MEO COA - Presentation Final

Wayne County Health, Human and Veterans Services
Contract to Provide Medical Examiner Services
Performance Audit
August 1, 2022
DAP No. 2021-57-003
Office of Legislative Auditor General

Purpose / Objectives
The Office of Legislative Auditor General conducted a Performance Audit of the Wayne
County Department of Health, Human and Veterans Services – Wayne County Medical
Examiner’s Office.
The engagement objectives were to:

⚫ Assess the contractor’s compliance with key contract provisions.
⚫ Assess controls over revenues and expenditures; and
⚫ Assess processes for providing MEO services.
2 The Office of Legislative Auditor General

Scope / Methodology
⚫ The engagement’s scope encompassed the period October 1, 2019 through April
30, 2022. The Performance audit was conducted in accordance with Generally
Accepted Governmental Auditing Standards (GAGAS).
⚫ Methodology – To address the objectives outlined for this engagement we:

– Conducted interviews with HHVS and MEO staff
– Performed inquiries, observations and analytical procedures
– Reviewed contract, public act and various documents
– Obtained access to the CASEManager System to obtain real-time data
– Performed various audit tests
– Observed a physical inventory of decedents
– Reconciled the inventory results with the CASEManager System.

Background
The Wayne County Medical Examiner’s Office (WCMEO) is a division within the
Department of Health, Human and Veteran Services
⚫ Created in accordance with Act No. 181 of the Michigan Public Act of 1953, as
amended.
⚫ Mission is to identify, investigate, and determine the cause and manner of death of
people who die in the County of Wayne under the circumstances or conditions
described by the Act.
⚫ Purpose is to provide forensic death investigations, autopsies, and toxicological
services to the general public, medical, legal, and criminal justice community so they
can have documented, timely, and accurate cause and manner of death for
individuals who died in Wayne County.

Background
Financial Operations
The financial information for the WCMEO is recorded in business unit 64800. In Fiscal
Year (FY) 2021,
⚫ Budget for the WCMEO (a General Fund operation) was $7.85 million
⚫ Actual expenditures were $7.58 million.
⚫ $6.48 million or 85 percent of expenditures were the fees paid to the UMHS for
professional and operational services.
⚫ Additional $1.1 million in expenditures includes personnel costs, contractual services
including chargebacks and operating transfers for debt services as shown in the
chart on page 6 of the report

Background
Financial Operations
⚫ The WCMEO relies on general fund support for its operations but receives some
revenue from fees for services (i.e., autopsy reports, reimbursement from government
agencies and other revenue).
⚫ FY 2021, the MEO received $938,789 in revenue which included.
– $793,159, or 84%, - autopsy report fees.
– $114,750 - reimbursement from Monroe County for autopsy services
– $12,880 - State of Michigan for infant autopsies.
– $18,000 - miscellaneous revenue from the State of Michigan for Violent Death Data.
– See chart on page 7 for details.

Background
Authority and Responsibilities
Wayne County Medical Examiner’s Office performs its services under the provisions of
the State of Michigan’s County Medical Examiners Act, which prescribes the powers and
duties of county medical examiners. Under provisions of this act, “A county medical
examiner or deputy county medical examiner shall investigate the cause and manner of
death of an individual under circumstances as identified in the Act. The types of
circumstances where a Medical Examiner is required to investigate the cause and
manner of death are:
• Death as a result of violence
• Unexplained, unexpected, and/or sudden deaths
• Deaths caused by drugs
• Deaths without medical attendance
• Deaths in custody or prison
• Deaths as a result of an abortion

Background
Type of Examinations Performed
Each body brought into the office receives some form of examination; either a complete
autopsy, limited autopsy, or external examination.
⚫ Autopsies are performed to collect evidence, document findings, and determine the
cause and manner of death in sudden, unexpected, unexplained, or suspicious
deaths.
⚫ External examinations and limited autopsy inspections are performed when sufficient
information documenting the cause and manner of death is available for the
pathologist to certify the death and meet local legal standards or where religious
practices request limited examinations.
⚫ In addition, the medical examiner will also perform private autopsies for a fee when
requested by the legal next-of-kin.

