Dr. Shahrzad Haghayegh / Hancock Dental PC
December 11, 2013 · Read the full official report (PDF) ↗
Published December 11, 2013 Audit covers January 1, 2008 – December 31, 2011 Under Suzanne M. Bump · 2011–2023
source
“Consequently, the $89,249 represents questionable costs to the Commonwealth.”
Read the plain-English breakdown
This is a Massachusetts State Auditor performance audit of Dr. Shahrzad Haghayegh / Hancock Dental PC for dental claims paid by MassHealth from 2008 through 2011.
“I am pleased to provide this performance audit of Dr. Shahrzad Haghayegh / Hancock Dental PC.”
The auditor reviewed whether MassHealth paid this provider only for dental services that were necessary, allowed, delivered, and properly documented.
“This audit was conducted to determine whether Dr. Haghayegh was paid only for medically necessary detailed oral screenings and several other selected dental procedures.”
MassHealth is publicly funded healthcare, so billing problems can waste taxpayer money and weaken trust in the program.
“As with any government program, the confidence of the public is essential to the Dental Program’s success and continued support.”
If you are a Massachusetts resident, this matters because MassHealth serves many people and is partly paid for by the Commonwealth.
“MassHealth provides access to healthcare services to approximately 1.3 million eligible low- and moderate-income individuals, couples, and families annually.”
The auditor recommended that MassHealth review or recover multiple payments and also referred possible fraud and abuse issues for further investigation.
“We have also referred this report to the Office of the Attorney General for further review and investigation.”
MassHealth said it would recover overpayments under its rules and had already begun making system changes to prevent some similar claims from being paid again.
“In response to this and our previous audit report on dental billings for detailed oral screenings (No. 2011-1374-3C), MassHealth has begun implementing many of the system edits and other suggested changes that we recommended in these reports.”
The case is significant because the audit found repeated billing and recordkeeping issues across a publicly funded dental program, and MassHealth dental spending was large.
“In fiscal year 2012, MassHealth paid a total of $264,998,490 in dental claims to over 2,000 participating dental providers.”
MassHealth is Massachusetts’ Medicaid program; DentaQuest handled dental claims administration; CHCs and HLHCs are health centers that could receive certain dental enhancement fees; detailed oral screenings were specialized exams limited to certain serious medical situations.
“Under Chapter 118E of the Massachusetts General Laws, the Executive Office of Health and Human Services, through the Division of Medical Assistance, administers the state’s Medicaid program, known as MassHealth.”
5 figure(s) pending source verification - not shown
What the Auditor checked
- Did not comply Determine whether dental claims filed by Dr. Haghayegh were accurate and properly supported by required documentation; services were delivered; and billings and payments were in compliance with applicable laws, rules, and regulations.
What the Auditor found
Why it matters: The Commonwealth made $89,249 in questionable payments for services not allowed under MassHealth rules.
Standard: 130 Code of Massachusetts Regulations 420.456(B)(1) ( 130 Code of Massachusetts Regulations 420.456(B)(1) )
1 recommendation
- MassHealth should review the billings submitted by Dr. Haghayegh for detailed oral screenings and, if warranted, recover the $89,249.agency: agreed
Agency response & Auditor reply
Agency: "MassHealth agrees that Dr. Haghayegh is in violation of MassHealth regulations in billing the service code D0160 [for members undergoing radiation treatment, chemotherapy, or organ transplant]."
Auditor: "Therefore, our audit findings are well founded in that they were developed in accordance with GAGAS, supported by documented evidence, and confirmed by Dr. Haghayegh’s own written statements."
Why it matters: The Commonwealth unnecessarily paid $10,876 for oral evaluations that were not allowable.
Standard: 130 Code of Massachusetts Regulations 420.422 ( 130 Code of Massachusetts Regulations 420.422 )
1 recommendation
- MassHealth should recover $10,876 and ensure DentaQuest and MassHealth modify claims-processing edits to deny claims that violate oral evaluation limits.agency: agreed
Agency response & Auditor reply
Agency: "The Audit Findings state neither statutory nor regulatory support for this allegation and yet characterize it as a “requirement.”"
Auditor: "Our audit finding was based solely on service limits established by MassHealth regulation 130 CMR 420.422, not the ancillary comment made by MassHealth officials."
Why it matters: The Commonwealth paid $2,470 for fluoride treatments the auditor considered unnecessary, and excessive fluoride may create health risks.
