THE MAJORITY OF UTAH RESIDENTS ENDORSE THE EXPANSION OF MEDICAID UNDER ACA

By Howard Green

Just under 60% of Utah residents side with the expansion of Medicaid under the ACA so as to include a greater number of low-income adults, according to a recent poll. A strong majority of Utahns stand behind a complete Medicaid expansion, according to the poll carried out by Dan Jones and Associates for UtahPolicy.com.

Thirty-six percent protest the expansion of Medicaid under the Affordable Care Act, whereas four percent said they "don't know."

There certainly are hopes from activists that a voter referendum next year will expand the state's Medicaid program. The group has up until the middle of April to gather the required 113,143 signatures to get on the November 2018 ballot. Those that advocate the initiative were motivated after a similar effort in Maine passed by voter referendum last month.

Activist groups in Idaho are also aiming to get on the state's ballot next year.

31 states and Washington, D.C., have extended Medicaid under the Affordable Care Act.

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GAO REPORTS $95 BILLION WASTED IN FISCAL 2016

By Howard Green

The GAO announced this week that The Centers for Medicare & Medicaid Services will need to create a much more rugged risk-based anti-fraud solution for the Medicare and Medicaid programs. Improper payments within both programs totaled about $95 billion in fiscal 2016.

The GAO, in a report published on December 5, 2017, indicated that CMS's anti-fraud objectives merely "partially align" with the GAO's fraud risk framework, which gives guidance on developing anti-fraud initiatives. The report notes that despite the fact that CMS has implemented anti-fraud training programs for stakeholders such as service providers, it does not require equivalent awareness training for agency staff members.

The report also declared that CMS does not have a fraud risk assessment for Medicare and Medicaid, in conjunction with an anti-fraud strategy for both programs.

"By developing a fraud risk assessment and using that assessment to create an anti-fraud strategy and evaluation approach, CMS could better ensure that it is addressing the full portfolio of risks and strategically targeting the most-significant fraud risks facing Medicare and Medicaid," the GAO stated.

In response, HHS said it will develop risk-based anti-fraud strategies for both Medicare and Medicaid after it completes its ongoing fraud-risk assessment of the federal healthcare marketplace.

The report was driven in part by earlier GAO assessments that determined both Medicare and Medicaid as having a great risk for fraud, waste, and abuse.

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TACKLE MEDICAID’S IMPROPER CLAIMS PAYMENTS WITH DATA, NOT ‘PAY AND CHASE’

By Howard Green 

The federal government must quickly move away from the “Pay and Chase” model where Medicaid routinely makes improper claims payments (those that were the liability of primary insurance plans), then retrospectively identifies the claims with third party liability. To make this change, the government must review and remedy the current, antiquated processes that are in place.

Medicaid is the payer of last resort; in other words, by law, all other sources of insurance coverage must pay for claims before Medicaid will pay for the care of an enrollee. This federal requirement is called third party liability (TPL). This means claims payments are the obligation of a third party other than the enrollee or Medicaid. To employ the Medicaid third party liability requirements, federal regulations mandate that states have processes in place to identify other health insurance (OHI) and process claims accordingly.

As much as 13 percent of Medicaid enrollees across thenation hold additional insurance other than Medicaid. Types of TPL include employee insurance, Workers’ Compensation, Medicare, COBRA health insurance from former employment, casualty insurance, dental insurance, eye insurance and insurance to cover pharmaceutical costs. Given the large numbers of Medicaid enrollees with “other health insurance,” the timely identification of TPL and mitigating improper claims payments equates to massive savings for the program.

In a recent GAO report, Medicaid accounted for 25% of government-wide improper payments amounting to $36 billion. The GAO noted that while states have improved TPL efforts in recent years, the increasing proportion of Medicaid enrollees with private health insurance creates additional opportunities to avoid and recover Medicaid funds (GAO 2015).

 TWO WAYS TO AVOID COSTS ASSOCIATED WITH IMPROPER CLAIMS PAYMENTS

Pay and chase. If primary insurance is discovered after a claim had been paid improperly, the Medicaid plan must pay the claim and then attempt to recover the money from the primary insurer. This has been the primary model for most TPL efforts; unfortunately, this approach is burdened with hefty administrative costs. When “Pay and Chase” is used to recover improper claims payments, an average of only 17% of the funds ever gets recovered. This is precisely why Medicaid programs must hasten their move away from the “Pay and Chase” model.

