Purpose

To determine whether New York City School-Based Health Center (SBHC or Center) facilities have implemented proper controls over their medications and related supplies. Our audit covered the period July 1, 2011 to November 21, 2013.

Background

New York State’s School-Based Health Center Program (Program) provides a campus-based health care alternative for preschool, elementary, middle, and high school students in low-income, high-risk communities. The New York State Department of Health (Department) oversees administration of the Program, including the licensing of the independent medical facilities (e.g., hospitals, diagnostic and treatment centers, and community organizations) that sponsor and operate the Centers. Services are provided at no out-of-pocket cost to students or their families. SBHCs bill Medicaid and third-party insurance for reimbursement, as appropriate.

All SBHCs must provide, on-site, a core of age-appropriate primary care services that comply in content and frequency with New York State’s Child/Teen Health Plan. A multidisciplinary team of medical professionals is available through each Center to provide comprehensive primary care and mental health services, including immunizations, urgent care, health screenings and assessments, counseling and referrals, reproductive health care, and health education. SBHC staff can also prescribe and dispense medications, which are procured from an independent pharmacy or the sponsoring organization.

As of November 2013, 222 SBHCs throughout the State provide medical services to nearly 170,000 students enrolled in the Program, accounting for approximately 700,000 health care visits annually. Sixty percent (129) of the Centers are located on New York City Department of Education campuses and serve 111,814 students at 293 schools.

Key Findings

• The sampled New York City SBHCs did not follow Department inventory control regulations for medications and potentially hazardous medical supplies. Ten of the 11 SBHCs sampled had shortages in various medication categories (907 out of 2,298.25 units expected).
• One school had an unexplained shortage of 2,712 hypodermic needles.
• The sampled SBHCs do not maintain proper inventory control over student-supplied medications. They do not record student medication transactions (e.g., medications received from or returned to the parent/guardian or student), nor do they document their contact with parents/guardians to notify them of expired medications or to arrange the return of medications at the end of the school year.
• The sampled Centers’ return of expired drugs to the sponsoring pharmacy was not always properly documented, either by the SBHC or the sponsoring pharmacy.

Key Recommendations

• Require SBHCs to perform periodic physical inventories of their medications and sensitive medical supplies and reconcile discrepancies as appropriate;
• Document all student-supplied medication transactions, including the type and quantity of the medication received or dispensed, as well as pertinent contacts with parents/guardians; and
• Document the disposition of expired medications.

Other Related Audits/Reports of Interest

New York City Health and Hospitals Corporation: Inventory Controls over Controlled Substances (2004-N-4)
Office of Mental Health: Controls over Prescription Drugs (2007-S-111)