Kentucky
Kentucky Auditor of Public Accounts
Published September 17, 2025

How Kentucky Failed to Prevent Over $800 Million of Medicaid Waste

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Overall Conclusion

Concurrent capitation payments across state lines resulted in substantial waste (over $800 million) during 2019–2022 due to gaps in residency determination, PARIS/T-MSIS data usage, and contract obligations with MCOs; remedies include stronger leadership, proactive data sharing, expanded federal data access, updated policies and procedures, and enhanced training to prevent future waste.

Source Document

Audit Scope

Examination period January 1, 2019 through December 31, 2022; Kentucky Medicaid capitation payments to managed care organizations (MCOs) for enrollees concurrently enrolled in Kentucky and at least one other state; analysis of T-MSIS data provided by HHS OIG; random sample of 100 enrollees from the top ten states by concurrent capitation payments; selection of subgroups; review of PARIS data, CHFS processes, and DMS/DCBS contracts.

Key Findings Summary

1

Kentucky paid MCOs $836,364,425 in capitation payments for enrollees concurrently enrolled in Kentucky and at least one other state during 2019–2022, involving 103,907 unique enrollees across 48 states.

2

Of the 100 sampled enrollees, 92 were linked to a single series of months, while 8 were linked to two or more series of months, indicating that PARIS alerts were issued for multiple series of months for some enrollees.

3

Case files lacked evidence that PARIS alerts had been issued for 37 enrollees, and for the remaining 63 enrollees it was unclear whether alerts were issued for the specific month in question.

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AI-Assisted

Generated by gpt-5-nano

AI Scope Summary

Objective: Assess whether Kentucky Medicaid paid capitation payments for beneficiaries concurrently enrolled in other states during 2019–2022, using a stratified random sample of enrollees and subgroups, and assess data controls and contracting adequacy that would prevent future concurrent payments across state lines.

AI-Generated Insight

The report identifies a systemic issue in cross-state Medicaid capitation payments driven by incomplete data access and fragmented processes; resolving it requires coordinated action across state agencies, MCO contracts, and federal data systems to prevent avoidable waste.