Background
⚫ Performance by Year (2019-2021)

2019 2020 2021
Reported Cases 15,752 19,101 16,277
Cremation Permits 11,114 13,756 10,652
Cases to MEO 3,173 3,625 3,610
Autopsies 2,349 2,621 2,720
Examinations 824 1,004 890

Background
Statistical Information Oakland Vs Wayne County

Calendar Year 2021
18,000
16,000
14,000
12,000
10,000
8,000
6,000
4,000
2,000
0
Reported Deaths Cases to MEO Autopsies (Full & Limited)
Oakland County Wayne County

Engagement Results
Objective 1: Assess the contractor’s compliance with key contract provisions
Our review of the five-year agreement between the County and UMHS noted that
generally, both parties complied with their respective contractual obligations.
Areas where contractual obligations were not complied with included:
⚫ MEO facility
⚫ Staff certifications
⚫ Benchmarking
⚫ Insurance coverage.

Engagement Results
Wayne County Medical Examiner Office Facility Not Adequately Maintained (pgs. 10-
11)
Contract states County is responsible for maintenance and update of facility including
heating/cooling/electrical and plumbing. According to MEO management, the current
facility is in a state of major disrepair. Some of these issues include:
⚫ Heating/cooling issues which affects the operations and condition of decedents at the
WCMEO.
⚫ Pipes freezing.
⚫ Drops in water pressure which affects the performance of autopsies.
⚫ One instance of note occurred between June 26, 2021 and June 28, 2021:
–Loss of power increased cooler temperature which adversely affected the
condition of decedents.

Engagement Results
11)
NAME accreditation inspection in December 2021 cited issues with facility condition:
⚫ Facility is not structurally sound as it is in need of repairs.

⚫ Heating and cooling systems are not very effective
⚫ Could impact the daily operations of the WCMEO
Noted deficiencies contributed to Provisional Accreditation.

Engagement Results
11)
Assessment by County’s Capital Development & Building Administration determined that
capital improvements were necessary to keep the building and systems from further
deterioration.
⚫ October 2021, a contract was executed for architectural and design services in the
amount of $526,000.
⚫ Total cost for renovations and improvements could range from $4.2 million to $4.8
million.
⚫ During the renovations, operations would have to be moved to utilize the Wayne State
Mortuary Science facility requiring 6 or 7 refrigerated trucks for transportation of
decedents during the autopsy process.

Engagement Results
11)
Lack of adequate and ongoing maintenance over the years has resulted:
⚫ Deterioration of facility
⚫ Impact on performance of daily operations
⚫ Provisional NAME accreditation

Engagement Results
11)
Recommendation #2021-01 – Significant Deficiency
We recommend WCMEO management along with senior executive management within the
County and Department of Health, Human, & Veteran Services (HHVS) work with the
Buildings Division in the interim period to ensure that the MEO facility is properly maintained
and repaired in order to ensure continued operations until a decision is made regarding
future operations.
Views of Responsible Officials – See Appendix B in report

Engagement Results
Inadequate Staffing/Board Certification of Pathologists (pgs. 11-13)

Contract requires autopsies performed by pathologists who are certified by the American
Board of Pathology. Staffing levels should be sufficient to attain accreditation from NAME.
NAME accreditation inspection from December 2021 noted two deficiencies regarding
pathologists contributing to Provisional Accreditation:
⚫ 11 pathologists were required, WCMEO had 7, a shortfall of 4.

⚫ 2 of 7 pathologists were not board certified (subsequently 1 became certified)

Engagement Results
⚫ Not maintaining sufficient staffing levels within the MEO could impact daily operations if
existing staff became unavailable.
⚫ Not ensuring all pathologists are board certified is a violation of the contract.
Furthermore, not meeting the certification requirements could possibly result in the
WCMEO not receiving full accreditation from NAME.

Engagement Results
We recommend management within the Wayne County Medical Examiner’s Office:
A. Continue to work with physician search firms to acquire staff levels sufficient to ensure
the continuity of daily operations and obtain full NAME Accreditation.
B. Implement procedures to ensure all pathologists within the WCMEO obtain American
Board of Pathology certification.
Views of Responsible Officials – See Appendix B in report.

Engagement Results
Medical Investigator Board Certification (pgs. 13-14)

⚫ Contract requires compliance with NAME standards. One standard requires majority of
medicolegal investigators, working longer than 5 years be certified by the American
Board of Medical Death Investigators.
⚫ Noted in NAME accreditation report that majority of medicolegal investigators, working

longer than 5 years were not certified by the American Board of Medical Death
Investigators (ABMDI).
⚫ Currently 13 investigators with 8 working longer than 5 years. Only 3 of the 8 are
ABMDI certified, therefore, not compliance with the NAME standard.

Engagement Results
Medical Investigator Board Certification (pgs. 13-14)
We recommend management within the Wayne County Medical Examiner’s Office

implement policy and procedures to ensure medical investigators who have worked in
the office for over 5 years obtain either the registered or board-certified credential for
the American Board of Medical Death Investigators.

