New York City Comptroller’s Contract School Nurses Investigation

On December 20, 2021, the Deputy Comptroller for Audit and Investigation by letter provided the New York City Department of Health and Mental Hygiene (DOHMH) and New York City Department of Education (DOE) with the results of an investigation the New York City Comptroller’s Office conducted of the Office of School Health’s (OSH) Management of Contract Nursing Assignments, including recommendations to identify all instances of past overbilling and overpayment and recoup any overpayments. In this investigation, DOE and DOHMH, jointly through OSH, collaborated with our staff to identify likely causes of billing discrepancies and seek solutions to prevent them going forward. Our recommendations include further steps to consolidate and build on the progress the respective agencies have made in addressing the issues.

Findings in Brief

• DOE’s payments to vendors totaled over $130 million for more than 400,000 contract nursing assignments over the nearly three-year period from July 1, 2016 through March 28, 2019
• Because OSH did not require vendors to submit timesheets for most nursing assignments, the DOE paid $53,593,287 (approximately 41 percent of total payments) without verifiable evidence that the corresponding services had been provided
• Because DOE’s payments were based on pre-scheduled nursing assignments, rather than on services detailed in timesheets, the payments often reflected uncorrected discrepancies between services scheduled and services provided. For example, the DOE paid vendors who billed for services using the scheduled nurse’s name even though the vendor’s timesheets indicated that a different nurse provided the service.

Corrective Actions taken by OSH

OSH acknowledged deficiencies during the investigation and reported that it implemented the following changes to its systems and procedures because of this investigation:

1. OSH now obtains, reviews, and reconciles timesheets for all types of nursing assignments.
2. OSH now updates DOHMH’s scheduling system, known as the Agency Nurse Tracking system (ANT), to ensure that the nursing assignment data it contains is supported by timesheets before transmitting such data from ANT to DOE’s Vendor Portal payment system, known as VPortal, and before it approves payment for the services.
3. ANT and VPortal each now include edits to identify and prevent scheduling and billing errors, including overlapping assignment start and end times for a single contract nurse on the same day.

Recommendations

1. Identify all instances of past overbilling and overpayment;
2. Recoup any overpayments;
3. Establish audit and review procedures to ensure the ongoing performance and monitoring of corrective actions already implemented during the investigation;
4. Publish the list of allowable and unallowable combinations of nursing services to its staff and vendors together with the criteria and procedure for allowing any exceptions;
5. Verify that DOHMH’s scheduling system, known as the Agency Nurse Tracking system, prohibits the scheduling of unallowable combinations; and
6. Monitor billing to ensure revised processes and systems are working to prevent instances of overbilling and overpayment.

The complete letter is posted on this page.