Audit Objective
Did the Bedford Central School District (District) officials claim all Medicaid reimbursements to which the District was entitled?
Audit Period
July 1, 2022 – June 30, 2024
Understanding the Program
The District is governed by a seven-member Board of Education (Board) that is responsible for the oversight and general management of financial and educational affairs, including adopting policies.
The Assistant Superintendent for Business (Assistant Superintendent) is responsible for overseeing the District’s budget preparation, including appropriations for special education services. The Director of Special Education (Director) oversees the special education department, including developing and implementing Individual Education Plans (IEPs)1 for students enrolled in special education programs.
The District’s 2023-24 special education budgeted appropriations totaled $18.5 million for therapeutic services such as physical, speech and occupational therapy provided to 658 students with IEPs, 110 of which received services eligible for Medicaid reimbursement. The New York State Education Department (NYSED) and New York State Department of Health (DOH) jointly established the School Supportive Health Services Program (SSHSP) to help school districts (districts) obtain Medicaid reimbursement for certain diagnostic and health support services provided to eligible students. The State’s share of Medicaid reimbursements received by a district is generally 50 percent, which is collected by deducting this amount from a district’s future State aid payment.
Audit Summary
According to a District official, the District has never filed claims for Medicaid reimbursement. Although the District provided 2,379 services to students with IEPs that were eligible for Medicaid reimbursement totaling $1.1 million throughout the two-year audit period, District officials did not submit any claims for reimbursement and as a result, forfeited the District’s share of reimbursement totaling approximately $566,000.
The Board did not adopt written policies for Medicaid billing and officials did not establish Medicaid reimbursement filing procedures, including:
- Assigning responsibilities to District officials for specific activities (e.g., obtaining written orders/referrals documenting the necessity of services and submitting Medicaid claims for reimbursement for services provided to eligible students).
- Annually mailing consent-to-bill forms.
- Requiring providers to log session notes.
- Using the District’s IEP software subscription.
The report includes four recommendations that, if implemented, will improve the District’s Medicaid claim process. District officials disagreed with certain aspects of our findings but indicated they planned to initiate corrective action. Appendix D includes our comments on issues raised in the District’s response letter.
We conducted this audit pursuant to Article V, Section 1 of the State Constitution and Office of the State Comptroller’s (OSC) authority as set forth in Article 3 of the New York State General Municipal Law (GML). Our methodology and standards are included in Appendix E.
The Board has the responsibility to initiate corrective action. A written corrective action plan (CAP) that addresses the findings and recommendations in this report must be prepared and provided to our office within 90 days, pursuant to Section 35 of GML, Section 2116-a (3)(c) of the New York State Education Law and Section 170.12 of the Regulations of the Commissioner of Education. To the extent practicable, implementation of the CAP must begin by the end of the next fiscal year. For more information on preparing and filing your CAP, please refer to our brochure, Responding to an OSC Audit Report, which you received with the draft audit report. The CAP should be posted on the District’s website for public review.
1 The IEP is the cornerstone of the special education process for each individual student with a disability. Each student with a disability must have an IEP in effect by the beginning of each school year. An IEP identifies a student’s unique needs and how the school will strategically address those needs, including how the school’s special education resources will be configured to meet the students with disabilities’ needs at that school.