Engagement Results
Benchmark Reporting Requirements (pgs. 14 - 15)
⚫ Contract requires UMHS to:

– Report quarterly on average time periods for processing histology, amending
case and issuing final cause of death with average times complying with NAME.
– Submit benchmarking statistics annually every November 1. NAME requires
preparation of annual report to include total cases reported, accepted,
examined, autopsied and cause of death sorted by manner of death.
⚫ Annual statistical information was shared with the County and NAME, a formal report
was not prepared and submitted.
⚫ Contract provisions only requires the WCMEO to “report” on the operations of the
office and not provide a formal report to the County.
⚫ Other local medical examiner’s offices prepare Annual Report and include on their
websites for the public to view.

Engagement Results
Benchmark Reporting Requirements (pgs. 14 - 15)
Recommendation #2021-04 – Control Deficiency
We recommend management at the UMHS, WCMEO and HHVS:

A. Ensure that all future agreements include formal benchmark reporting documentation
as well as submission of these reports to senior county executive officials and the
Wayne County Commission for review.
B. Include an Annual Report, as well as benchmarking statistics, on the County’s
website.

Engagement Results
Inadequate Insurance Coverage (pgs. 15 - 16)
⚫ Contract requires certain insurance coverages be maintained by each respective party.

– County has maintained its required Commercial General Liability Insurance
coverage.
– UMHS Professional Liability Insurance coverage contains an aggregate coverage
of $3,000,000 less than the $5,000,000 required.
⚫ By not having the required insurance coverage, UMHS is not in compliance with the
contract terms and could expose the County to potential liability exceeding an
aggregate total of $3 million.

Engagement Results
Inadequate Insurance Coverage(pgs. 15- 16)
We recommend management within the Department of Health, Human and Veteran

Services and Risk Management:
A. Ensure the insurance coverage obtained for the WCMEO is in accordance with the
contract provisions.
B. Ensure the administrator over the WCMEO provides Risk Management and HHVS
executed annual insurance certificates, including renewal periods, for review.

Engagement Results
Objective 2: Assess Controls Over Revenue And Expenditures
⚫ Controls over payments from the County to UMHS for professional and operational
services appear to be adequate. We noted that all payments for the period of October
1, 2017 through September 30, 2021 were in accordance with contract provisions and
no additional fee for services in excess of the allowed services were made.
⚫ However, we noted controls over the receipt of revenue for services performed by the
medical examiner’s office could be strengthened.

Engagement Results
Lack of Controls Over Cash Receipts (pgs. 17 - 18)
⚫ WCMEO only accepts business checks, money orders, and cashier checks in
payment for the services they provide. These remittances are primarily received via
mail.
⚫ Review of the cash receipt processes noted:

– One individual receives and opens the mail, and distributes the checks, money
orders and/or cashier checks to a designated staff (approximately four [4] other
employees) for processing of the services by the staff person.
– Once service is performed, the staff person that performed the services places
the checks/money orders in a lockbox.
– Checks/money orders are retrieved by the same individual who originally
distributed them. This same individual then completes the deposit slip and makes
the deposit.
Engagement Results
Lack of Controls Over Cash Receipts(pgs. 17 - 18)
We noted the following internal control weaknesses in this process.

⚫ Lack of segregation of duties as the same individual opens the mail, prepares the deposit slip and
deposits the checks/money orders.
⚫ A log is not maintained listing all checks/money orders when received and the service requested.
⚫ Checks/money orders are not immediately endorsed upon receipt.
⚫ Checks/money orders are provided to investigators that are to perform the service rather than
being secured until a deposit is prepared.
⚫ No second verification is performed to ensure the deposit is accurate and includes all incoming
checks/money orders.
⚫ Deposits are made approximately every two (2) weeks averaging approximately $30,000 per
deposit.
⚫ Deposits are not transported in a secure manner.
By not implementing proper internal controls over cash receipts (business checks, money orders
and/or cashier checks) increases the risk of lost, stolen, or misappropriation of funds.
Engagement Results
Lack of Control Over Cash Receipts (pgs. 17 - 18)

We recommend management within the Medical Examiner’s Office implement the
proper internal controls over cash receipts for services provided and:
A. Establish a segregation of duties so the same individual does not open the mail,
prepare the deposit slip, and makes the deposit.
B. Ensure all checks/money orders are:
– Recorded in a log immediately upon receipt.
– Restrictively endorsed immediately upon receipt.
– Maintained in a secure location by one (1) individual until deposited.
– Second verification of the deposit is performed.
– Deposits are made at a minimum of twice per week and transported in a secure manner.

