On September 19, 2019, the OIG released a report relating to recent audits of the CHIPRA program. The audits, performed from April 2012 through September 2017, identified over $277 million in unallowable payments made to 12 states: Virginia, Alaska, Idaho, Kansas, Colorado, New Mexico, North Carolina, Wisconsin, Ohio, Washington, Louisiana, and Alabama.
Under CHIPRA, certain qualifying states received bonus payments for 2009 through 2013 to offset the costs of increased enrollment of children in Medicaid. Under the program, a state was eligible for a bonus payment if it increased its current enrollment of qualifying children in its Medicaid program above the baseline enrollment of qualifying children for a given year. To qualify for a bonus payment, a state must also have implemented at least five of the Medicaid enrollment and retention provisions specified in CHIPRA.
In total, CMS paid $645,009,558 in CHIPRA bonus payments for the given years, 40% of which were identified as “unallowed” under the terms of the bonus program. According to CMS, states were instructed to calculate their current CHIPRA enrollment figures by using the same “institutional data sources” as used for reporting under the Medicaid Statistical Information System. However, states incorrectly calculated the CHIPRA enrollment figures, resulting in allegedly “inflated” figures, which were then used as the basis for the CHIPRA bonus payments.
Given that the bonuses were allegedly calculated based upon the incorrect enrollment figures, CMS took action to recover the alleged overpayments. To date, three states voluntarily returned overpayments totaling approximately $37 million, and CMS has recovered $88 million in “unallowable” payments. CMS is also working with the states to recover the remaining $189 million. CMS has also withheld approximately $51 million from three states with unspent bonus payment funds. In the report, the OIG recommended that CMS (1) continue to work with the states to collect the outstanding remainder of $189 million in “unallowable” CHIPRA bonus payments, and (2) use the findings of the report to tighten controls and review processes in similar programs.
The full report is available here.
