Evidence record

Oversight of Services for Medicaid Members Enrolled in Clinical Trials

Jurisdiction
New York
Publication date
June 4, 2026
Source record
Original document linked
Open original reportOriginal source available

Findings

4

Recommendations

3

Overall conclusion

DOH did not always receive attestation forms prior to members participating in clinical trials, and a limited number of improper Medicaid payments related to investigational services or services not covered by the member’s MCO or lacking prior authorization were identified. DOH officials indicated they will issue reminders to providers about the attestation process and documentation requirements, and OMIG is analyzing identified claims to determine recoveries where applicable.

Scope

Period July 2019 through June 2024; review of DOH oversight of Medicaid payments for services provided to members enrolled in clinical trials, including attestations, Q0 modifier usage, MCO guidance, and related claim data from eMedNY and the Medicaid Data Warehouse.

Findings (4)

Each finding has a stable link.

  1. F-1302

    DOH did not always receive an attestation form before members participated in a clinical trial.

  2. F-1303

    A substantial number of claims related to clinical trials (32,578 claims totaling approximately $94 million for 7,447 members) lacked a corresponding attestation form.

  3. F-1304

    Judgmental sampling identified instances where services should have been billed to clinical trial sponsors rather than Medicaid, and some corrected claims saved Medicaid money ($1,169 from corrected claims; $12,010 saved from one provider's corrections; remaining $113 awaiting adjustments).

  4. F-1305

    Claims with the Q0 modifier (4,813 claims totaling nearly $4 million) indicated investigational services; most were encounter claims; MCOs generally had guidance and system edits, but none performed a risk assessment of clinical trial claims or tracked costs between Medicaid and sponsors.

Recommendations (3)

  1. R-1160

    Remind Medicaid providers to submit the required attestation forms prior to starting clinical trial treatment for Medicaid members.

    Related finding F-1302
  2. R-1161

    Review the $23,631 ($113 + $23,518) in improper payments for investigational claims that should have been billed to the sponsor instead of Medicaid, were not covered by the MCO, or lacked prior authorization, and recover as appropriate.

    Related finding F-1304
  3. R-1162

    Remind providers of the documentation requirements to support Medicaid payments.

    Related finding F-1303