Following a press release last week which disclosed preliminary findings of a forensic audit of Medicare accounting at the county-owned Oak Hill senior care facility, more questions were seemingly raised than answered during Tuesday’s Monroe County Board meeting.

The release indicated Oak Hill may have received excess Medicare payments over several years – a matter that was listed as a factor in the recent decision to transfer operations to Accolade Healthcare late last year.

Medicare is a federally-funded health insurance program primarily used for people ages 65 and older. It and Medicaid – a federal and state medical insurance administered mostly to lower-income adults – are managed through the Centers for Medicare and Medicaid Services, a division of the U.S. Department of Health and Human Services.

The Medicare billing irregularities at Oak Hill were found as part of a three-year investigation initiated in February 2023 following a “whistleblower” report submitted to then Monroe County Board Chairman Dennis Knobloch and State’s Attorney Ryan Webb, the commissioners stated in a press release posted Thursday night on the county government website.

“An internal review into the whistleblower allegations quickly revealed evidence of significant problems, prompting the county board to order a seven-year forensic audit of medical billing records,” the press release states. 

The audit was conducted by Armanino LLP, an outside auditor specializing in long-­term care billing issues. Oak Hill records from 2016 through 2022 were examined, with the total cost of this audit being $265,624.09.

The commissioners said 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 payments to be moved between resident accounts, inaccurate quarterly reports filed with Medicare falsely stating that no excess payments had been received by Oak Hill, and several “blank record” entries in the billing software that had no supporting documentation.

Further information on “potential” Medicare overbilling was provided at Tuesday’s meeting of the Monroe County Board, though it did little to satisfy skeptical members of the audience who spoke during public comments.

Monroe County Democratic Central Committee Chairman Scot Luchtefeld was first to speak, questioning why overbilling wasn’t found with any earlier audits.

Annual audits are conducted on all county finances, with a separate audit to review Oak Hill’s books.

Medicare also conducts independent audits of entities it funds.

From 2016 through 2022, there were no reports of irregularities found through either auditing system. 

Webb responded by saying the forensic audit was substantially more in-depth than a typical audit.

“A standard audit would not have found this,” Webb explained before offering further background on the situation.

“Back in 2023 when Chairman Knobloch and myself sat down with the whistleblower, there were specific irregularities that were identified by that individual,” Webb said. “At that time, there was a consultant brought in who understood the billing practices. That ended up being Armanino LLP. They were brought in to conduct a full forensic audit because of those irregularities. That is looking at the internal billing, and a standard audit doesn’t look at the internal billing practices. It looks at, ultimately, the end numbers.”

Webb further noted outside consultants recommended beginning the forensic audit at 2016, and the board heeded this advice.

Following Luchtefeld, frequent meeting attendee Pat Kelly questioned why this overbilling and the forensic audit hadn’t been discussed sooner.

“Part of the reason you’ve claimed for getting rid of the nursing home was because of this,” said Kelly, who is also a Democrat running unopposed for county commissioner in this year’s general election. “Why, when all of this come about, didn’t you come up front and tell the public why you were going to do this to get rid of the nursing home itself because of this problem with the Medicare overpayment?”

Monroe County Board Chairman George Green responded by explaining an announcement of the audit sooner might have hindered its effectiveness.

“Blurt this out in public, say, ‘Hey, we’re gonna go do a forensic audit,’ would have alerted people,” Green said. “Records would have been messed with. We don’t know what we might have found. This was the right way to do it.”

Webb offered further insight, indicating a need for discretion.

“Ultimately, this was a long process that was directed by outside consultants, outside attorneys who have expertise in this area,” Webb said. “We’ve been directed by them as to how to proceed, on what we can and cannot say in public.”

He added the outside advisors have only recently allowed for any public disclosure, adding civil liabilities may also be in play should Medicare review find them to be applicable.

During Tuesday’s meeting, the county board authorized a payment of $354,606 for any “potential overpayment” to Oak Hill by Medicare, with this payment to be taken from the county’s general fund. 

Green explained that 614 “negative transactions”  were noted in the audit and 462 transactions totalling $354,600 were found but were not supported by any available documentation.

Webb explained the county would soon submit a self-disclosure notice to CMS along with a promised payment of $354,606 to adequately repay the amount this audit found to be overbilled.

