In its FY 2011 Work Plan, the U.S. Department of Health and Human Services Office of the Inspector General (OIG) announced plans to audit school-based Medicaid direct service billing and Medicaid Administrative Claiming (MAC) programs. Although reviews of school-based Medicaid programs have often been included in the OIG’s annual Work Plans, this is the first time school-based services have been specifically targeted since the FY 2008 Work Plan. The FY 2011 Work Plan states that the OIG “will review Medicaid services provided in schools to determine whether payments for school-based services complied with laws and regulations.” The document also stated that “prior OIG reviews of school-based services found significant unallowable payments.” In its fall 2010 Semiannual Report to Congress, the OIG described the results of its 2010 audits of school-based services in Arizona and New Jersey that found unallowable payments.
On March 9, 2011 the Inspector General gave testimony before a U.S. Senate subcommittee regarding its new tools to curb Medicaid waste and fraud and stated, among other things, that the OIG has “conducted a series of audits over the past decade, identifying improper federal Medicaid payments for school-based health services.”
Often, negative findings in audits of school-based Medicaid programs are related to inaccurate, inadequate or missing service documentation. PCG Education provides Web-based IEP development and service documentation tools to promote accurate and appropriate documentation by school-based clinicians. The PCG Education team also conducts periodic training sessions with clinicians to help them understand the importance of accurate service documentation.