Cost avoidance. If the Medicaid plan is aware that an enrollee has primary insurance coverage when the claim is filed, the plan can reject the claim and instruct the provider to submit it to the potential primary payer. The GAO has noted that this type of cost avoidance accounts for most of the savings to Medicaid associated with TPL (GAO 2015).

The Centers for Medicare & Medicaid Services’ stated that methods for identifying and preventing improper payments “not reassuring.” House Ways and Means Oversight Subcommittee Chairman Peter Roskam (R-IL) rebuked CMS for utilizing “pay and chase” methods of investigating improper payments.

“Despite the fact that Congress has given the agency expanded authority to stop payments before they are made, it continues to rely on pay-and-chase, or making the payment and only checking after the fact to see if it was proper,” Roskam said in his hearing remarks.

In order to address these problems, CMS issued guidance that requires states to uphold the cost avoidance standard for pharmacy claims and eliminate waivers that permit “pay and chase” methodologies.

Based on this guidance, states have responded by developing coordination of benefits (COB) programs that rely on self-reported recipient eligibility data and/or on stagnant data collected by TPL vendors for pay and chase purposes. This data is incomplete, latent and not sufficient for true cost avoidance. In order to successfully meet CMS’ cost avoidance guidelines, an effective real time, point of sale solution would be required to cost avoid claims and mitigate the need for “Pay and Chase.”

Keep learning more here. 

THE REPERCUSSIONS OF REPEALING THE ACA MEDICAID EXPANSION

By Howard Green

While the Senate takes into consideration the Obamacare Repeal Reconciliation Act of 2017, the Kaiser Family Foundation just recently reported on the primary provisions that would impact Medicaid; they are, the removal of statutory authority to cover childless adults up to 138% FPL ($ 16,643 for an individual in 2017) in addition to the provision that does away with the enhanced match rate for the Medicaid expansion.

In the research study, KFF reports that a repeal of the Medicaid expansion would have dire coverage and financing repercussions for the states that have expanded the program.

Evaluation of the data showed that states would see a $700 billion deficit in federal Medicaid funds from 2020 to 2026. In 2026, states would see a decrease in federal Medicaid funding of $121 billion and estimated reductions in coverage of 17.6 million individuals. Without Medicaid expansion or affordable insurance alternatives, it is likely that most of these individuals would become uninsured.

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MEDICAID ENROLLEES GENERALLY HAPPY WITH PROGRAM

By Howard Green

Enrollment surveys have shown that healthcare choices under Medicaid programs are acceptable to enrollees. Enrollees have stated in a countrywide survey that the healthcare they receive under Medicaid is more than adequate. Analysts at Harvard T.H. Chan School of Public Health found that in general, Medicaid enrollees have accessibility to doctors with their Medicaid insurance.

JAMA Internal Medicine just recently published these findings while some lawmakers continue to argue the opposite. Some argue that Medicaid is broken and does not supply appropriate services to those in need. Never the less, JAMA's findings indicate that enrollees are obtaining and making use of the provided options.

According to Michael Barnett and Benjamin Sommers, professors of health policy at the Harvard Chan School, "the debate on the future of Medicaid has largely marginalized a crucial voice: the perspective of enrollees. Our findings confirm that Medicaid programs are fulfilling their mission to provide access to necessary medical care."

Harvard researchers evaluated data from Medicaid's first national Consumer Assessment of Health Providers and Systems survey. This sought to assess people's experiences with Medicaid. The survey was carried out by the Centers for Medicare & Medicaid Services from December 2014 to July 2015. More than 270,000 members from 46 states responded. Based on the survey's results, researchers where able to garner the following information about enrollee's satisfaction with the program:

• On a scale of zero to 10, with zero representing "the worst health care possible" and 10 representing "the best health care possible," participants in the survey rated their overall health care an average rating of 7.9.
• 84% of enrollees revealed that prescribed care was accessible from their physician in the past six months.
• 83% reported having a usual source of care.
• Only 3% reported not being able to get care because of waiting times or insufficient coverage.

As a whole, the study revealed that participants from all demographics are satisfied with Medicaid in states that did not expand and states that did expand under the ACA.

