Office of the Medicaid Inspector General

STATE OF NEW YORK OFFICE OF THE MEDICAID INSPECTOR GENERAL 250 Veterans Memorial Highway, Room 4A12 Hauppauge, New York 11788 (631) 952-6386 Fax: (631) 952-6415 GEORGE E. PATAKI KIMBERLY A. O’CONNOR GOVERNOR MEDICAID INSPECTOR GENERAL

December 7, 2006

Mr. John J. Finello, Superintendent Huntington Union Free School District 50 Tower Street Huntington, NY 11746

Re: CAR #05-1569 Provider #01379813

Dear Mr. Finello:

This letter is the final notification of our findings from our recently completed review of the documentation supporting claims that Huntington Union Free School District (UFSD) submitted under the School Supportive Health Services Program (SSHSP). The SSHSP assists school districts in obtaining federal Medicaid funds for certain diagnostic and health related services that traditionally have been funded exclusively through educational resources.

PURPOSE AND SCOPE

The purpose of this Corrective Action Review was to ensure compliance with applicable Federal and State laws, regulations, rules, and policies governing the New York State Medicaid Program and to verify that:

 Medicaid reimbursable services were rendered for the dates billed;

 Appropriate rate codes were billed for services rendered; and

 Student-related records contained the documentation required in the School Supportive Health Services Program Medicaid Claiming Handbook (#5) and all applicable updates.

The scope consisted of a review of 122 sample claims, representing each type of service for which Huntington UFSD received Medicaid payments, totaling $44,189.60 during the period March 31, 2004, through March 30, 2005.

SUMMARY

Huntington Union Free School District’s Medicaid records were organized, but claims were not always supported by adequate documentation. There were 18 sampled claims identified, totaling $6,434.00, 2 that must be voided. In addition, we found 4 service categories that have systemic errors (2 or more of the same type of error within a service category).

DETAILED FINDINGS

UNALLOWABLE CLAIMS

No Social History For sampled claims number 18, 19, 20, 21, 24 and 25, the comprehensive psychological evaluations had no social histories.

The Medicaid Claiming/Billing Handbook states, “Comprehensive Psychological Evaluation is a diagnostic evaluation and testing to study and describe a student’s developmental, learning, behavioral and other personality characteristics. It includes social history which means a report of information gathered and prepared by qualified school district or preschool personnel pertaining to the interpersonal, familial and environmental variables which influence a student’s general adaptation to school or preschool, including but not limited to data of family composition, family history, developmental history of the student, health of the student, family interaction and school or preschool adjustment of the student.” Update # 5, page 14

This error resulted in an overpayment of $1,872.00. The school district is to void these claims. They may be resubmitted as basic psychological evaluations. Due to the systemic determination of this error, the school district is to review comprehensive psychological evaluations claims for social histories, retroactive to July 1, 2002, and void any that are inappropriate. Voided claims may, however, be re-submitted for basic psychological evaluations should the documentation support rebilling.

Student Classified from Previous Individualized Education Program (IEP) Review For sampled claims number 78 and 82, the students were given an initial review while still classified from a previous school.

The Medicaid Claiming/Billing Handbook states, “An initial can only be billed when an unclassified student is referred to the CSE for an initial IEP and a CSE meeting is held.” Update # 5, page 20

This error resulted in an overpayment of $1,550.00. The school district is to void these claims. They may be resubmitted for the appropriate review. Due to the systemic determination of this error, the school district is to review claims, to determine if classified students were given initial reviews, retroactive to July 1, 2002, and void any that are inappropriate. Some of these claims may be re-billed at the lesser rate for either an Amended Review ($520.00), or a Re-evaluation Review ($492.00), as outlined in the State Education Department January 2002 Memorandum – Students Transitioning from Preschool to School Age. Re-billing may further be restricted by the requirement that no more than three billings in a nine-month period are submitted for an Amended Review, or one bill in a nine-month period is submitted for a Re-evaluation Review.

No Meeting /No IEP For sampled claims number 77, initial review, and 103, triennial/reevaluation review, the District could not find the Committee on Special Education (CSE) meeting notes and the IEP. 3 The Medicaid Claiming/Billing Handbook states, “Service Documentation: The completed IEP (identified as an initial) and CSE minutes of the meeting. For a student referred but not classified, the documentation is the initial IEP with a notation “no services”, if available, and/or the CSE meeting minutes with an indication that services were not necessary.” Update # 5, page 20

The Medicaid Claiming/Billing Handbook states, “Service Documentation: The completed IEP (identified as a re-evaluation or triennial review) and minutes of the CSE meeting.” Update # 5, page 21

These errors result in an overpayment of $1,267.00. The school district is to void these claims.

Missing Referrals for Evaluations For sampled claims number 3 and 4, specialist medical evaluation, and 5, 6 and 7, audiological evaluation, the school district could not find referrals for the evaluations.

The Medicaid Claiming/Billing Handbook states, “Evaluation must be by referral in writing from a licensed physician, a registered physician’s assistant under the supervision of a licensed physician, or a licensed nurse practitioner within the scope of the Nurse Practice Act.” Update # 5, page 15

The Medicaid Claiming/Billing Handbook states, “Evaluation must be referred in writing by a licensed physician, registered physician assistant or a licensed nurse practitioner. Update # 5, page16

These errors resulted in an overpayment of $684.00. The school district is to void these claims. Due to the systemic determination of both categories, the school district is to review specialist medical evaluations and audiological evaluations for proper referrals, retroactive to July 1, 2002, and void any that are inappropriate.

Wrong IEP Billed Sampled claim number 98 was billed as a reevaluation review. It should have been claimed as an annual review.

This error resulted in an overpayment of $492.00. The school district is to void this claim. It may be reclaimed as an annual review.

Minimum Services Not Met For sampled claim number 70, there was only one occupational therapy service documented for the review month; this did not meet the minimum requirement of 2 documented services for the month.

This error resulted in an overpayment of $422.00. The school district is to void this claim.

Missing Evaluation Report For sampled claim number 2, there was no medical evaluation report found. 4 The Medicaid Claiming/Billing Handbook states, “Medical evaluations must be signed and dated by a licensed physician, licensed nurse practitioner (according to the Nurse Practice Act) or a registered physician assistant under the supervision of a licensed physician.” Update # 5, page 15

This error resulted in an overpayment of $147.00. The school district is to void this claim.

PROCEDURAL ERRORS

We also noted the following procedural issue which does not require the payment to be voided, but does require corrective action by the District.

Service Claimed in Wrong Month For sampled claim number 26, the comprehensive psychological evaluation was claimed for the month it was started, but it was completed the following month. The school district must implement procedures to ensure that an evaluation is claimed for the month it is actually completed.

IMPACT

The total actual Medicaid overpayment for this review is $6,434.00. These findings were discussed with you and your staff at our Exit Conference of October 4, 2006. We were informed that the District would void all inappropriate claims and initiate corrective action. Within 60 days of the issuance of this letter, please submit to Susan Wise:

 Documentation of claims voided including identifying sample number, date(s) of service, eMedNY cycle number and date voided.

 A written explanation of corrective action taken by the school district.

The Office of the Medicaid Inspector General may follow-up with the Huntington UFSD to determine if the needed corrective action identified during this review has been implemented.

Thank you for your cooperation in this matter. If you have any questions related to this review, please contact Susan Wise at (631) 952-6390.

Sincerely,

DBM by Denise Marshall

D. Bruce Malito, Director 5 Long Island Regional Office

cc: Harold Matott, SED Dr. Vicki L. Mingin, Executive Director Special Education and Student Support Services