Official Site of The State of New Jersey

TRENTON — The New Jersey Office of the State Comptroller (OSC) found that Bonnie Brae, a provider of residential treatment services for youth whose main location is in Liberty Corner, Bernards Township, failed to adequately document contractually required clinical and other services, and, in some cases, failed to provide minimum required services under its Medicaid contracts, and must repay more than $1.5 million to the Medicaid program.

An OSC Medicaid Fraud Division audit determined that Bonnie Brae’s records were unreliable, inconsistent, and in some cases implausible, preventing OSC from verifying that Bonnie Brae delivered required therapy, psychiatric care, and case management services to vulnerable youth in their care.

The audit found that Bonnie Brae:

• Failed to maintain documentation supporting required service hours, while cumulative documentation suggested staff performed hundreds more hours of services than reflected in employee timesheets. The differences would have required approximately 10 additional full-time staff to account for the gap.
• Documented individual therapy sessions that overlapped in time, which could not have occurred as documented.
• Submitted nearly identical progress notes across multiple patients and sessions.
• Documented services for youth who, according to other documents, were absent.
• Documented services for clinical coordinators during periods when those individuals were documented as absent.
• Provided documentation that showed Bonnie Brae failed to meet minimum required hours for clinical therapy and psychiatric services for multiple youth.
• Employed two unlicensed clinical coordinators.

Due to these deficiencies, OSC determined that Bonnie Brae could not demonstrate that it satisfied Medicaid regulations and provided the volume of services required under its contracts. Accordingly, OSC recommended that Bonnie Brae return $1,528,109 to the Medicaid program.

Medicaid paid Bonnie Brae approximately $34.4 million during the audit period, and more than $91 million over a five-year period.

Given that Bonnie Brae serves youth with significant emotional, behavioral, and mental health needs, the documentation failures highlighted in OSC’s report raise serious concerns whether vulnerable youth in Bonnie Brae’s care received the care to which they were entitled - services DCF contracted for and Medicaid paid Bonnie Brae to provide.

“Accountability matters, especially when it comes to the care of some of New Jersey’s most vulnerable youth,” said Acting State Comptroller Shirley U. Emehelu. “Providers receiving Medicaid funding must deliver the services they bill for and maintain accurate records to prove it. When they fail to do so, we will take action to protect both Medicaid beneficiaries and taxpayers.”

OSC recommended that Bonnie Brae improve its documentation practices, meet its contractual requirements, verify that its staff are properly licensed, and reimburse the Medicaid program. Given the scope of the findings, OSC also recommended that Bonnie Brae retain an independent third-party monitor to oversee compliance and reporting.

Bonnie Brae submitted a corrective action plan outlining steps it states it has taken and plans to take to address the findings, but it did not address repayment of the identified overpayment.

Read the report.

Sign up for OSC's newsletter.

To report government fraud, waste, mismanagement, or corruption, file a complaint with OSC or call 1-855-OSC-TIPS.