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THE ASSOCIATION FOR COMMUNITY AFFILIATED PLANS PUSHES BACK ON PROPOSED MEDICAID CUTS

by Howard Green

The Association for Community Affiliated Plans (ACAP) has launched a massive advertising campaign imploring Republican senators from Medicaid expansion states to oppose any Medicaid cuts.

The message from ACAP: Medicaid is economically critical because it supports workers.

“Medicaid cuts will put millions of jobs at risk,” the advertisement says.

The television ads will be on the air in Colorado, Arizona, West Virginia, Ohio and Nevada — Republican swing states that expanded Medicaid. These states have at least one moderate Republican senator who has conveyed trepidations over changes to Medicaid.

The Association for Community Affiliated Plans represents Medicaid plans that administer the program for more than 20 million enrollees in 29 states.

“We are reminding Senators that protecting Medicaid protects workers and small businesses in their states — half of working people who rely on Medicaid for coverage work for small businesses,” said Margaret A. Murray (ACAP CEO) in a recent press release.

ACAP does not support the current bill from the Senate, called the Better Care Reconciliation Act (BCRA), stating in a letter that “because the BCRA makes massive cuts to federal Medicaid funding and does not protect plans from unsound rates, ACAP has no choice but to oppose this legislation.”

Medicaid has surfaced as one of the most challenging concerns of repealing and replacing the Affordable Care Act. Senators from expansion states do not want to responsible for their constituents losing coverage, while the other Senators don’t want to be rebuked for holding fast to conservative principles.

In a report, the Congressional Budget Office (CBO) projected the BCRA would lead to a reduction of 15 million Americans on Medicaid by 2026. The bill includes a $772 billion reduction in Medicaid funding for the poor and disabled.

The Better Care Reconciliation Act phases out the ACA’s Medicaid expansion starting in 2021, and would regress to pre-ACA levels by 2024.

Many moderate Republican senators, such as Rob Portman (Ohio) and Shelley Moore Capito (W.Va.), were promoting a 7-year phase out of additional federal funding for Medicaid expansion. Neither one of them has communicated how they would vote on the bill; however, last Friday, Senator Dean Heller (R-Nev.) said that he was in opposition to the bill in its current incarnation. Last weekend, Senator Ben Sasse from Nebraska said the bill doesn’t really repeal the ACA but is “largely a Medicaid reform package.”

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MEDICAID PLANS DRIVE CONTINUED FUNDING FOR PROGRAM IN LETTER TO SENATE

By Howard Green

The recently released Senate health care plan, if passed, would greatly scale back Medicaid financing. This would cripple the program that serves healthcare to a significant portion of the population. Reforming the program is critical; yet, the recent proposal has brought the health insurance industry to their feet. Chief executives in the industry have filed a joint letter to the Senate imploring them to reconsider their plan for financing Medicaid. The letter requests that Senators carefully consider the consequences of drastically altering Medicaid funding. CEO's from the countries largest Medicaid plans signed the letter. They claim that the ACA, along with its underlying structure to finance Medicaid, should be reformed in ways that encourage savings rather than cutting funding to the states.

" This year's discussion began with a focus on the ACA's individual insurance market, but current healthcare proposals go further and do not enact meaningful, needed repairs to the ACA," the letter says.

" However, our primary concerns lie in the impacts these policies will have on the 74 million low-income, disabled and elderly Americans whose healthcare coverage through Medicaid rests in the hands of the Senate as you craft new legislation and policy options."

As an alternative to the funding cuts under consideration, the joint letter urges Senators to integrate other options to preserve accessibility to quality care:

• Reduce regulation to increase efficiency
• Waiver flexibility for states
• Restructure the pharmacy program
• Value-based pricing
• Alternative payment methods for healthcare providers based on population
• Flexibility in utilizing Medicaid funds
• Consolidation of administration and benefit design for the dual-eligible

These health plan leaders universally advocate Medicaid reform, but they are united against the current proposal from the Senate.

" We are not advocating to maintain the status quo; rather we are advocating for meaningful Medicaid reform," the letter says.

The letter recognizes that the policies currently being deliberated in Congress, the federal government would introduce a limit on the funding it would offer to states each year starting in 2020, and in place of actuarial calculations the government would use 2016 Medicaid costs trended forward by the Medical Consumer Price Index. That strategy is projected to diminish the federal share of Medicaid funding by more than $800 billion over 10 years, amounting to a 25% shortfall in covering the actual cost of Medicaid.