Engagement Results
Objective 3: Assess Processes For Providing MEO Services

⚫ Obtained an understanding of the CASEManager database
– Web-based software used to track all cases and maintain electronic case records.
– Book of record for tracking chain of custody and the autopsy/investigative process.
– Policies and procedures require all information related to the decedent be input into the
CASEManager system.
⚫ Obtained a copy of report from CASEManager for the period October 1, 2019
through December 31, 2021 which listed 8,068 decedents that came into the
WCMEO during this time period.
⚫ Assessed the information in this report to determine if the data entered the
database appeared accurate and complete.
⚫ Reviewed case information and reports to obtain an understanding of the
processes for identifying decedents and notifying next of kin.

Engagement Results
Cases Documented in CASEmanager from October 1, 2019 – December 31, 2021
Decedents transported to WCMEO was 8,068.

Decedents at the WCMEO at time of report – 250
Decedents released with 10 days or less – 6,720 or 86%
Decedents released greater than 10 or 50 or less days – 752 or 10%
Decedents released greater than 10 but 100 or less days – 110 or 1%
Decedents released greater than 100 days – 236 or 3%

Engagement Results
Objective 3: Assess Processes For Providing MEO Services
Overall, with the volumes of deaths that occur in the county, based on our review, it
appears that the WCMEO does an adequate job. However, there are areas where
additional procedures, oversight, and controls could be put in place to enhance
operations and processes.

Engagement Results
Ensure All Pertinent Information in CaseManager is Complete (pgs. 20 – 21)

Generally, data related to the receipt or release of a decedent was included with the
CASEManager report. We did not a few instances where other data fields related to
the receipt or release of a decedent had pertinent information missing.
Missing Pertinent Information Related to WCMEO Receipt of Body

Policies require date a decedent is received by (check in date) be entered into the
database. We noted:
27 instances were there was no check in date.
Based on further review, 4 of the 27 decedents’ check-in date was input in February
2022, almost 1 year after the decedent was transported to the WCMEO

Engagement Results
Missing Pertinent Information Related to WCMEO Release of Body

Policies require the autopsy technician to update CASEManager with release of body
information. This data was not always input. Missing information included:
⚫ Missing check-out dates
⚫ Funeral home the decedent was released to
⚫ Funeral home representative
⚫ Whether clothing was released with the decedent
We found these instances were minimal compared to the number of decedent bodies
received at the WCMEO.

Engagement Results
Missing Information Related to Condition of Body

When a body is released, its status (i.e., decomposition) is assessed by the Autopsy
Technician, communicated to the funeral director, and recorded in CASEManager.
We noted 750 instances where the body was released but its condition was not noted.
This information is vital should questions/litigation arise concerning the noted body
condition.
Missing Information Related to Notification of Next-Of-Kin (NOK)
WCMEO is responsible for notifying a decedent’s Next-Of-Kin (NOK). We noted 3,241

instances where the NOK notified field was blank. As a result, we were not able to
determine if the NOK was actually notified but other fields referenced NOK.
35 . The Office of Legislative Auditor General

Engagement Results
The Medical Examiner’s Office has not implemented review and monitoring procedures
to ensure all pertinent information in CASEManager is complete.
While the number of instances of missing data may be minimal, responses from
families of decedents could be negatively impacted because of inaccurate or
incomplete information.

Engagement Results
Ensure All Pertinent Information in CaseManager is Complete (pgs. 20 - 21)
We recommend management within the Medical Examiner’s Office implement policy

and procedures to ensure information within the CASEManager database is periodically
reviewed for accuracy and completeness in order to ensure the integrity of the
information within the system.

Engagement Results
Lack of Reconciliation Between Physical Inventory and CASEManager (pgs. 21 -

24)
Decedents received at the WCMEO must be maintained in coolers and/or freezers

until released for disposition. Each decedent is included in a perpetual inventory
record. (”Cooler Inventory Summary”). A weekly physical inventory is conducted of the
decedents contained in the coolers/freezers. However, there is no reconciliation
performed between the Cooler Inventory Summary and the data contained in
CASEManager.
We observed a physical inventory conducted on April 5, 2022, and attempted to

reconcile from the Cooler Inventory Summary to those decedents shown as still at the
WCMEO within the CASEManager system.
Based on our review, it was determined that 23 decedents should physically have
been present based on no check-out date in CASEManager.
Engagement Results

24)
Based on review of the case files, to determine actual dispositions we noted:
Decedents With Check-In Dates; but not Transported to WCMEO
5 decedents were never transported to the WCMEO and should not have been in the
inventory. However; these cases should not have been assigned a Check-In date in
CASEManager,
Decedents With Check-In Dates and No Check Out Dates
2 decedents were included in the database although they did not have a check-in or
check-out date.
Decedents With Check-In Dates; but Actually Released to Funeral Home

4 decedents were actually released to a funeral home, but the database was not
updated to reflect this.

