Review of the Qualified Pension Plan at Blue Cross Blue Shield of Wyoming, a Terminated Medicare Contractor, for the Period January 1, 1986, to January 1, 2007

Blue Cross Blue Shield of Wyoming (Wyoming), a Centers for Medicare & Medicaid Services (CMS) contractor, did not always comply with Federal requirements and the Medicare contracts' pension segmentation requirements while updating the Medicare segments' assets from the initial asset allocation to January 1, 2007.  In addition, Wyoming did not comply with the provisions of its Medicare contracts or the Cost Accounting Standards when determining Medicare's share of the Medicare segment excess pension assets as of the termination of the Medicare contracts. As a result, Wyoming overstated Medicare's share by $47,000.  Wyoming administered Medicare Part A operations under cost reimbursement contracts with CMS until the contractual relationship was terminated October 31, 2006. The effective closing date for the Medicare segment was January 1, 2007.

We recommended that Wyoming (1) decrease Medicare segment pension assets as of January 1, 2007, by $48,000; (2) decrease Medicare's share of the excess Medicare segment pension assets as of January 1, 2007, by $48,000; and (3) refund to the Federal Government $70,000, which we calculated to be Medicare's share of the Medicare segment excess pension assets as of the termination of the Medicare contracts.  Wyoming concurred with our findings and stated that it will refund $70,000 to the Federal Government.