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Series: MCO Payments for Services After Beneficiaries' Deaths

Announced on  | Last Modified on  | Series Number: W-00-24-31497

OBJECTIVE

Previous OIG reports found that Medicare paid for services that purportedly started or continued after beneficiaries' dates of death. We will identify Medicaid managed care payments made on behalf of deceased beneficiaries. We will also identify trends in Medicaid claims with service dates after beneficiaries' dates of death.

There are 3 projects in this series.

ACTIVE PROJECTS IN THIS SERIES (1)

COMPLETED PROJECTS IN THIS SERIES (2)

Colorado

Delaware

TIMELINE

  • August 20, 2021
    Series Number W-00-24-31497 Assigned
  • August 20, 2021
    Project Announced

    Colorado - A-07-21-05132

  • May 16, 2022
    Project Announced

    Delaware - A-03-22-00205

  • August 8, 2023
    Project Announced

    Project A-04-23-09010

  • March 25, 2024
    Project Complete - A-03-22-00205

    Delaware has been marked as complete. This audit resulted in 4 recommendations.

  • February 14, 2025
    Project Complete - A-07-21-05132

    Colorado has been marked as complete. This audit resulted in 6 recommendations.

  • Today
    1 Audit In-Progress
  • Est FY2026
    Estimated Fiscal Year for Series Completion

2 REPORT PUBLISHED

24-A-03-051.01 to CMS - Open Unimplemented
Update expected on 03/15/2026
We recommend that the Delaware Division of Medicaid and Medical Assistance refund $3,484,904 to the Federal Government.

24-A-03-051.02 to CMS - Open Unimplemented
Update expected on 03/15/2026
We recommend that the Delaware Division of Medicaid and Medical Assistance identify and recover unallowable capitation payments, which we estimate to be at least $4,246,759, made to MCOs during our audit period on behalf of deceased enrollees.

24-A-03-051.03 to CMS - Open Unimplemented
Update expected on 03/15/2026
We recommend that the Delaware Division of Medicaid and Medical Assistance identify and recover unallowable capitation payments made on behalf of deceased enrollees in 2022 and 2023 (the years after our audit period), and repay the Federal share of amounts recovered.

24-A-03-051.04 to CMS - Open Unimplemented
Update expected on 03/15/2026
We recommend that the Delaware Division of Medicaid and Medical Assistance develop and implement quality assurance steps, including supervisory review, within its policies and procedures to verify that State agency personnel correctly enter enrollees' information into the MMIS system.

View in Recommendation Tracker

25-A-07-044.01 to CMS - Open Unimplemented
Update expected on 03/30/2026
We recommend that the Colorado Department of Health Care Policy and Financing refund $6,012,198 to the Federal Government, consisting of $3,509,358 (Federal share) of capitation payments made on behalf of deceased enrollees who had a date of death recorded in SSA's DMF but not in the State agency's eligibility system; $293,890 (Federal share) of capitation payments made on behalf of deceased enrollees who had a date of death recorded in SSA's DMF and in the State agency's eligibility system; and $2,208,950 (Federal share) in other Medicaid expenditures that the State agency had previously overreported.

25-A-07-044.02 to CMS - Open Unimplemented
Update expected on 03/30/2026
We recommend that the Colorado Department of Health Care Policy and Financing identify and recover unallowable capitation payments made to MCOs during our audit period on behalf of deceased enrollees who did not have a date of death recorded in the State agency's eligibility system but who did have a date of death recorded in the DMF, which we estimate to be at least $6,737,760.

25-A-07-044.03 to CMS - Open Unimplemented
Update expected on 03/30/2026
We recommend that the Colorado Department of Health Care Policy and Financing recover unallowable capitation payments totaling $582,406 that were made to MCOs during our audit period on behalf of deceased enrollees who did have a date of death recorded in the State agency's eligibility system.

25-A-07-044.04 to CMS - Open Unimplemented
Update expected on 03/30/2026
We recommend that the Colorado Department of Health Care Policy and Financing identify and recover unallowable capitation payments made on behalf of deceased enrollees after our audit period and repay the Federal share of any amounts recovered.

25-A-07-044.05 to CMS - Closed Implemented
Closed on 06/10/2025
We recommend that the Colorado Department of Health Care Policy and Financing strengthen internal controls, to include strengthening policies and procedures on identifying and verifying date-of-death information, so that the State agency's eligibility system is updated based on information provided by data sources, and that capitation payments that have been made on behalf of verified deceased enrollees are recovered.

25-A-07-044.06 to CMS - Open Unimplemented
Update expected on 03/30/2026
We recommend that the Colorado Department of Health Care Policy and Financing strengthen policies and procedures for the accurate reporting of all Medicaid expenditures to CMS, to include strengthening the State agency's procedures for the routine reconciliation of information provided by the State agency's fiscal data vendor, so that only actually incurred Medicaid expenditures are reported on the Forms CMS-64 to CMS.

View in Recommendation Tracker

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