armanino without full access to all requested documentation, Webb maintained – and Monroe County Board Chairman George Green expressed a similar sentiment – that the audit was still complete and comprehensive enough to prompt the board into further action.

“I believe the commissioners felt comfortable that the extent of the audit alerted them to the ongoing issues that had existed that allowed them to make decisions about hiring outside counsel, to self-report and all the other things they’ve done,” Webb said. “I don’t believe that they look at this as incomplete, that there’s something missing that would otherwise tell them a different story. I believe that they have a complete understanding of what happened, just not perhaps every single document of every single transaction that occurred between 2016 and 2022.”

Regarding the self-disclosure to Medicare, the county has yet to file such documentation with the Center for Medicare and Medicaid Services, commonly known as CMS.

A CMS spokesperson communicated to the Republic-Times on March 6 that the agency “does not have record of the provider in question contacting Medicare Administrative Contractor about, or disclosing, a self-reported overpayment.”

Webb and McLean confirmed this self-disclosure has yet to be submitted to CMS.

The CMS spokesperson further provided documentation noting time limits for submitting overpayment self-disclosures, with an entity being required to report and return a self-identified overpayment to MAC within 60 days of identifying the overpayment or six years of getting an overpayment – generally known as the “lookback period.”

When asked about adherence to these timeframes, Webb and McLean suggested those statutes were likely more applicable to individual instances of overpayments rather than a years-long trend of overpayments such as at Oak Hill.

Among the discussion of the audit, self-disclosure process and authorization of a $354,606 repayment to Medicare at that Feb. 17 county board meeting, it was also noted the ultimate outcome of the self-disclosure will be based on a review by Medicare personnel, with the possibility of expanding the audit if it is deemed possible that overbilling took place before 2016.

Conversely, based on the uncertainty presented in the Armanino report, the possibility exists that additional documentation may show no overpayment, or overpayment in a lower amount.

Ultimately, the determination of overpayment will be decided by Medicare personnel – although the county has yet to submit its self-disclosure report of suspected overpayment. 

Asked if it would have been possible for a self-disclosure to be submitted any earlier, Webb and McLean were emphatically negative, reiterating the self-disclosure process has been and is still being handled by outside counsel.

McLean noted the process has been slow for a number of reasons, with the audit taking time due to the abundance of hard-to-find physical documents and the vetting and hiring of the aforementioned D.C. legal counsel also taking time.

“We got the final report from Armanino Oct. 3, 2024, and after we got that final report, Armanino recommended that we hire an attorney that specializes in Medicare,” McLean said. “It took Ryan a couple of months to find someone because it’s a very difficult line of work to deal with… We’re looking at the beginning of 2025 before we even got the ball rolling as to, ‘OK, how do we self-report Medicare billing issues between 2016 and 2022.’ That took a little bit of time… We’re talking about early 2025 before we even had an attorney retained to be able to help us put together a self-disclosure certificate to file with CMS, and then around April of 2025 is when we started conversations with Accolade about leasing the facility.”

Webb, who also expressed amid the county’s press release and meeting in February that the county has been “directed by (outside counsel) as to how to proceed, on what we can and cannot say in public,” further spoke to the delayed nature of this self-disclosure process.

“I think there’s this general sense that this is just somehow, ‘Here’s information, and then you get it,’” Webb said. “It’s just not that simple for the folks that actually deal with this. And it’s also why former administrator Anna Johnson told folks at a public hearing that the county board would never have found this because it is so buried in billing. It’s just a lot to observe and then report accurately, because the last thing I think anybody wants to do – and that includes obviously our outside accountants and attorneys… I’m confident that they’re ensuring everything they’re required to do so they remain in good standing with their practices.”

Webb and McLean further noted the seriousness with which the process is being handled by both them and the county board.

“We don’t take this lightly,” McLean said. “This is a serious matter, and that’s also why it’s taken a little bit of time because we did our due diligence. We’ve looked at everything. It took a while to even get things going because of scanning documents, trying to locate documents from a long time ago. It was time consuming, but we did a thorough job, I believe. We’ve taken it very seriously.”

Despite the county officials’ insistence that due diligence has been administered in the matter, complaints of a perceived lack of transparency have been voiced since the initial announcement of a proposed lease agreement in August.

A major contention – beginning in August and continuing through the transfer of operations process – was that the public was not included in any part of the decision to lease the facility that voters approved to be built.

Heightening public frustration are delays in providing details on the lease agreement following approval of the transfer which have been noted by residents during recent county board meetings.

Additionally, the Illinois Health Facilities and Services Review Board – the agency responsible for issuing a “certificate of need” required to formalize the operational transfer – reiterated a condition of issuing the certificate which has not yet been satisfied.

In a “permit approval letter” to commissioners dated Nov. 25, 2025, the HFSRB stated Monroe County officials must “provide all available documentation regarding the process of selecting viable candidates to lease and/or operate Oak Hill.” 

Those documents include anything that describes “the ultimate decision-making process leading to the selection of Accolade Ventures LLC, including, without limitation, (Monroe) County Board meeting minutes, public notices, requests for proposals, memorandums, communications to candidates, residents and community members, etc.”

No documentation has been provided on the county website or discussed during subsequent board meetings.

With the disclosure that Armanino will not provide a finalized audit report, yet another request from taxpayers will remain unfulfilled.

And finally, Medicare has not yet confirmed any irregularities on the part of Oak Hill staff – the result of which is a controversial and widely criticized lease agreement predicated on suspected billing issues which have not been verified, only based on an audit which was seemingly conducted without potentially critical documentation being made available.

Furthermore, despite the county investigating possible billing issues, in September 2024, commissioners decided to install an organizational leader at Oak Hill who had no financial experience – 16 months after ordering a forensic audit to investigate accounting practices at the facility.

As previously reported, an audit report from Schmersahl, Treloar & Co. delivered to commissioners in July 2025 detailed $3.3 million in misrecorded debits and credits during Fiscal Year 2024, ultimately leading to the resignation of the acting director at Oak Hill who had been selected for the position less than a year earlier.  

Following the issuance of the Feb. 12 press release, McLean told the Republic-Times a major issue at the time was lack of experience in handling financial duties by the person who had been selected to lead Oak Hill.

The timing of that release came a little over a month before the primary election which will determine if incumbent Monroe County Board Chairman Green will have the opportunity to retain his seat during the general election this November.

One recent social media post pointed out that Green, during his 2020 election campaign, said any decision on Oak Hill should be met with public dialogue. 

Green is opposed by Marvin Wittenauer in Tuesday’s Republican primary for a seat on the county board. Wittenauer has stated a major reason for his candidacy is how the current board has handled the Oak Hill situation. 

The search for a lessee of the Oak Hill property and business operations coincided with the final bond payment on the facility in March 2025.

Taxpayers had approved $20 million in bonds in 2004 to finance a new facility. Those bonds were paid in full last year, even with the county supporting construction of a new Evergreen Pointe rehabilitation center in 2017 – funded by Oak Hill profits without the need for any new taxpayer-supported financing.