US
Office of Inspector General, Department of Health and Human Services
Published December 2024

Twelve Selected States Did Not Accurately Calculate the Federal Share of Medicaid Collections Subject to the Increased COVID-19 Federal Medical Assistance Percentages

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Overall Conclusion

Twelve of the thirteen selected States did not accurately calculate the Federal share of Medicaid collections subject to the increased COVID-19 FMAP, resulting in net underreporting of $61.8 million. CMS concurred with all four recommendations and described actions to address them, including correcting reporting, recoupments/refunds, and strengthening oversight.

Source Document

Audit Scope

The audit analyzed the Federal share of Medicaid collections reported on CMS-64 related to the increased COVID-19 FMAP across the 50 States and the District of Columbia, focusing on 13 nonstatistically selected States for detailed review out of 17 identified states. The review covered $1.7 billion in Federal share related to $3.017 billion in Medicaid collections subject to the increased COVID-19 FMAP from January 1, 2020, through June 30, 2022. The increased COVID-19 FMAP provided a temporary 6.2 percentage point increase to regular FMAPs effective January 1, 2020, through December 31, 2023, with the rate beginning to phase down on April 1, 2023. The audit also examined CMS’s oversight and documentation supporting its review of six States’ collections and assessed adherence to CMS policies; the CMS-64 reporting timeline and the treatment of lines 9A–9G for collections. The scope included evaluation of procedures for identifying applicable FMAPs and calculating the Federal share, potential recoupments or refunds, and the adequacy of CMS’s oversight controls.

Key Findings Summary

1

CMS reviewers detected at least one instance where a State was instructed to adjust for the increased FMAP for TPL, but no corrections were made.

2

CMS oversight reviews often did not detect calculation errors during CMS-64 reviews; reviewers did not consistently verify that increased FMAP for all collection types was properly supported.

3

Twelve of the 13 selected States underreported the Federal share of Medicaid collections subject to the increased COVID-19 FMAP by a net $61,792,714 due to using incorrect FMAPs and calculation errors.

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AI-Assisted

Generated by gpt-5-nano

AI Scope Summary

The audit aimed to verify that selected States accurately calculated the Federal share of Medicaid collections during the COVID-19 FMAP increase and to identify miscalculations and CMS oversight gaps requiring corrective action.

AI-Generated Insight

The audit highlights the financial significance of FMAP-based reporting errors during the COVID-19 emergency and reveals gaps in CMS oversight that allowed miscalculations to occur across multiple States and collection types. Strengthening validation across all collection types and FMAP periods is critical to safeguarding Federal funds and program integrity.