US
Office of Inspector General, U.S. Department of Health and Human Services
Published September 21, 2026

Medicaid Managed Care: CMS’s Accuracy Check Process For State-Submitted Medical Loss Ratio Data Has Limitations

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Overall Conclusion

The OIG identified limitations in CMS's process to verify State-submitted Medicaid MLR data and recommended procedures to address inaccuracies, with CMS concurring.

Source Document

Audit Scope

Evaluation of CMS's process to verify the accuracy of State-submitted Medicaid Medical Loss Ratio data, including the limited accuracy checks, follow-up actions, and cross-staff communication, as described in the report text.

Key Findings Summary

1

CMS performed only limited accuracy checks on the four required MLR data elements, and those checks showed that some State-submitted MLR data may be inaccurate.

2

CMS did not follow up with States that submitted potentially inaccurate MLR data.

3

Results of MLR accuracy checks were not shared across CMS staff, limiting the ability to inform capitation-rate reviews.

AI-Assisted

Generated by gpt-5-nano

AI Scope Summary

This audit evaluated CMS's verification of State-submitted Medicaid Medical Loss Ratio data, identified limitations in accuracy checks and follow-up, and recommended improvements to data sharing across CMS, to support more reliable capitation-rate decisions in future audits.

AI-Generated Insight

The report highlights data quality risks in Medicaid Managed Care MLR reporting and shows how gaps in internal communication can undermine oversight; strengthening data governance and cross-functional collaboration is critical to reliable capitation-rate setting.

Audit Objectives

1

Assess CMS's procedures for verifying the accuracy of State-submitted Medicaid Medical Loss Ratio data.

2

Determine whether CMS follows up on potentially inaccurate State-submitted MLR data.

3

Evaluate whether CMS shares insights from its reviews of State-submitted Medicaid MLR data with CMS staff responsible for reviewing capitation rates.

Audit Findings (3)

1

CMS performed only limited accuracy checks on the four required MLR data elements, and those checks showed that some State-submitted MLR data may be inaccurate.

2

CMS did not follow up with States that submitted potentially inaccurate MLR data.

3

Results of MLR accuracy checks were not shared across CMS staff, limiting the ability to inform capitation-rate reviews.

Recommendations (3)

1

CMS should establish procedures that outline the steps to be taken to address potentially inaccurate Medicaid MLR data submitted by States and follow up with States, as needed.

2

CMS should ensure that insights from its reviews of State-submitted Medicaid MLR data are communicated to CMS staff responsible for reviewing plans’ capitation rates.

3

CMS should improve the efficiency and effectiveness of its oversight of the accuracy of State-submitted Medicaid MLR data.