Monday, June 29, 2020

ADMINISTRATIVE CHALLENGES IN THE MEDICAID PROGRAM

GAO Improper Payments Medicaid Syrtis Solutions Program Integrity Fiscal Oversight

Medicaid has been designated as a high-risk government program by the GAO since 2003. The Medicaid program has struggled over the last seventeen years because of insufficient fiscal oversight and other administrative difficulties. These challenges will be exasperated as the program expands and enrollment climbs in the course of the COVID-19 pandemic. If Medicaid is expected to deliver on its goal to serve the health and wellness needs of our nation's most vulnerable low-income individuals and families, it is essential that these administrative problems be addressed.

In a recent report from the GAO, the agency analyzed federal Medicaid policies, state perspectives on challenges they encounter due to present policies, and what federal actions may be taken to resolve these problems. After speaking with Medicaid officials from 50 states and Washington D.C., the GAO was able to determine federal policies, laws, and regulations that caused difficulty to effectively administer the Medicaid program.

Four problematic areas cited by officials include coverage exclusions and care coordination, covered benefits and eligibility, Medicare and Medicaid alignment, and payment methods. In addition, administrative officials brought up reporting requirements and the inadequate guidance. There is also much consternation due to the lengthy delays when states are seeking approval to waive various statutory Medicaid requirements. CMS is already in the process of resolving these problematic areas and has released revised guidance, streamlined the waiver procedure, and is working with stakeholders to develop an updated reporting system.

Additionally, the GAO also found five relevant considerations that broadly apply to the reported areas of concern. They include targeting federal oversight to important areas, making use of program data, balancing oversight and flexibility for waivers and demonstrations, clarifying CMS policy, and responding to change.

IMPORTANT GAO CONSIDERATIONS


Targeting Federal Oversight To Crucial Areas


The GAO determined that program oversight tasks must support beneficiary accessibility to benefits and the proper use of federal expenditures to protect against improper payments. This consideration was based on the GAO's March report that estimated improper payments in the Medicaid program increased $21 billion in FY 2019. HHS stated that the surge was a result of inadequate documentation for eligibility determinations. Additionally, many improper payments resulted from noncompliance in screening and enrollment requirements.

Leveraging Program Data


Poor quality data has been another issue for Medicaid plans in recent times. Incomplete and outdated data make program oversight extremely problematic. The report stated that "accurate and complete data on key measures-- such as measures for beneficiary access and use of services and the costs of providing such services-- are critical for oversight, including ensuring proper payments, and for informing any evaluation of policies." Dependable quality data could help display the cost-effectiveness of expanding Medicaid coverage to other services. States and stakeholders agree that quality data will considerably aid in managing the Medicaid program.

Medicaid has been on the GAO's High-Risk List since 2003 due to poor oversight and other administrative issues. Over the last seventeen years, Medicaid officials have struggled to administer Medicaid due to laws, policies, and regulations. If the program is to become fiscally solvent while properly coordinating care, improving fiscal oversight and accessing quality data is essential.

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Wednesday, June 24, 2020

MEDICAID IMPROPER PAYMENTS IN 2019


Improper payments in the Medicaid program are payments full or partial claims payments paid in error or payments made to the incorrect party. Improper payments have been a major issue for Medicaid over the last few years and have cost the program's valuable resources. Across all federal programs, improper payments have been determined to total almost $1.7 trillion between 2003 and 2019. In March of this year, the Government Accountability Office (GAO) published its latest report, GAO-20-344, which estimated improper payments in federal agencies for FY 2019. The report indicates that federal agencies estimated improper payments amounted to a shocking $175 billion in 2019. The majority of the improper payments came from three programs: Medicaid, Medicare, and the Earned Income Tax Credit (EITC). Medicaid had a 14.9% improper payment rate, up nearly 5.1% from 2018, and represented 32.8% or $57.4 billion of the $175 billion in government improper payments. Unfortunately, understanding these payments and their impact continues to be a difficulty due to incomplete, unreliable, and understated estimates from government agencies. In addition, agencies are not complying with reporting and additional requirements from the Improper Payments Elimination and Recovery Act of 2010 (IPERA). For example, eight out of fourteen agencies failed to publish and meet targets for reducing improper payments in 2019.

From 2018 to 2019, Medicaid's improper payment rate increased by 5.1%. 


According to the Department of Health and Human Services (HHS), the five-point jump in payments made in error was due in part to the department's reintegration of the Payment Error Rate Measurement (PERM). In the prior four years, HHS did not estimate improper payments associated with eligibility and they also used a proxy estimate that was last reported in 2014. In addition, HHS was only able to estimate eligibility determination related improper payments for 17 states since the majority have not been measured since PERM was reintegrated. In the HHS FY 2019 agency financial report, the department cited that many of Medicaid's improper payments stemmed from states not complying with provider screening and enrollment requirements. Furthermore, eligibility errors identified by PERM were a result of insufficient documentation to confirm eligibility or noncompliance with the requirements for redetermining eligibility.

Improper payments are taking valuable resources away from the Medicaid program and other federal programs. These payments are reported as a monetary loss and they could have possibly been prevented or recovered. While reporting improper payments is helpful in understanding how prevalent they are, it does nothing to reduce them. This must be resolved, particularly in a time where unemployment has skyrocketed due to the Coronavirus pandemic. Millions of Americans are turning to the Medicaid program and every dollar counts.