Engagement Results

24)
Decedent Listed in Database with Checkout Date but Physically in Inventory

Decedent was released to a funeral home but due to a family conflict, was returned to
the WCMEO. The return was not reflected in the database.
Based on these noted exceptions, as a result of not reconciling the physical inventory to
the electronic records resulted in errors going undetected and the electronic records
not accurately reflection the actual disposition of the decedents.
More importantly, the electronic records database may not always be relied upon to
provide to provide accurate information in response to inquiries from the general public.

Engagement Results

24)
We recommend management within the Wayne County Medical Examiner’s Office:

A. Perform weekly reconciliations of physical body counts to CASEManager database
including those stored in the Anthropology Room. The reconciliation should be
performed by someone independent of the weekly body count.
B. Follow up on any discrepancies and ensure CASEManager accurately reflects the
disposition of all cases.
C. Instead of “Released”, implement a unique code to classify bodies that are never
ordered to be transported to the morgue.
D. Conduct periodic training for staff assigned responsibility for input entered into the
CASE Manager System.
Engagement Results
Unknown and Unclaimed Decedent Identification and Next-of-Kin (pgs. 24 - 27)
Two types of decedents that remain at the WCMEO until released:

⚫ Unclaimed –decedents that have been identified but either the Next-of-Kin has not
been identified or has not claimed the body for release.
⚫ Unidentified – decedents where a positive identification has not been made.
Two types of identification:

⚫ Positive – Identification confirmed by scientific method using visual identification by
Next-of-Kin, dental, DNA, fingerprints, etc.
⚫ Presumptive – Identification by non-scientific method such as personal effects or
forms of identification
The WCMEO is responsible for the notification of Next-Of-Kin (NOK).

Engagement Results
We reviewed the process the WCMEO utilizes to identify the unknown decedents or
identification of the next-of-kin for those decedents that were identified. We also
reviewed the process for disposition of those that were at the WCMEO a significant
amount of time but ultimately received an indigent cremation.
Unknown Decedents
Of the 8,068 cases, 26 were listed as unknown persons. Five (5) received an indigent
cremation. 21 of the 26 were either skeletal remains or the body was badly decomposed.
In 25 of the 26, based on documentation in the CASEmanager system, appropriate steps

were taken to identify the remains. We noted in one case, the documentation notes were
vague.
.
Engagement Results
Unclaimed Decedents
Of the 8,068 cases, at the time of our review, 153 cases had still been at the WCMEO 50
days or more
50 – 100 days 38 decedents
101- 500 days 105 decedents
Greater than 501 days 10 decedents
Additional 213 decedents submitted for county cremations as a result either the NOK not
located or NOK approved cremation.
Judgmentally selected 29 of the 153 cases and 23 of the 213 cases to review the steps
taken to identifying and notifying NOK so decedent could be released or submitted for
county cremation.

Engagement Results
Based on our review, it appears that generally, investigators performed sufficient due
diligence in the identification/location of the Next-of-Kin.
However, we noted:
⚫ Gaps in the documented progress in some of the cases.
⚫ Instances where NOK was notified but lengthy delays in either removing the decedent
from the WCMEO or providing authorization for cremation by the WCMEO.

Engagement Results
As a result, delays in following procedures, or lack of following all procedures, could

result in decedents not being identified or the Next-of-Kin not being notified in a timely
manner. Furthermore, extended delays in the identification and notification of Next-of-Kin
results in decedents remaining at the WCWC for extended periods of time.
However, since we began the engagement, the WCMEO has established a policy for the
length of time a decedent will be held after notifying the NOK.

Engagement Results

We recommends management within the Wayne County Medical Examiner’s Office:
A. Continue with developing a website to enable the public to identify decedents including
a search of distinguishing identifiers such are scars, tattoos, etc.
B. The WCMEO develop, implement, and utilize a standardized checklist of required
procedures and ensure that dates and results of procedures are documented in the
CASEManager system.
C. Continue with oversight/monitoring of all cases either not identified or released, to
ensure progress is made toward release to the NOK or submission to the county for
cremation.
D. Once all due diligence is completed, follow WCMEO guidelines for submission of
decedents for county cremation.

