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State Audit Analyzes MSD Reimbursement Procedures

An audit of the Massapequa School District’s Medicaid Revenue Enhancements procedures has found that district officials did not claim a total of $255,285 in costs, and as a result, did not realize a total of at least $63,821 in reimbursement revenues for the 2008-09 fiscal year.

The findings were made public last week by New York State Comptroller Thomas P. DiNapoli, whose office also audited the Dunkirk City School District, the Union Free School District of the Tarrytowns and the Wayland-Cohocton Central School District. 

“My office’s audits of school districts and BOCES help schools improve their financial management practices,” DiNapoli said. “These audits are tools for schools to make sure proper policies and procedures are in place to protect taxpayer dollars and provide students with the best possible education.” 

The total, $63,821, may not sound like much in light of a $172 million annual budget, but the Comptroller’s office was willing to point out both the district’s shortcomings, its strengths, and ways to increase reimbursement revenue in the future.

In its report, the Comptroller’s office said the district had failed to submit claims for “certain Individual Education Plan (IEP)-related services” for 10 students, all of which would have generated an extra $6,102 in additional revenue.

It added also that the district did not obtain, “although [it] did request,” the parental consent required to bill Medicaid for 24 other Medicaid-eligible students. That, the Comptroller’s office said, would have resulted in additional revenue of $40,200.

Finally, the district did not submit claims for “ongoing service coordination” provided to students, which, the Comptroller’s office maintains, could have potentially generated an estimated $5,000 in additional reimbursements.

In one instance, concerning the ongoing service coordination process, the report claims that the district did not “have procedures in place to monitor and reconcile the claims submitted by the consultant to the reimbursed amounts and, therefore, could not know whether all eligible claims property submitted were in fact reimbursed.” 

The report did issue four suggestions for the school district to take in the future; those would help them receive maximum gains in reimbursement revenue. They include:

• Establishing written policies that comply with the new Medicaid requirements to “ensure that the District claims all Medicaid reimbursements to which it is entitled.”

• District officials should improve procedures for obtaining consent from parents of Medicaid-eligible students to allow for filing of Medicaid reimbursement claims.

• District officials should “retain appropriate documentation that is essential for the efficient filing of claims” for reimbursement of all eligible costs.

•  District officials should “maintain access to the CNYRIC website application in order to monitor Medicaid claiming activity,” while reconciling the amounts claimed for reimbursements with the amounts received.


The District’s Response

For its part, the school district had responded to the Comptroller’s report even before it was made public.

In a letter dated Feb. 17, 2011, Alan Adcock, deputy superintendent, said that in February 2007, New York State imposed a moratorium on Medicaid claims for speech, special transportation, and counseling services. When, a year later, the moratorium was lifted, the “rules and requirements for pursuing Medicaid reimbursement were significantly changed,” Adcock noted.

Concerning specific cases, Adcock added that the district has also significantly increased the percentages of signed parental consents, from 64 percent in 2008-09, to 77.6 percent in 2009-10, to, finally, 96 percent in 2010-2011. 

“The Comptroller’s methodology assumed that every child is going to receive every service mandated on the IEP for every month,” Adcock said. “Reality does not always bear this out. Children, especially severely disabled students, may miss school and not receive the scheduled service; the providers may miss days of school for a host of reasons and not be able to provide make-up sessions; and sessions are missed when schools are closed for emergency conditions, including unpredictable weather.” 

On Medicaid reimbursements, Adcock said that it has always been district policy to file Medicaid claims for “only those services that met all of the Medicaid rules.”

Concerning special transportation, Adcock noted that in 2008-90 Medicaid reimbursements could only be claimed if a student used the bus both to and from school. This is not always the case with Massapequa students who for a variety of reasons may only use the bus on a one-way basis. Such discrepancies were not factored into the Comptroller’s review, Adcock said. 

Concerning ongoing service coordination, Adcock said that more discrepancies were involved such as “routine and regular mechanisms” when students received a health care related service.

“To assume that each child would have received a claimable ongoing coordination service just because they received health services is inaccurate,” Adcock wrote.

In the report’s conclusion, personnel in the Comptroller’s office had their own say on Adcock’s defense. They admitted that some of their numbers were based on estimates, which they also claim as done on a “reasonable basis.” The conclusion also recognized the school district’s improved procedure reforms and encouraged ongoing efforts to obtain increased parental consent.