Evidence record
Medicaid Payments to MCOs for Deceased Individuals
- Jurisdiction
- Nebraska
- Publishing agency
- Nebraska Auditor of Public Accounts
- Publication date
- August 21, 2025
- Source record
- Original document linked
Findings
7
Recommendations
4
Overall conclusion
The DHHS procedures for identifying deaths, updating records, and recouping post-death Medicaid payments were found to be insufficient to prevent improper disbursements to MCOs. While some adjustments and recoupments have begun, there are notable opportunities to strengthen internal controls and data interfaces to reduce the risk of fraud or misuse of state funds.
Scope
Review of March 2025 Medicaid capitation payments to MCOs, cross-checks with Vital Statistics death records, NFOCUS interfaces, and MMIS data; analysis through August 4, 2025; includes 13 deceased recipients across 4 MCOs with overpayments totaling $65,554.43 and ongoing recoupment.
Findings (7)
Each finding has a stable link.
- F-1080
Four Medicaid MCOs identified receiving March 2025 capitation payments for 13 deceased recipients, with overpayments totaling $65,554.43.
- F-1083
MMIS eligibility end dates were sometimes established after the date of death or ended with the status Not Eligible instead of Recipient Deceased, resulting in continued payments after death totaling substantial sums (e.g., $12,409.07 in one set; $26,951.37 across five cases).
- F-1081
NFOCUS did not receive automated death notices from Vital Statistics for certain recipients, leading to untimely death verifications and continued payments.
- F-1082
Several cases were closed or reopened due to death timing and renewal issues, causing delayed action and continued payments.
- F-1084
Recipients listed as Not Eligible rather than Recipient Deceased in MMIS, delaying recognition of death and end-date updates.
- F-1085
MMIS reason codes were changed to Recipient Deceased after APA inquiry, and some overpayments had not yet been recouped as of August 4, 2025.
- F-1086
As of August 4, 2025, DHHS had adjusted and begun to recoup the overpayments for 3 of the 13 Medicaid recipients.
Recommendations (4)
- R-959
Strengthen procedures to ensure all payments are proper and allowable, precluding disbursements to MCOs for deceased individuals unless for services provided prior to death.
Related finding F-1080 - R-960
Correct and recoup overpayments in a timely manner and update records promptly to reflect accurate dates of death.
Related finding F-1085 - R-961
Establish and/or enhance interfaces with systems containing death information (Vital Statistics, NFOCUS) to ensure automated case notices trigger timely eligibility end-date updates.
Related finding F-1081 - R-962
Improve staff training and ongoing monitoring related to Vital Statistics notices, death date verification, and case closure decisions to prevent future overpayments.
Related finding F-1082