Engagement Results
Next-Of-Kin Protocol for Release of Decedent (pgs. 27 - 28)
As part of our review of the various WCMEO functions, we reviewed in detail over 115
decedent cases during the engagement scope period (October 1, 2019 – March
2022). In several instances and in discussion with WCMEO personnel, we found that
on occasion, inaction, or a lack of efforts by Next-Of-Kin to expedite the release of the
decedent from the Wayne County Medical Examiner’s Office occurred.
⚫ Additionally, in several instances, while initially agreeing to complete the WCMEO
requested release of decedent remains protocols, the NOK did not uphold the
agreement; at which time, the WCMEO extended the maintenance period with the
understanding that NOK was taking the necessary action, when, in fact, no action
was taken by the NOK.

Engagement Results
⚫ In October 2021, the WCMEO revised its Identification Procedures to include timeframes for
submission of decedents for County cremation. Prior to this update, there was no formally
recognized timeframe for the completion of NOK responsibilities as they relate to the release of the
decedent from the WCMEO for funeral/burial services, or ultimately, consideration for indigent
cremation by the county.
⚫ We found no evidence in the revised Policy as to how the documented notification to the NOK
informing them of the necessity for swift completion of the release protocols, will be implemented.
⚫ As a result, the WCMEO has maintained decedents for extended periods of time (six [6]
months or more. The reported/observed inaction by the NOK places the WCMEO in a precarious
position regarding balancing its compassion for the families of the deceased and maintaining the
decedent’s body at the WCMEO facility which could result in additional expense to the county for
maintenance of bodies in excess of what the facility will hold.

Engagement Results
We recommends management within the Wayne County Medical Examiner’s Office:

A. Implement the revised policy that determines a “reasonable” timeframe for the
completion of procedures by NOK to expedite the release of a decedent; and,
B. Incorporate the identified timeframe into a disclaimer to be included on all NOK
release documents and clearly presented on the WCMEO website/homepage
stating a decedent left unclaimed for the specified timeframe may be cremated by
the county as an indigent cremation.

Engagement Results
Timeliness of Cremation Requests (pgs. 28 - 30)
⚫ In Michigan, the cremation of a decedent requires a cremation permit issued by the

County Medical Examiner’s Office in which the death occurred.
⚫ In 2019, 2020, and 2021, the WCMEO processed 11,115, 13,769, and 9,766
cremation authorizations, respectively.
⚫ In 2019 Wayne County Approved 11,115 compared to 6,890 by Oakland County.

See chart on page 28 for comparison with other counties.
⚫ Wayne County allows funeral directors to obtain cremation permit by fax, walk in or
through the State’s Electronic Registration System (EDRS)

Engagement Results
⚫ We performed a review of the process and timeliness for the WCMEO to provide
the requested cremation authorization.
⚫ Our review included contacting seven (7) funeral homes to discuss their process
and experience with obtaining cremation authorizations from the WCMEO. The
results of the discussion was the turn around time at the county was slow and
averaged approximately 3 to 4 days while other local medical examiner offices, the
standard turnaround approval time was a few hours.
⚫ In addition, while other local counties require authorization requests for cremation
to be processed through the EDRS, Wayne County currently allows processing
through fax, walk in and EDRS.

Engagement Results
To assess WCMEO turn around time, we judgmentally selected a sample of 22 cremation

permits submitted by fax and another sample of 48 submitted through the EDRS system to
determine the turn around time for processing. Based on our sample, the turn around time for
faxed requests were faster than through the EDRS. Specifically:
⚫ 12 of the 22, or 55 percent, of the faxed requests were approved within 12 hours.
⚫ 21 of the 48, or 44 percent, of the electronic requests were approved within 12 hours.
By not having adequate policies and procedures in place with adequate timelines to authorize
cremations along with a dedicated individual responsible for processing cremation permit can
cause a delay in a decedent’s cremation and lead to additional undue stress on the decedent’s
family along with potential negative publicity for the WCMEO.

Engagement Results
We recommend management within the Medical Examiner’s Office:

A. Establish and/or revise existing policies and procedures to ensure “all”
cremation requests are processed within 12 hours or less daily, or within
24 hours on weekends and holidays, and document when the
performance standard is unachievable.
B. Assign a dedicated person(s) to handle all cremation requests to enhance
accountability and consistency within the process.
C. Inform all funeral homes to utilize the EDRS system for the submission of
their cremation requests on their website.

