Evidence record
Twelve Selected States Did Not Accurately Calculate the Federal Share of Medicaid Collections Subject to the Increased COVID-19 Federal Medical Assistance Percentages
- Jurisdiction
- AlabamaCaliforniaColoradoConnecticutFloridaIndianaMassachusettsMinnesotaNew HampshirePennsylvaniaVirginiaWisconsinWyoming
- Publication date
- December 2024
- Source record
- Original document linked
Findings
5
Recommendations
4
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.
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.
Findings (5)
Each finding has a stable link.
- F-290
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.
- F-291
One State (Wyoming) overreported the Federal share of Medicaid collections, and one State (Wisconsin) reported the correct Federal share.
- F-292
States did not consistently follow their own procedures for calculating the Federal share; manual keying errors and Excel formula errors contributed to miscalculations.
- F-293
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.
- F-294
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.
Recommendations (4)
- R-277
Require States to correct the reported Federal share of Medicaid collections subject to the increased COVID-19 FMAP by recouping $62,504,429 from the 11 underreporting States and refunding $711,715 to 1 overreporting State.
Related finding F-290 - R-278
Emphasize to States that they should consistently follow their procedures for calculating the Federal share of collections, including during periods of increased FMAPs.
Related finding F-292 - R-279
Reinforce with CMS reviewers that the increased Federal share for TPL collections is properly supported, including accounting for any increases in FMAP that may be available.
Related finding F-293 - R-280
Revise CMS policies and procedures for reviewing States’ reported collections to include review of States’ calculations of the Federal share for all collections.
Related finding F-293