" While this may appear positive from an immediate budgetary perspective, these amounts spell deep cuts, not state flexibilities, in Medicaid. There are no hidden efficiencies that states can use to address gaps of this magnitude without harming beneficiaries or imposing undue burden to our health care system and all U.S. taxpayers," the letter says.

" Reducing the federal government's share of Medicaid in this manner is not meaningful reform to bend the cost curve. It is simply an enormous cost shift to the states. It does nothing to address underlying drivers of the cost of care, like expensive new drugs and therapies, and an aging population living longer with disability."

In order to make up for the reduction in funding, States would need to raise taxes, reduce benefits, cut reimbursement, and remove some eligible beneficiaries.

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IS MEDICAID MANAGED CARE IN DANGER?

The AHCA, which narrowly passed in the House of Representatives, aims to cap federal Medicaid funding. The major drop in funding could possibly put an end to Medicaid Managed Care as we know it. Converting the open-ended entitlement program to a system of per capita caps or block grant payments would make it very challenging for Medicaid managed care plans to continue to function. The CBO estimates, that over a ten-year period, federal Medicaid spending would be reduced by $834 billion.

States that did not end their Medicaid expansion programs could likely see an increase in enrollment. According to Joe Moser, "States are going to look for what gives them budget predictability, and that's what managed care does. You will see more states expanding their managed care populations to more critical populations." PwC at the moment estimates that 73% of Medicaid beneficiaries are covered by Medicaid managed care; however, this does not account for those in need of long-term care or the disabled. It is very easy to presume that by shifting these groups to managed care; states could reduce costs as federal funding begins to dry up. Ari Gottlieb, of PwC stated, "A per capita cap could accelerate the trend of managed care." Still, insurers contend that the proposed fixed-payment formula will put plans at risk. They vehemently disagree that the formula would offer adequate resources for an unanticipated economic recession, new public health needs, or new prescription medications and treatments.

Under the proposal, the guideline for state's per-capita beneficiary group spending would be established off of the 2016 fiscal year. Payments would rise yearly at the rate of the Medicaid component of the CPI. The elderly, blind, and disabled payments would also increase at CPI plus one percentage point. Medicaid spending in 2016 reached $548 billion. The consulting firm, Health Management Associates measured that Medicaid managed care spending went from $238 billion in 2015 to $269 billion in 2016.

Anna Gupte, an analyst at Leerink Partners, strongly believes that the 2016 baseline will make it more likely that states will cut payment rates to managed care plans if costs or enrollments increase. Medicaid plans' operating margins average around 2%. "I expect margin compression as states claw back rates in Medicaid to offset the funding pressure from the rollback in Medicaid funding and a move to per capita caps."

Insurance companies are looking to the Senate for a correction in the AHCA's framework for federal Medicaid payments to the states. More specifically, they would like the calculating baseline year to adjust every two years. Additionally, insurers want states to be required to adhere to federal actuarial soundness in arranging payment rates to Medicaid plans. John Lovelace, president of UPMC, stated, "The concept of a per capita cap is fine. It's a devil in the details conversation."

The situation could be critical if there are zero protections in place and the bill passes without any revisions. Meg Murray, CEO of ACAP, whole-heartedly opposes the House bill's Medicaid provisions. "What we're worried about is that plans wouldn't be able to survive. It could end up fundamentally undermining the Medicaid managed care system and all the good things that have come out of it."

Read more here.

H.R. 938 MISSES THE POINT: THE NEED TO MAKE MEDICAID MORE EFFICIENT

By Howard Green

H.R. 938, the Medicaid Third Party Liability Act, was recently presented by Rep. Michael Burgess (R-Texas) to help Medicaid save money. As legislators return to Washington this week, health care remains at the top of their agenda. The primary issue amongst Republicans is how to handle the Medicaid debate, particularly in states that expanded the program, or are choosing to expand under the ACA. But they will have a challenging time funding the expansions without continued federal support. The outcome of the decision is sure to affect patients, health care workers and the overall economy.

The Trump administration has left all sectors involved in health care with uncertainty. The promise to repeal and replace the Affordable Care Act with the AHCA passed by a razor thin margin last month in the House of Representatives. Waivers to alter Medicaid are being submitted to HHS for review. And the publication of the president's budget creates ambiguity with regard to the level of federal funding states can count on.