Engagement Results
Lack of Call Inquiry/Complaint Log or Automated System (pgs. 30 - 31)
WCMEO receives telephone calls regarding complaints/inquiries from a variety of

sources, such as the family of the deceased, funeral homes, and the general public.
Calls received during normal business hours (8:00 AM until 4:00 PM) are answered by
the reception desk and routed appropriately. Calls received after hours are forwarded
to the investigator on duty.
⚫ Calls related to a specific decedent, it is referred to the case investigator on duty,

who documents the call in the CASEManager system in the appropriate case file.
⚫ Calls classified as an inquiry and/or complaint in nature, are not documented in
CASEManager therefore the inquiry or disposition of the call is not captured
⚫ Phones at the WCMEO may go unanswered and/or were placed on hold for an
extended period of time.
⚫ There is no an automated phone system which would allow the transferring of calls
to responsible parties within the MEO.
Engagement Results

We recommend management within the Medical Examiner’s Office:

A. Establish policies and procedures for MEO personnel for receipt and logging of
all inquiry/complaint calls during business hours.
B. Establish policies and procedures for the handling of after hour
inquiry/complaint calls.
C. Establish a log to track all inquiry/complaint calls to include the name(s) of both
the individual making the inquiry as well as the decedent who is the subject of
the request. In addition, the disposition/resolution of the inquiry/call should be
noted for future review.
D. Work with DoIT to implement an automated phone system.

Engagement Results
Implement Service Request Tracking System/Formalize Request Process (pgs. 31 -

32)
Our review disclosed that the WCMEO has not implemented a formalized service request
process nor has a tracking system for providing copies of autopsy reports, photographs,
toxicology reports etc.
In addition, there is no mechanism to process orders online similar to other MEO offices.
Nor is there an associated fee schedule which hinders the efficient processing of service
requests from the public.
Also, by not implementing a formal service request tracking process diminishes

management oversight of services being completed and increases the risk of requests for
service not being fulfilled and/or being fulfilled on a timely basis.

Engagement Results
Implement Service Request Tracking System/Formalize Request Process (pgs.

31 – 32

We recommend management within the Medical Examiner’s Office work with the
Department of Information Technology (DoIT) to:
A. Make available on their website a request form that the public can utilize when
requesting a service, as well as a list of associated fees per service.
B. Implement a formal service request tracking system for all incoming requests for
services. This system should capture information such as the date a service
request was received; payment information; type of service being request; the
staff member assigned to complete the service; the date the service was
completed; as well as when the requested service/documentation was returned to
the requesting party.

Engagement Results
Policies and Procedures Over Personal Property Not Always Followed and Could
be Strengthened (pgs. 32 - 34)
Property arriving with a decedent is to be identified, removed, stored, and released to the
next-of-kin. We judgmentally selected 28 cases to assess the controls over the receipt,
documentation, storage, and release of property. We noted the following areas where
appropriate documentation procedures were not followed:
– Property Disposition Not Accurately Documented in Case Registration Summary
– Property Documented in Case Registration Summary Not Documented the Same in Property
Book
– Property Documented in Property Logbook But Not Documented in Case Registration
Summary
– Release of Property Not Adequately Documented
– Investigator responsible for the case obtains the property, secures it in an envelope, and
records the property in Property Logbook and the CASEManager system. There is no
independent verification of property received.
Not ensuring that adequate controls over property could result in the risk of the
misappropriation of Personal Property, in appearance, or in fact.
Engagement Results
Policies and Procedures Over Personal Property Not Always Followed and
Could be Strengthened (pgs. 32 - 34)
We recommend the Wayne County Medical Examiner’s Office develop and implement
the following policies and procedures:
A. Specific Personal Property detail is to be consistently documented in the Case
Registration Summaries, CASEManager, Property Logbook, and on Property
Envelopes including detailed property description, disposition of property in field,
when obtained, when released and who released to.
B. Requiring an independent verification of property obtained and documented in the
Property Logbook and electronic CASEManager database.

Engagement Results
Emergency Plan Not Communicated (pgs. 34 - 35)
On April 12, 2022, the WCMEO lost total internet access for approximately 10 hours
(2:00 AM until 12 noon).
Chief Investigator and the Administrative Manager, were not aware there was an
Emergency Operating Plan in place to address MEO procedures due to a loss of internet
service.
However, the MEO 2021-2022 Continuity of Operations Plan contains procedures to be

followed in the event of a network failure but was not communicated to staff.
Loss of internet access prevents the WCMEO from providing their services to the public,
including families of decedents and funeral homes.

