ADDRESSING MEDICAID BUDGET PRESSURE WITHOUT REDUCING BENEFITS

As states prepare their fiscal year (FY) 2027 Medicaid budgets, financial flexibility is becoming increasingly limited. State revenue growth has slowed, healthcare costs continue to climb, and federal policy changes enacted through the 2025 budget reconciliation law have altered how future funding risk is managed. Even as enrollment stabilizes, Medicaid spending remains on an upward trajectory, driven by higher clinical complexity, increased utilization of long-term services and supports, rising pharmacy expenditures, and expanded behavioral health needs.

In this environment, states are revisiting familiar cost-containment strategies. Proposals to reduce provider reimbursement, narrow optional benefits, or tighten utilization controls are once again entering budget conversations. While these measures can reduce spending in the short term, they often introduce downstream challenges—including access limitations, provider participation concerns, and outcomes that conflict with CMS’s emphasis on coverage stability and care quality. As financial pressure grows, Medicaid agencies and managed care organizations (MCOs) are increasingly seeking alternatives that protect budgets without undermining benefits.

Improper Payments Now Carry Direct Budget Risk

One of the most significant shifts affecting Medicaid finances is the heightened consequence of payment errors. Improper payments above the federal 3 percent threshold now result in concrete funding penalties, regardless of whether states later recover the dollars. Federal matching funds may be reduced for any excess over the benchmark, with fewer opportunities for exceptions or mitigation.

This framework fundamentally changes the role of recovery. Post-payment collections no longer shield states from financial exposure or help preserve future funding. A payment made incorrectly remains improper under federal standards—even if it is later recouped—making prevention the only reliable way to manage risk.

Moving Beyond “Pay and Chase”

A large portion of Medicaid improper payments occur when claims should have been paid by another insurer. Traditional recovery-based approaches identify these issues only after funds have been disbursed, offering little benefit in reducing improper payment rates.

Prospective cost avoidance addresses this challenge by stopping errors before they occur. Real-time identification of other health insurance and third-party liability ensures Medicaid consistently acts as the payer of last resort. Each avoided improper payment directly supports compliance with the 3 percent standard and preserves funding for covered services.

Operational Accuracy Drives Financial Stability

Administrative inefficiencies often compound budget challenges. Manual claims review, fragmented eligibility systems, and delayed coverage verification increase error rates while adding operational cost.

By automating eligibility checks, coverage validation, and claims workflows, Medicaid programs and MCOs can improve accuracy while reducing administrative burden. Operational modernization enables compliance with federal standards without shifting costs onto providers or beneficiaries.

Program Integrity as a Budget Strategy

Program integrity has become a central component of fiscal management rather than a retrospective compliance exercise. Continuous monitoring, data-driven oversight, and early risk detection allow states to prevent recurring payment issues before they escalate.

When paired with prospective cost avoidance, these efforts reduce financial leakage, improve audit preparedness, and support long-term budget sustainability—even during periods of economic uncertainty.

Protecting Coverage Through Prevention

As Medicaid budgets face increasing pressure, benefit reductions should remain a last-resort option. The most effective way to prepare for funding constraints is to ensure claims are paid correctly the first time.

Preventing improper payments, maintaining compliance with the federal 3 percent standard, and modernizing operational processes allow states and MCOs to preserve access to care while safeguarding limited resources. In today’s Medicaid environment, cost avoidance is not optional—it is essential to sustaining program integrity and financial stability.

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MEDICAID PAYMENT INTEGRITY: ADDRESSING IMPROPER PAYMENTS

 

Improper payments and fraud continue to be chronic and costly difficulties for Medicaid and other government-funded programs. The GAO defines improper payments as payments that should not have been made or that were made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements. According to the GAO, the federal government loses between $233 billion and $521 billion annually to fraud alone.

Since FY 2003, executive branch agencies have reported increasing improper payment estimates totaling approximately $2.7 trillion. In fiscal year 2023 alone, federal agencies reported $236 billion in improper payments across 71 programs. While the FY 2023 estimate represents an $11 billion downturn from the previous year, this reduction is credited to temporary flexibilities granted during the COVID-19 PHE. These measures, such as relaxed eligibility requirements for Medicaid beneficiaries and providers, minimized instances of improper payments under the altered criteria.

Medicaid's High-Risk Status

Medicaid has been on the GAO's High-Risk List since 2003 due to vulnerabilities in payment integrity. In FY 2023 alone, HHS estimated that Medicaid improper payments totaled $50 billion. According to HHS, the leading contributors to these payments are missing or insufficient documentation, particularly in validating beneficiary eligibility and payments to ineligible beneficiaries or ineligible services.