Trump's budget, "A New Foundation for American Greatness," eviscerates spending in almost every department except defense. While it has little to no chance of passage, health care professionals caution that it shouldn't be ignored because it demonstrates clear intent. "It's hard to imagine that it'll be enacted fully, but at a minimum, it reflects the priorities of the administration," says Elizabeth Burak, senior program director at Georgetown University's Center for Children and Families.

The administration's submitted budget would slash Medicaid spending by $800 billion over a decade. This is above and beyond suggested cuts in the American Health Care Act to replace the ACA, which the President's budget assumes will become law. If both the President's proposed budget and the AHCA were to pass, states will encounter well over a $1 trillion reduction in Medicaid funding.

Trump's budget director, Mick Mulvaney, emphatically argues that the decreases in funding, along with the shift to per capita caps and block grants, would offer states more flexibility in the administration of their respective Medicaid programs. However, most health care experts believe that such deep cuts would only give states flexibility in disenrollment plans for a large swath of Medicaid beneficiaries.

So currently, more than ever, Medicaid plans should be concentrating their efforts on finding ways to further efficiency and cost savings ahead of potential funding cuts. Discovering ways to save taxpayer money is certainly a good practice regardless of the political headwinds, but now; Medicaid overseers can not rest on their laurels and assume the status quo of federal funding will continue. They need to begin getting aggressive in cost control. Recently, House Bill H.R. 938 was presented to do just that.

H.R. 938, known as The Medicaid Third Party Liability Act, aims to remove loopholes that forces Medicaid to pay for claims that are the liability of primary payers. As much as 13 percent of Medicaid members around the nation hold additional insurance other than Medicaid, which is called Third Party Liability (TPL). Types of TPL include employee insurance, Workers' Compensation, Medicare, COBRA health insurance from former employment, casualty insurance, dental insurance, eye insurance and insurance to cover pharmaceutical costs. In these instances, Medicaid pays last, and if a Medicaid member holds other insurance coverage, that insurer pays first and then Medicaid pays any remaining costs.

H.R. 938 was formed to increase savings and promote efficiency by eliminating loopholes that third parties have been capitalizing on. The bill protects against payers that are liable for costs from holding back payments to Medicaid. The primary provisions in H.R. 938 that help Medicaid avoid the costs of improper claims payments are:

• H.R. 938 would thwart efforts of liable commercial payers to deny reimbursement of claims due to a lack of prior authorization.
• H.R. 938 would afford Medicaid Managed Care Organizations (MCOs) the same rights as state-run Fee For Service plans to be the payer of last resort.
• H.R. 938 would replicate the same prompt payment standards regularly enforced in the commercial marketplace, but in this case, the recovery of improper claims payments made by Medicaid that are really the liability of a primary insurer.

While the provisions of The Medicaid Third Party Liability Act are solid steps in the right direction, they are in a sense addressing the symptoms of improper claims payments, rather than the disease of "Pay & Chase". What we need is more pressure or incentive to persuade Medicaid plans to get better at identifying TPL prior to improperly paying for claims. The Social Security Act, signed into law by President Franklin Roosevelt in 1934, states in the statute § 1902( a)( 25) of the law "... that the State or local agency administering such plan will take all reasonable measures to ascertain the legal liability of third parties ... to pay for care and services" delivered to Medicaid recipients.

Passage of the Medicaid Third Party Liability Act (H.R. 938) will help recover money that was spent incorrectly, but until we shift our focus from Pay & Chase to prospectively preventing the costs of improper payments, Medicaid will still see substantial amounts of waste.

Learn more here. 

PROPOSED MEDICAID REDUCTIONS FROM PRESIDENT TRUMP'S ADMINISTRATION

By Howard Green

Medicaid could receive funding cuts due to Trump's 2018 budget proposal and this may fundamentally transform how the Medicaid program operates. The proposals goal is to give individual states flexibility. According to the budget, states will have an option between receiving a block grant in the fiscal year 2020 or they can choose to receive Medicaid funds as a per-capita cap grant. This is the foundation of the American Health Care Act, which, if passed in the Senate, would take the place of the Affordable Care Act.

Richard Frank, a Harvard Medical School professor, feels this will fundamentally change how Medicaid would operate. "It's no longer an open-ended matching program" and the proposal "fundamentally changes the kind of contract that exists between the states and the federal government." The CBO estimates that 14 million people will no longer have access to Medicaid by 2026 as a result of the AHCA eligibility requirements.

