The scheme

• 25 people were charged with wire fraud – administrators and employees of three Florida nursing schools as well as recruiters.
• The recruiters sought out individuals that were willing to pay $10,000 to $15,000 for fake nursing school documents that allowed them to take national nursing licensure examinations.
• A total of 7,600 fake nursing diplomas and transcripts (completion of required courses and clinicals) were provided to individuals from all over the US. The buyers wanted to take licensing exams to become registered nurses, licensed practical nurses, or licensed vocational nurse licenses.
• The three now closed nursing schools that issued the fake documents were Siena College, Sacred Heart International Institute, and Palm Beach School of Nursing.
• None of the individuals that bought the fake documents have been charged (yet).

Why is this Important?

• In a NY Times article, the special agent in charge for the Miami region of the Office of Inspector General said approximately 2,800 buyers passed the licensure exam.
• A large percentage of the 2,800 that passed are working.
• The NY Times article stated that providers that hired these nurses “included Veterans Affairs hospitals in Maryland and New York, a hospital in Georgia, a skilled nursing facility in Ohio, a rehabilitation center in New York and an assisted-living facility in New Jersey.”

What to do?

• Conduct an application education audit for all current RN, LPN or LVNs. Look for any that received a nursing degree from Siena College, Sacred Heart International Institute or Palm Beach School of Nursing.
• Audit your nursing staff screening process for criminal background checks, active licensure as well as monthly review of the federal OIG exclusion lists and if applicable, state exclusion lists. But, please note that at this time, these reviews would not identify any nurses that “bought” their degrees from these schools.
• Update your compliance program. Cite the DOJ press release as a new potential risk area and include any policy review, policy updates or audits. Don’t forget to summarize audit findings even if there is no evidence of any problems or concerns.
  
  Program updates can be summarized for reporting to your leadership and board. The OIG wants to see an active compliance program. Continuous documentation provides clear evidence that your compliance program is changing due to new risks, periodic policy review/updates and/or new audits.