US
U.S. Government Accountability Office
Published June 28, 2023

Medicaid CMS Oversight and Guidance Could Improve Recovery Audit Contractor Program

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Overall Conclusion

CMS's oversight of the Medicaid RAC program has been inconsistent, with missed opportunities to recover overpayments and improve program effectiveness. Implementing recommended policies and conducting targeted studies could enhance the program's efficiency and recovery potential.

Source Document

Audit Scope

The audit covers the Medicaid Recovery Audit Contractor (RAC) program during fiscal year 2021, including state participation status, CMS oversight practices, exemption processes, and the scope of audits, particularly focusing on the inclusion of managed care payments and the monitoring of program effectiveness.

Key Findings Summary

1

Most states did not participate in the Medicaid RAC program during fiscal year 2021, citing reasons such as having other program integrity initiatives, inability to procure a contractor, and high enrollment in managed care.

2

CMS did not consistently establish or communicate expiration of exemptions for full participation, leading to potential missed opportunities for recovery.

3

Most participating states operated with regulatory exceptions, which could influence program effectiveness.

View the Findings tab to see all 5 findings

AI-Assisted

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AI Scope Summary

The report aims to assess the current state of Medicaid Recovery Audit Contractor programs across states, evaluate CMS's oversight mechanisms, and identify areas for policy and operational improvements to enhance recovery efforts and program integrity.

AI-Generated Insight

The GAO report highlights significant gaps in CMS's oversight and the operational flexibility granted to states, which may hinder the effectiveness of Medicaid overpayment recoveries. Addressing these gaps through policy reforms and targeted analyses could substantially improve fiscal oversight and program integrity.

Audit Objectives

1

Describe the status of states’ participation in the Medicaid RAC program.

2

Evaluate CMS’s oversight of states’ Medicaid RAC programs.

3

Identify opportunities for CMS to improve the Medicaid RAC program.

Audit Findings (5)

1

Most states did not participate in the Medicaid RAC program during fiscal year 2021, citing reasons such as having other program integrity initiatives, inability to procure a contractor, and high enrollment in managed care.

2

CMS did not consistently establish or communicate expiration of exemptions for full participation, leading to potential missed opportunities for recovery.

3

Most participating states operated with regulatory exceptions, which could influence program effectiveness.

4

CMS's oversight was inconsistent, particularly regarding monitoring SPA expiration dates and reporting on program effectiveness.

5

CMS has not conducted a cost-effectiveness study on including managed care in the RAC scope, despite the growth of managed care enrollment.

Recommendations (4)

1

Establish and implement written policies and procedures to document and communicate SPA expiration dates.

2

Establish and implement policies to monitor SPA expiration dates.

3

Describe the effectiveness of the RAC program and include recommendations for improvement in annual reports to Congress.

4

Conduct a study to determine the cost-effectiveness of including managed care payments in the RAC program.