Engagement Results
Emergency Plan Not Communicated (pgs. 34 - 35)
We recommend management within the Wayne County Medical Examiner’s Office

distribute to all staff the Emergency Operating Plan to address WCMEO operations in
light of an extended loss of internet/phone access. This Plan may include, but not be
limited to:
• Contact information for area hospitals and funeral homes, for proper notification.
• Use of backup cellphones in the office.
• Procedures to be followed by all staff until internet access is reestablished.

OAG Overall Conclusion
As a result of our audit, we determined there are areas where the internal control
environment as well as operational procedures could be strengthened. There were 15
findings and 33 recommendations made to strengthen controls and processes within
the Wayne County Health, Human & Veterans Services, Medical Examiner’s Office.
Five (5) findings are a control deficiency which is deemed low risk, and ten (10) are
significant deficiencies which are deemed medium risk but will require management to
address those areas in the near term.
We assert if management within the WCMEO implements the recommendations they

could help with their due diligence when performing the identification of decedents and
notification to their next-of-kin. In addition, there are recommendations related to
contract compliance concerns which will be instrumental in future contracts for Medical
Examiner Services.

OAG Overall Conclusion (Con’t)
We discussed the issues and corresponding recommendations with representatives

from the Wayne County Department of Health, Human & Veterans Services and the
Wayne County Medical Examiner’s Office. Management agreed with the
recommendations and in many instances have already started implementation of
corrective action. Management’s comments have been included in the report in
Appendix B Views From Responsible Officials.
A Corrective Action Plan will be requested approximately 30 days after this report is
formally received and filed by the Wayne County Commission. If sufficient corrective
action is not taken, a follow-up review may be necessary.

Wayne County Department of Health, Human and
Veterans Services, Contract to Provide Medical
Examiner Services
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Wayne County Health, Human and Veterans Services

Contract to Provide Medical Examiner Services

Office of Legislative Auditor General

The engagement objectives were to:

2 The Office of Legislative Auditor General

⚫ Methodology – To address the objectives outlined for this engagement we:

3 The Office of Legislative Auditor General

4 The Office of Legislative Auditor General

5 The Office of Legislative Auditor General

6 The Office of Legislative Auditor General

Authority and Responsibilities

7 The Office of Legislative Auditor General

Type of Examinations Performed

8 The Office of Legislative Auditor General

⚫ Performance by Year (2019-2021)

9 The Office of Legislative Auditor General

Statistical Information Oakland Vs Wayne County

10 The Office of Legislative Auditor General

Objective 1: Assess the contractor’s compliance with key contract provisions

11 The Office of Legislative Auditor General

12 The Office of Legislative Auditor General

⚫ Facility is not structurally sound as it is in need of repairs.

Noted deficiencies contributed to Provisional Accreditation.

13 The Office of Legislative Auditor General

14 The Office of Legislative Auditor General

15 The Office of Legislative Auditor General

Recommendation #2021-01 – Significant Deficiency

Views of Responsible Officials – See Appendix B in report

16 The Office of Legislative Auditor General

Inadequate Staffing/Board Certification of Pathologists (pgs. 11-13)

⚫ 11 pathologists were required, WCMEO had 7, a shortfall of 4.

17 The Office of Legislative Auditor General

Inadequate Staffing/Board Certification of Pathologists (pgs. 11-13)

18 The Office of Legislative Auditor General

Inadequate Staffing/Board Certification of Pathologists (pgs. 11-13)

Recommendation #2021-02 – Significant Deficiency

We recommend management within the Wayne County Medical Examiner’s Office:

Views of Responsible Officials – See Appendix B in report.

19 The Office of Legislative Auditor General

Medical Investigator Board Certification (pgs. 13-14)

⚫ Noted in NAME accreditation report that majority of medicolegal investigators, working

20 The Office of Legislative Auditor General

Medical Investigator Board Certification (pgs. 13-14)

Recommendation #2020-03 – Significant Deficiency

We recommend management within the Wayne County Medical Examiner’s Office

Views of Responsible Officials – See Appendix B in report.

21 The Office of Legislative Auditor General

Benchmark Reporting Requirements (pgs. 14 - 15)

⚫ Contract requires UMHS to:

22 The Office of Legislative Auditor General

Benchmark Reporting Requirements (pgs. 14 - 15)

Recommendation #2021-04 – Control Deficiency

We recommend management at the UMHS, WCMEO and HHVS:

Views of Responsible Officials – See Appendix B in report.

23 The Office of Legislative Auditor General

Inadequate Insurance Coverage (pgs. 15 - 16)

⚫ Contract requires certain insurance coverages be maintained by each respective party.