Standard: 130 Code of Massachusetts Regulations 420.424(B)(1)(a) and American Academy of Pediatric Dentistry fluoride recommendations ( 130 Code of Massachusetts Regulations 420.424(B)(1)(a); American Academy of Pediatric Dentistry fluoride recommendations )
1 recommendation
- MassHealth should recover $2,470 and add claims-processing edits once fluoride treatment frequency limits are developed.
Agency response & Auditor reply
Agency: "The OSA cannot possibly argue that Dr. Haghayegh violated a regulation that did not exist nor that “recommendations” can be the basis of a sanction."
Auditor: "We agree with Dr. Haghayegh’s attorney that MassHealth had not established a limit on the number of fluoride applications a member could receive per year."
Why it matters: The Commonwealth paid $3,271 in unallowable dental enhancement fees.
Standard: 130 Code of Massachusetts Regulations 420.405(C) and 114.3 CMR 14.02 ( 130 Code of Massachusetts Regulations 420.405(C) )
1 recommendation
- MassHealth should recover $3,271, investigate all dental enhancement fee claims, and develop system edits to deny claims from ineligible providers.agency: agreed
Agency response & Auditor reply
Agency: "MassHealth agrees that Dr. Haghayegh is in violation of MassHealth regulations in billing the service code D9450, which only allows for dental enhancement fees to CHCs and HLHCs."
Why it matters: The condition of the files made it impossible for the auditor to verify the validity of many claims submitted for payment.
Standard: 130 Code of Massachusetts Regulations 450.205(D) and 130 Code of Massachusetts Regulations 420.414(B) ( 130 Code of Massachusetts Regulations 450.205(D); 130 Code of Massachusetts Regulations 420.414(B) )
1 recommendation
- Dr. Haghayegh should ensure her medical records are maintained in accordance with state regulations and support claims submitted to MassHealth.agency: disagreed
Agency response & Auditor reply
Agency: "Dr. Haghayegh disputes that her records are illegible."
Auditor: "The records maintained by Dr. Haghayegh were illegible because of many problems, including poor penmanship, alterations, white-outs, cross-outs, etc., not because of a lack of understanding of dental terminology or abbreviations as implied by Dr. Haghayegh’s attorney."
Why it matters: The Commonwealth paid $24,336 for denture repair claims the auditor considered unallowable and deceptive.
Standard: 130 Code of Massachusetts Regulations 420.428(D) ( 130 Code of Massachusetts Regulations 420.428(D) )
1 recommendation
- MassHealth should determine whether the billings were appropriate, recover $24,336 if not, establish service limits, and develop edits to deny claims exceeding those limits.agency: agreed
Agency response & Auditor reply
Agency: "The medical records and the supporting explanations clearly evidence that the dentures in question were broken, in need of repair, and painful to the MassHealth member."
Auditor: "Despite Dr. Haghayegh’s objection, we still contend that she circumvented MassHealth’s regulations regarding the replacement of dentures."
Why it matters: The Commonwealth paid claims that were not adequately supported, including $17,475 not addressed in other findings.
Standard: 130 Code of Massachusetts Regulations 420.414(B) and 130 Code of Massachusetts Regulations 450.205 ( 130 Code of Massachusetts Regulations 420.414(B); 130 Code of Massachusetts Regulations 450.205 )
1 recommendation
- Dr. Haghayegh should establish administrative procedures to ensure all services are adequately documented, and MassHealth should recover $17,475 after excluding amounts counted elsewhere.agency: disagreed
Agency response & Auditor reply
Agency: "Contrary to the OSA’s claim, other than few, isolated dates of service, Dr. Haghayegh’s records were complete and fulsome."
Auditor: "Contrary to Dr. Haghayegh’s attorney’s contention, Dr. Haghayegh’s records are not complete, and this audit issue does not involve a few, isolated dates of service."
Why it matters: The Commonwealth paid $6,342 in unallowable restoration claims.
Standard: 130 Code of Massachusetts Regulations 420.425 ( 130 Code of Massachusetts Regulations 420.425 )
1 recommendation
- MassHealth should recover $6,342 and MassHealth and DentaQuest should develop a system edit to ensure dental restorations are paid in accordance with state regulations.agency: agreed
Agency response & Auditor reply
Agency: "Finally, Dr. Haghayegh objects to the Audit Findings allegation that her claims reflect a “repetitive pattern” that is “highly questionable.”"
Auditor: "MassHealth’s regulations leave no room for interpretation regarding payments for tooth restorations."
Verified dollar findings
Money paid out that the audit found should not have been - overpayments, unallowable and nonreimbursable charges, improper claims.
Funds recovered or repaid to the Commonwealth.