Objective

To determine if the Department of Health has provided adequate oversight of the Lead Poisoning Prevention Program. Our audit covered children identified with elevated blood lead levels during the period January 1, 2014 through August 7, 2018 and follow-up activities done by the local health departments through March 19, 2019.

About the Program

Lead poisoning poses a major health risk to children. Lead poisoning is most often the result of inhaling or ingesting lead-contaminated dust. The irreversible effects of lead exposure can include anemia, hearing loss, lower IQ, growth and behavioral problems, kidney damage, and even death. In New York State, the Department of Health (Department) is responsible for administering the Lead Poisoning Prevention Program (Program). The Program, designed to develop and coordinate activities to prevent lead poisoning and minimize exposure to lead, is implemented through local health departments (LHDs). LHDs follow Department guidance in creating programs to address lead-poisoning prevention requirements and provide case management and follow-up services for children based on their elevated blood lead levels (BLLs). Services can range from nutritional and risk education to environmental investigation to determine the source of the lead contamination.

BLLs are tracked through LeadWeb, a Department-maintained system used by LHDs to carry out the required case management and follow-up activities for children with elevated BLLs. The Department’s regional offices are responsible for scheduling and conducting reviews of LHDs’ Program implementation once every three years or more frequently for cause.

Key Findings

• While we found that, in general, the LHDs are providing required Program services to lead-poisoned children, the Department should improve its monitoring of Program implementation to ensure all children with elevated BLLs are receiving required services. We found the following instances of noncompliance with Program requirements:
  • Department regional staff are not consistently scheduling and conducting on-site reviews of LHDs' Program implementation, contrary to the requirement that these reviews be conducted every three years at a minimum. Notably, we found that 4 of the 56 LHDs have not been reviewed since 2010.
  • Five of the eight LHDs we visited had cases where either proper follow-up services were not provided to children with elevated BLLs or a determination could not be made based on the documentation in the case file, accounting for 43 (11 percent) of the 400 case files reviewed. As a result, 37 children did not receive, and 6 children may not have received, the follow-up services required for their BLL.
• Given the Department’s use of LeadWeb as the primary system for monitoring whether lead-poisoned children receive timely care, it is important that the system contain comprehensive, reliable data. However, we found significant issues with the reliability of the system’s data and identified discrepancies between LeadWeb and LHD data.
• On April 12, 2019, the Public Health Law was amended to lower the State standard for elevated BLLs to the level recommended by the Centers for Disease Control and Prevention in 2012. The fact that the number of BLL tests requiring follow-up services under the standard in place during our audit (24,989 tests) was 31 percent of what it would have been under the current standard (80,946 tests) during our test period underscores the importance of improved monitoring of LHD Program operations moving forward, as LHDs will be managing significantly more elevated BLL cases.

Key Recommendations

• Ensure that the risk of exposure to lead is minimized through compliance with Program monitoring requirements.
• Implement the proper internal controls and quality assurance measures to provide adequate assurance that LeadWeb data is complete and accurate before it is used by LHDs or for Department monitoring purposes.
• Develop and enforce regulations requiring LHDs to perform follow-up services for all children whose BLLs meet or exceed the statutorily set levels, or lower levels as may be established, according to rule or regulation.