CMS Should Improve Its Policies and Procedures for the Oversight of States’ Reported Medicaid Expenditures to Better Protect the Financial Integrity of the Medicaid Program

CMS did not consistently follow its policies and procedures related to the oversight of Medicaid State expenditures reported on the CMS-64. Specifically, CMS’s quarterly review work papers for five selected States that we reviewed were not always clear, accurate, or consistent enough to validate that its analysts thoroughly completed all procedures outlined in its Review Guide.

CMS’s policies and procedures related to deferred expenditures did not adhere to the timely resolution timelines set forth in Federal regulations, resulting in deferred payments remaining unresolved for years.

CMS’s policies and procedures related to tracking of disallowed expenditures need improvement to allow for more accessible and accurate reporting of disallowed payment information.

Develop and implement additional training for analysts to improve the clarity, accuracy, and consistency of their documentation for reviewing CMS-64s.

Revise its policies and procedures related to deferred payments to align the deferral resolution timelines with Federal regulations.

Modify its policies and procedures to specify which CMS departments are responsible for tracking and resolving disallowed payments.

Modify its Review Guide to include a step that requires analysts to determine the status of disallowed payments.