Review of Medicaid Speech Claims Made by the New York City Department of Education

EXECUTIVE SUMMARY:

Our objective was to determine whether Federal Medicaid payments for speech services claimed by New York City Department of Education were in compliance with Federal and State requirements.  Eighty-six of 100 speech claims in our sample did not comply with requirements and 68 of the sampled claims contained more than 1 deficiency.  Specifically: (1) For 42 claims, we were unable to verify that the services billed were rendered.  (2)  For 47 claims, we were unable to verify that a minimum of 2 speech services were rendered during the month billed.  (3) Two claims lacked any documentation at all.  (4)  Forty-three claims lacked a referral by an appropriate medical professional.  (5) For 24 claims, no child's plan/family plan was provided or the plan was untimely.  (6) One claim did not include a recommendation for speech services in the child's plan/family plan.  (7) For 76 claims, the services were not provided by or under the direction of an individual certified by the American Speech-Language-Hearing Association or a similarly qualified person.  As a result, we estimate that the State improperly claimed $435,903,456 in Federal Medicaid funding during our audit period.

We recommend that the State (1) refund $435,903,456 to the Federal Government, (2) provide proper and timely guidance on Federal Medicaid criteria to New York City Department of Education, (3) reinforce the need for New York City Department of Education to comply with Federal and State requirements, (4) improve its monitoring of New York City Department of Education's speech claims to ensure compliance with Federal and State requirements, and (5) instruct New York City Department of Education to maintain appropriate documentation to support its speech claims.  In written comments on our draft report, State officials disagreed with most aspects of the report, including the audit period, approach, criteria, and conclusions, and stated that the draft report should be withdrawn.  The State also expressed concern that we had applied Federal regulations designed for a medical office setting to an educational setting and that we had not conducted our audit in accordance with generally accepted government auditing standards.