Objective

To determine the extent of implementation of the six recommendations included in our initial audit report, Improper Medicaid Payments Involving Fee-for-Service Claims for Recipients With Multiple Client Identification Numbers (Report 2019-S-22).

About the Program

The Department of Health administers the State’s Medicaid program. Individuals may enroll in Medicaid through Local Departments of Social Services or the NY State of Health (the State’s online health insurance marketplace). Multiple eligibility systems are used to process Medicaid applications and enrollments. Each individual who applies for Medicaid benefits is assigned a Client Identification Number (CIN), a unique identifier. Medicaid recipients may have more than one CIN assigned to them during the time they are in receipt of benefits; however, only one CIN should have active eligibility at a time. Individuals are enrolled into Medicaid fee-for-service (FFS) or managed care.

We issued our initial audit report on September 17, 2020. The audit objective was to determine if improper Medicaid payments were made on behalf of recipients with multiple CINs where at least one CIN was enrolled in FFS. For the period January 1, 2014 through March 31, 2019, the audit identified $47.8 million in Medicaid payments on behalf of recipients with multiple CINs, as follows: $32.6 million in improper premiums for inappropriate managed care enrollments of recipients concurrently enrolled in FFS foster care under different CINs; $12.7 million in improper premiums for managed care enrollments of recipients concurrently enrolled in FFS under different CINs; and $2.5 million in potential duplicate FFS payments made on behalf of recipients with concurrent FFS enrollments under different CINs. The Office of the Medicaid Inspector General (OMIG) recovers improper premium payments for foster care recipients with multiple CINs and, by the end of our fieldwork, $16.6 million of the $32.6 million in improper payments identified were voided. However, we determined OMIG does not have a process to recover improper payments for non-foster care recipients with concurrent FFS enrollment or improper FFS payments for recipients with multiple FFS enrollments.

Key Finding

Officials have made little progress in addressing the problems we identified in the initial audit report and significant action is still required. In particular, OMIG has done very little to review and recover the outstanding Medicaid overpayments we identified. Of the initial report’s six audit recommendations, two have been partially implemented and four have not yet been implemented.

Key Recommendation

Officials are given 30 days after the issuance of the follow-up report to provide information on any actions that are planned to address the unresolved issues discussed in this report.