He also noted Medicare could wish to expand the audit as the board is uncertain if any overbilling might have taken place before 2016.

Commissioner Vicki Koerber described authorizing the payment as “the first step in rectifying what the forensic audit found.”

While the board has taken measures to stem any compounding issues, it was also noted the ultimate outcome will be based on a review by Medicare personnel.

A lack of any definitive numbers, the timing of the announcement and the audit being unavailable for review led Kelly to describe the situation as “fishy.”

The press release was issued prior to the county submitting its self-disclosure notice to Medicare, and the findings of the forensic audit were admitted to still be in “draft form” at the time of Tuesday’s meeting – though Webb and Green said the self-disclosure should be made available to the public once finalized.

Koerber expressed hopes for the audit to be finalized and made public, requesting Webb discuss the matter with Armanino.

The press release also stated, “The transfer of ( Oak Hill) operations and reimbursement of excess payments is a condition of the county’s offer to settle the Medicare billing issue,” even though Medicare has yet to receive a self-disclosure notice. 

Monroe County Clerk Jonathan McLean offered additional information following the meeting, noting among other things that the board’s 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.

McLean also responded to a question regarding additional issues with Oak Hill’s accounting practices in 2024 – after the forensic audit began.

Despite officials being aware of possible billing irregularities at Oak Hill, there appears to have been no attempt to prevent further accounting issues 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, ultimately leading to the resignation of the acting director at Oak Hill.  

McLean noted a major issue at this time was the lack of experience in handling financial duties by the person who had been selected to lead Oak Hill after the termination of the previous administrator in September 2024.

Although county officials say they will release documentation of the forensic audit once finalized, commissioners have yet to release information required as part of its lease of Oak Hill – predicated in part by this suspected Medicare billing snafu.

The Illinois Health Facilities and Services Review Board included that requirement in a “permit approval letter” to commissioners dated Nov. 25, following the board issuing a “certificate of need” required for Accolade’s takeover of Oak Hill.

As part of the permit being issued, commissioners 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 (RFPs), memorandums, communications to candidates, residents and community members, etc.”

The decision to pursue a lease-to-purchase arrangement with Accolade was announced in August, with commissioners approving the tentative agreement during a special meeting Aug. 26.

During that meeting, the suspected Medicare billing issues and subsequent forensic audit were briefly presented as part of the decision by commissioners to explore the possibility of divesting the county from its interest in the skilled medical care industry.

A first five-year lease term outlined during that meeting went into effect Dec. 1.

The decision was met by backlash from county residents who spoke during the special meeting and several subsequent hearings.

Many speakers noted a lack of transparency on the part of county officials in addition to concerns regarding a potential for lower quality care at Oak Hill once it came under the stewardship of a private, for-profit business.

The HFSRB had its own questions about transparency, as noted in a recently-published letter on the review board website dated Oct. 27.

In response to a question as to how “the new operator and county board (will) ensure transparency and ongoing public input during the transition,” an attorney representing Monroe County and Accolade Healthcare responded by suggesting “claims regarding the lack of transparency surrounding the change of control are unfounded.”

The attorney then explained that Monroe County’s “labor attorney contacted the union business agent on Oct. 4, 2025, to provide advance notice of the pending lease agreement” even though the proposal was first announced in early August.

The attorney also argued the “public were provided an opportunity to provide comments on the proposed transaction” during the the Aug. 26 meeting even though the lease details were mostly hashed out prior to that meeting without any prior public input.

The idea to lease Oak Hill and efforts to find a suitable lessee began that spring – several months prior to the public being made aware of the plans.

The announcement comes with a little over a month until the general primary election March 17.

Current Monroe County Board Chairman George Green is facing competition for his seat from Marvin Wittenauer in the Republican primary.

One of Wittenauer’s platforms is the county’s handling of the Oak Hill lease. Green joined the board in 2020.

During a candidate forum prior to the 2021 election, Green addressed “rumors” of Oak Hill being sold.

“My position is, before that would ever happen, that is something that would have to be discussed with the citizens, and I would suggest it would have to be a referendum,” Green said.

Per the lease agreement with Accolade, if both parties agree to a second five-year lease, a referendum question would be put on a ballot in 2030 or 2032 asking voters if Monroe County should sell the business and property associated with Oak Hill.