To ensure that the providers receive reimbursement for only valid services, Health Care Services should immediately direct its investigations division to determine whether it authorized any improper payments to program providers for deceased beneficiaries outside of our audit period. It should also determine whether it authorized such payments through its other Medi-Cal programs. Health Care Services should initiate efforts to recover such payments as appropriate.
Fiscal Management and Accountability Branch (FMAB) and EITSD determined that no further enhancement is needed to the Short-Doyle system to address this issue. All improper payments have been recouped, an edit in the Short-Doyle system was deployed to prevent future improper payments, Medi-Cal Eligibility Division improved their ability to provide rapid notification on beneficiary deaths; and a quarterly report from Short-Doyle is generated and reviewed by FMAB to review for potential dead beneficiary overpayments.
Status and Implementation Date: Fully Implemented, 7/18/2017.
Although Health Care Services indicated that it has fully implemented this recommendation, it did not provide adequate documentation to support its assertion.
Program is currently waiting on the Enterprise Information Services Division to complete system enhancements on the Short Doyle Platform.
For the dead beneficiaries identified in the CSA report, FMAB has determined that providers were inappropriately paid for services provided to beneficiaries after their date of death. A total of $2,566.83 will be recovered in the FY 12-13 cost report settlement. Invoices are being prepared to recoup the remaining $3,257.67 in inappropriate payments (for services provided prior to FY 12-13). Anticipated completion is January 2016 (when the FY 12-13 cost reports are settled).
As stated in the six-month update, MCED developed a six-month work plan to reduce the lag time to improve identification of dead beneficiaries and prevent improper payments going forward via system edits within all Medi-Cal programs. Over the last year, MCED has identified and evaluated numerous federal, state, private, and direct reporting sources that help public assistance programs identify unreported beneficiary deaths. Based on this evaluation, DHCS forecasts that comprehensive improvements will be in place on or before June 30, 2016. This includes the acquisition, testing, and rollout of new death notification sources and the improvement of existing channels. These enhancements will be in place for the entire Medi-Cal population. In addition, FMAB developed queries to manually check for potential dead-beneficiary overpayments. Queries will complement the enhanced system edit capabilities with MCED's six-month work plan. FMAB also reviewed the DMC list of dead beneficiaries identified by CSA to confirm overpayments made. FMAB completed the analysis and will pursue DMC overpayment recoveries.
Date of implementation is set for June 2016.
MCED confirmed improper payments were made due to deceased beneficiaries that were not identified timely. A&I worked with MCED and determined excessive lag time in updating deceased beneficiary information on Medi-Cal Eligibility Data System (MEDS). MCED developed a six month work plan to reduce the lag time to improve identification of dead beneficiaries and prevent improper payments going forward via system edits within all Medi-Cal programs.
In addition, FMAB is developing queries to manually check for potential dead-beneficiary overpayments. Queries will complement the enhanced system edit capabilities with MCED's six month work plan.
FMAB is reviewing the DMC list of dead beneficiaries identified by CSA to confirm overpayments made. Once analysis is completed, FMAB will pursue DMC overpayment recoveries.
DHCS is pursuing two remedies for the identification of dead beneficiary-related overpayments outside of DMC program and CSA's audit period:
1)A&I data analytics system now contains alerts to indicate when claim is paid for dead beneficiaries. A&I staff will continuously review the flags to determine if an investigation should be initiated. Currently, there is limitation to this process because data analytics contract only covers Short-Doyle Medi-Cal data. Therefore, alerts only apply to DMC and Mental Health claims. Once DHCS awards the data analytics contract in Spring 2016, alerts will be available for all Medi-Cal programs.
2)With remedy #1 limitations, DHCS is exploring options for Xerox to run necessary algorithms to identify dead beneficiary-related overpayments for past claims. Once overpayments are identified, recoveries will be pursued.
A&I will coordinate with the Substance Use Disorder (SUD) division and develop an audit plan to identify overpayments for deceased beneficiaries outside CSA's audit period. If A&I confirms that improper payments were made, recovery of the overpayments will be pursued. Moreover, if A&I establishes a credible allegation of fraud, it will also refer the matter to the state DOJ as required.
In addition, the A&I received a comprehensive analysis of payment made for deceased beneficiaries from its contractor, and is in the process of analyzing the report for inappropriate payments made to deceased beneficiaries for SUD and other Medi-Cal programs. And, as seen in response to recommendation 15, DHCS has updated its procedures to include a search of the US Social Security Administration Death Master File.
Health Care Services indicated that it will not implement this recommendation until January 2015.
Agency responses received are posted verbatim.