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Thursday, June 11, 2020

SYRTIS SOLUTIONS MEDICAID NEWS - MAY 2020

Medicaid News Recap Syrtis Solutions


Syrtis Solutions distributes a Medicaid newsletter on a monthly basis to help you stay informed. Here is a summary of last month's Medicaid news, legislation, and industry developments relating to Medicaid integrity, cost avoidance, improper payments, fraud, waste, and abuse.

See the newsletter here. 

Monday, April 6, 2020

MEDICAID NEWS RECAP - MARCH 2020

Medicaid Newsletter Syrtis Solutions


Syrtis Solutions distributes a Medicaid newsletter on a monthly basis to help you stay informed. Here is a roundup of last month's Medicaid news, legislation, and industry developments relating to Medicaid integrity, cost avoidance, improper payments, fraud, waste, and abuse.

Read the March newsletter here. 

Monday, March 30, 2020

SECTION 1135 WAIVERS AID STATES AMID COVID-19

Soon after COVID-19 was declared a national emergency on March 13th, the Centers for Medicare and Medicaid Services (CMS) was able to waive stipulations in federally funded programs to support States responding to the pandemic. To date, CMS has authorized Medicaid Section 1135 Waivers for 23 States that give them the power to suspend pre-admission screening for nursing facilities. Additionally, Washington, Missouri, North Dakota, and Oregon also have the authority to adjust Medicaid rates, cost-sharing amounts, and premiums without informing the public.

According to the Centers for Disease Control (CDC), 122,653 individuals in the U.S. have been infected and 2,112 have died. The data includes both verified and presumptive positive cases of COVID-19 reports to the CDC or tested at the CDC since January 21, 2020. That being said, those numbers are most likely to increase as a result of the lack of available testing.

Apart from the Section 1135 Waivers, the Department of Health and Human Services (HHS) and CMS are also responding to the virus by expanding Medicare. Their initiatives are geared at removing regulatory barriers for States and Medicare restrictions. CMS is also calling for Medicare Part D and Advantage prescription plans to waive cost-sharing for COVID-19 testing and treatment. Furthermore, CMS is asking that hospitals delay elective surgical procedures to conserve resources.


SECTION 1135 WAIVERS 

CMS has authorized the most lenient Medicaid waivers to New Hampshire, New Jersey, Illinois, and Mississippi. Their waivers consist of the following provisions:

  • Temporarily suspend Medicaid fee-for-service prior authorization requirements. Section 1135(b)( 1 )(C) allows for a waiver or modification of pre-approval requirements, including prior authorization processes required under the State Plan for particular benefits.
  • Extend pre-existing authorizations for which a beneficiary has previously received prior authorization through the end of the public health emergency.
  • Suspend Pre-Admission Screening and Annual Resident Review (PASRR) Level I and Level II Assessments for 30 days.
  • Enable modification to the timeframe for State fair hearing requests and appeals.
  • Temporarily enroll providers who are enrolled with another State Medicaid Agency and/or Medicare for the duration of the public health emergency.
  • Provision of services in alternative settings permitting facilities to be fully reimbursed for services rendered to an unlicensed facility provided that the State makes a reasonable assessment that the facility satisfies minimum standards.

North Carolina asked for all of the Section 1135 Waiver provisions above except extending pre-existing authorizations. California, New Mexico, Louisiana, and Arizona also made similar requests.

At the moment, CMS is still working on additional waiver applications from New Hampshire, California, Illinois, Arizona, Louisiana, New Jersey, Mississippi, North Carolina, New Mexico, and Virginia.

California's governor, Gavin Newsom, has also requested federal assistance to supplement temporary housing for the homeless in the event that they are exposed to or test positive for COVID-19 and provisions to waive the cost of testing and treatment for particular Medi-Cal beneficiaries.

Due to the major impact of COVID-19, federal departments and agencies are working to minimize regulation and barriers through Section 1135 Waivers to help States respond to the pandemic. These waivers are effective as of March 1 and last for the duration of the public health emergency or any extension thereof.

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Thursday, March 12, 2020

MEDICAID NEWS RECAP FROM SYRTIS SOLUTIONS - FEBRUARY 2020


Every month, Syrtis Solutions puts together a Medicaid newsletter to help you stay up-to-date. Here is a roundup of last month's Medicaid news, legislation, and industry developments pertaining to Medicaid integrity, cost avoidance, improper payments, fraud, waste, and abuse.

Open the newsletter. 

Wednesday, March 11, 2020

MICHIGAN OPTS OUT OF RX CARVE-OUT

FROM CARVE-OUT TO SINGLE PDL


Back in September, Michigan proposed policy 1936-Pharmacy to carve-out the State's Managed Medicaid outpatient pharmacy drug coverage and move to a Fee-for-Service (FFS) model. That being said, plans to carve-out pharmacy benefits have recently been updated. After considering the plan, the State has made a decision to instead implement a single Medicaid Preferred Drug List (PDL). The single PDL was a recommendation in the Governor's Executive Budget and serves to maximize manufacturer rebates to increase savings. Along with the PDL, MDHHS is also advising raising MHP's dispensing fee to $3 for independent pharmacies. Currently, the department is preparing an updated policy and there will be an opportunity for public comment.

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