Wisconsin
U.S. Department of Health and Human Services Office of Inspector General
Published September 30, 2026

Wisconsin May Have Improperly Claimed $455 Million in Medicaid Reimbursement for Its School-Based Program

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Overall Conclusion

Wisconsin may have improperly claimed Federal Medicaid reimbursement for its school-based program, and the OIG issued six recommendations to recover funds or support costs and to strengthen RMTS and related controls.

Source Document

Audit Scope

Examination of Wisconsin's Medicaid school-based program reimbursements claimed during a four-year period, with focus on RMTS processes, cost allocation, licensing verification, and documentation.

Key Findings Summary

1

Wisconsin may have improperly claimed an estimated $454.9 million in Federal Medicaid reimbursement for its school-based program.

2

At least $67 million improperly claimed based on unsupported RMTS coding and services provided by unlicensed providers.

3

An additional $387.9 million improperly claimed because it could not provide documentation to support ratios used to allocate costs to Medicaid.

View the Findings tab to see all 4 findings

AI-Assisted

Generated by gpt-5-nano

AI Scope Summary

The audit objective was to determine if Wisconsin properly claimed Medicaid school-based program reimbursements over a four-year period, focusing on RMTS methodology, documentation, and licensing verifications. The four-year scope and the finding of potential improper claims led to six recommendations to recover funds or strengthen controls for future audits.

AI-Generated Insight

The audit identifies material risks in the state's RMTS implementation and cost allocation processes, with an estimated $454.9 million in potentially improper Medicaid reimbursements and six recommendations to enhance accountability, documentation, and licensing verification.

Audit Objectives

1

Determine whether Wisconsin properly claimed Medicaid reimbursement of $505.5 million in school-based program services during a four-year period.

Audit Findings (4)

1

Wisconsin may have improperly claimed an estimated $454.9 million in Federal Medicaid reimbursement for its school-based program.

2

At least $67 million improperly claimed based on unsupported RMTS coding and services provided by unlicensed providers.

3

An additional $387.9 million improperly claimed because it could not provide documentation to support ratios used to allocate costs to Medicaid.

4

Additional unallowable costs because RMTSs did not sample moments during the beginning of the school year.

Recommendations (6)

1

Refund the estimated $67,042,719 to the Federal Government related to moments that could not be supported as Medicaid-eligible health services or Medicaid administrative activities.

2

Provide documentation that can reasonably support its allocation of health services costs to Medicaid or refund $387,870,393 to the Federal Government.

3

Ensure that its contractor obtains sufficient information so that the Wisconsin Department of Health Services can validate the contractor's coding of RMTS moments.

4

Ensure that school districts verify and document that providers are appropriately licensed or under the direction of licensed providers before they provide health services to students.

5

Develop an accurate, supportable method to identify Medicaid costs that can be verified with source documents.

6

Revise RMTSs to include the beginning of the school year.