Actions and Legislative Efforts to Reduce Improper Payments:

CMS has made some progress in identifying these susceptibilities. For instance, CMS collaborated with states and audit contractors to improve oversight of healthcare companies contracted to manage healthcare services for Medicaid beneficiaries. Investigations rose from 16 between 2016 and 2018 to 893 between 2019 and 2021, uncovering significant overpayments.

Over time, several legislative efforts have been aimed at curbing fraud, waste, and abuse. Despite these pieces of legislation, Medicaid continues to lose billions of dollars because of payments made in error. The measures directed by the legislation are costly and primarily revolve around compliance and reporting rather than reducing improper payments.

Remaining Challenges:

The GAO identified several areas for improvement, including:

Provider Screening and Enrollment Requirements

The GAO suggested CMS review state compliance with screening and enrollment requirements and monitor noncompliance yearly. While CMS has provided technical assistance, further action is needed to assess and address all states' compliance.

Medical Reviews for Improper Payments

The GAO advised CMS to strengthen Medicaid's medical review processes to identify the root causes of improper payments and implement corrective actions. As of March 2024, HHS disagreed with this recommendation and does not plan to implement it.

Compliance with the Payment Integrity Information Act of 2019 

Medicaid was deemed compliant with PIIA criteria in FY 2023. However, it was not fully compliant in fiscal years 2021 and 2022.


Considerable gaps remain in addressing improper payments and fraud. By fully implementing GAO recommendations and enhancing oversight, federal agencies and programs like Medicaid can better safeguard taxpayer dollars, reduce waste, and improve operational efficiency. Nevertheless, to prevent improper payment rates from rising even more, agencies should look to innovate data solutions to identify and prevent fraud, waste, and abuse.

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STRENGTHENING PAYMENT INTEGRITY AND REDUCING ABRASION

 

Payment integrity programs are developed to provide correct claims processing, adherence to contractual rates, and compliance with payment rules. These efforts are essential for maintaining the financial stability of healthcare systems and making certain that patients receive appropriate care. That being said, they can produce friction between payers and providers, originating from disputes over claim denials, decreased reimbursements, and the administrative burden associated with claims adjudication.

Providers are under considerable pressure, with inflation at 3.3% driving up hospital costs. Additionally, cuts to Medicare physician payment rates are making it more and more challenging for physicians to maintain their practices, adding to a rise in hospital-employed physicians, now at 77.6%, a 25.8% increase from a decade ago.

Compounding these challenges, 7% of physicians have left the workforce, mainly from internal medicine and family practice. Healthcare organizations must find ways to compensate for these shortages, with increased billing on claims being one potential method to recoup costs. Unfortunately, this can increase tensions between payers and providers.

As payment integrity becomes more important due to rising healthcare spending and complex billing processes, it must focus on reducing provider abrasion to improve billing practices and relationships between health plans and providers.

Improving communication around claim denials and payment policies is one primary method to reduce provider abrasion. Readily available policies can reduce the chances of surprises by helping providers know what to expect when processing claims.

The next important strategy is communication coupled with the human element. While the role of artificial intelligence (AI) in healthcare is a hot topic at the moment, it will take some time for technology to fully comprehend the complexity of medicine and coding. Codes and rules are constantly changing and being added. Payment integrity requires human expertise and interactions to effectively address provider abrasion. AI is unable to explain complex payment integrity decisions like clinicians with extensive coding knowledge and coders with deep clinical knowledge.

Another effective approach is tailoring payment integrity solutions to meet the unique needs of various providers and patient populations. Sometimes, a payer might allow claims from a specific provider offering advanced treatment considered investigational that might not be allowed from another provider. It's important for payer organizations to handle such situations in a custom manner.

One more vital component of payment integrity programs is the adoption of modern technology solutions that utilize accurate and usable eligibility data in coordinating benefits. When Medicaid payers do not have access to clean eligibility data, it can lead to abrasion at the pharmacy for program beneficiaries and lead to improper payments. Accurate eligibility data significantly helps to properly adjudicate claims, saves valuable program resources, and, most importantly, ensures that members receive the care and medications they need.

Clear communication, human expertise, and customized solutions are key to enhancing the relationship between healthcare providers and payer organizations. The adoption of modern technology solutions and clean, actionable data is another key tool for reducing abrasion and honing payment integrity. As the healthcare industry evolves, these strategies and data solutions will ensure efficient payment integrity efforts, ultimately leading to better patient outcomes.

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