Review of Illinois' Reporting of Fund Recoveries in the Appeals Process on the Form CMS-64

For the period January 1, 2007, through September 30, 2009, the Department of Healthcare and Family Services (State agency) did not report Medicaid overpayments totaling approximately $18 million ($9 million Federal share) in accordance with Federal requirements. The State agency did not report 24 of the 27 overpayments reviewed on the CMS-64. The State agency correctly reported the remaining three overpayments. The State agency did not properly report these overpayments because it had an unwritten policy of reporting overpayments not involving fraud or abuse when the provider appeals process was completed, rather than at the end of the 60-day period following discovery.

We recommended that the State agency include unreported Medicaid overpayments of approximately $18 million of the CMS-64 and refund approximately $9 million to the Federal Government. We also recommended that the State agency ensure that future Medicaid overpayments that are in the appeals process are reported on the CMS-64 in accordance with Federal requirements. The State agency concurred.