IN THE PAST, STATES RECEIVE MONEY FOR MEDICAID FOR:
New treatments

Treatment expenses

An increase in healthcare needs

In addition to the federal government match, states themselves fund a considerable amount for their Medicaid programs. This is beginning to exhaust resources locally and federally because Medicaid has always been an open-ended entitlement program.

The possible passage of the proposed budget plan has states on their feet to grow their Medicaid programs. Since the implementation of the ACA, eligibility requirements became relaxed and contributed in broadening access to a larger percentage of the population. To compensate for the increased amount of enrollees, states received enhanced federal funds. States such as North Carolina, Virginia, and Kansas made efforts to expand in March but failed.

NO MEDICAID PLAN IS FLAWLESS

Richard Frank is troubled with the proposal's two funding choices because the medical care CPI does not account for shifts in the population or unexpected crises. For instance, overall improved health and longer life spans have risen in recent years. People are more healthy and living longer. This means in the near future, the amount of eligible enrollees to the program will increase and create a larger demand on Medicaid. Dr. Frank feels that the costs for elderly people's healthcare would jump at a faster rate than the medical care CPI.

In addition, the per-capita funding option would organize people into groups based on age or disabilities. This is problematic since the groups would be too broad and would not allow for effective distribution of available funds. The Harvard medical professor estimates there will be a 9% shortfall, which translates into $10 billion annually that states would have to satisfy. On the other hand, the CBO estimates that spending will be reduced 25% by 2026 compared to the ACA.

STATE'S OPTIONS

In the current landscape, states will need to either cut expenses or invest in their programs. If they cut costs, beneficiaries will lose coverage and the eligibility requirements will become stricter for future enrollees. It's thought that substance abuse and mental illness treatment would be the first to be discontinued. This is problematic given that opioid deaths increased 15% between 2014 and 2015. The medical care CPI doesn't account for that growing rate.

At this point, there is a significant amount of criticism as to what should be done and how it should implemented. What is certain is that the demand for Medicaid is increasing and there are many opinions on the best course. Currently, a majority of the public thinks the program should remain the same.

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$36 BILLION IN IMPROPER MEDICAID PAYMENTS IN 2016

For the fourth straight year, the federal government increased the amount of money described as improper payments. The Government Accountability Office is reporting that agencies exceeded $144 billion in improper payments in fiscal 2016, up from $137 billion in 2015.

This escalation translates to a higher improper payment rate as well, up to 4.67 percent of all outlays from 4.39 percent last year. Regardless of the increase, the rate still is half a percent lower than when President Barack Obama entered office in 2009, U.S. GAO said.

" This increase between FY 2015 and FY 2016 can be attributed to percentage and dollar increases in the Medicaid Program, the Direct Loan Program, the Medicare Part C Program, the Pell Grant Program, the VA Community Care Program, and the Earned Income Tax Credit (EITC) Program," U.S. GAO mentioned in the report released January 12. "For fiscal year 2016, federal entities reported improper payment error rates that exceeded 10 percent for 11 risk-susceptible programs, accounting for more than 70 percent of the governmentwide improper payment estimate."

GAO states the Medicare Fee for Service (FFS) program accounted for the largest amount of improper payments-- $41 billion or 28 percent of the governmentwide total. Medicaid was the second with $36 billion or 25 percent of the governmentwide total while the EITC and Medicare Part C joined account for the third with $33 billion or 23 percent of the governmentwide total.

On the positive side, The GAO claimed the government recovered about $20 billion in overpayments last year. To be clear, an improper payment does not suggest the federal government overpaid a beneficiary or another customer. An improper payment could signify someone was underpaid as well.

" Approximately $44 billion of the governmentwide improper payments in fiscal 2016 are caused by insufficient documentation. A lack of supporting documentation could be a situation where there is a lack of supporting documentation necessary to verify the accuracy of a payment identified in the improper payment testing sample such as a program not having the documentation to support a beneficiary's eligibility for a benefit," GAO stated. "Approximately $34 billion of the governmentwide improper payments in fiscal 2016 were caused by the inability to authenticate eligibility." The GAO explains the inability to authenticate eligibility is a problem where the agency can't identify if the citizen is eligible to prevent a payment.

The OMB has been pushing for agencies to employ more and better data and other approaches to decrease improper payments.

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