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Audit of Office of Medicaid (MassHealth) - Review of Drug Testing Frequency

July 27, 2018 · Office of Medicaid (MassHealth) · Read the full official report on mass.gov ↗ · official site ↗

Published July 27, 2018 Audit covers July 1, 2012 – June 30, 2016 Under Suzanne M. Bump · 2011–2023

In plain English
MassHealth paid for many drug tests during 2012-2016, and the auditor found that some payments may have been for tests that were unnecessary, improper, or not properly documented.
source
“MassHealth may have paid as much as $6.2 million for unnecessary drug tests.”
Read the plain-English breakdown
What is this?

This is a Massachusetts State Auditor performance audit looking at MassHealth payments for drug testing from July 1, 2012 through June 30, 2016.

“OSA has conducted an audit of MassHealth’s drug tests for the period July 1, 2012 through June 30, 2016.”
Why was it audited?

The audit checked whether MassHealth was paying only for drug tests that were connected to diagnosis, treatment, or medical need.

“The purpose of this audit was to review the drug tests that MassHealth paid for during the audit period and determine whether the nature and frequency of testing complied with MassHealth regulations, which allow authorized prescribers treating MassHealth members to order and use drug tests for diagnosis, treatment, or otherwise medically necessary purposes.”
Why it matters

This matters because MassHealth is a major public program, and the report says public trust is important to keeping support for Medicaid.

“As with any government program, public confidence is essential to the success and continued support of the state’s Medicaid program.”
What's in it for me?

For an ordinary taxpayer or MassHealth member, the issue is whether public healthcare money was spent on drug tests that were truly needed instead of being wasted.

“These funds could have been used to pay for other medical services to MassHealth members.”
The bottom line

The auditor concluded that MassHealth did not always pay only for drug tests tied to diagnosis, treatment, or medical necessity.

“Did MassHealth only pay for drug tests that were used for diagnosis, treatment, or otherwise medically necessary purposes?”
What happens next

The auditor recommended stronger controls, better claim information, reviews of lab paperwork, and repayment for unsupported payments.

“MassHealth should collaborate with the laboratory discussed in this finding to establish a plan for repayment of the $21,073 in overpayments for improper laboratory drug test billings.”
Why it's significant

The report is significant because MassHealth paid about $39.8 million for drug tests for more than 240,000 members during the audit period, and the auditor questioned millions of dollars in payments.

“During this period, MassHealth paid laboratories approximately $39,771,152 to provide drug tests for 240,711 MassHealth members.”
Jargon, unpacked

In plain terms, “residential monitoring” means drug testing required by a sober home to check whether residents are using alcohol or drugs, rather than testing that is tied to medical treatment.

“This type of testing is referred to as residential monitoring, since the sober home requires it in order to ensure that a resident is not abusing alcohol or drugs.”
Identified in this audit - source-verified
$741,621

3 figure(s) pending source verification - not shown

What the Auditor checked

What the Auditor found

MassHealth may have paid for unnecessary drug tests that were not tied to diagnosis, treatment, or medical necessity.
internal controlsrecordkeeping/documentationvendor oversight

Why it matters: Funds could have been used to pay for other medical services to MassHealth members.

Standard: 130 CMR 401.402 and 130 CMR 401.416(A), plus SAMHSA Treatment Improvement Protocol 47 guidance. ( Section 401.402 of Title 130 of the Code of Massachusetts Regulations; 130 CMR 401.416(A) )

3 recommendations
  • MassHealth should establish controls to ensure that it only pays for drug tests that are used for diagnosis, treatment, and otherwise medically necessary purposes.
  • MassHealth should ensure that all claim submissions include the referring provider’s identification number and use this information to monitor or edit claims.
  • MassHealth should require laboratories to send all drug test results directly to the prescribing providers who ordered them.
Agency response & Auditor reply
Agency: "MassHealth disagrees with the finding that it may have paid as much as [$6.2] million for unnecessary drug tests."
Auditor: "Our report explains that our $6.2 million calculation was not based on the results of our audit testing at one laboratory; rather, our audit work at laboratories was only the initial testing we conducted that helped us identify what appeared to be a high risk of improper payments for drug testing."
MassHealth may have paid for drug tests for sober-home residents that appeared to be for residential monitoring.
internal controlsvendor oversightrecordkeeping/documentation

Why it matters: MassHealth may have paid for tests that its regulations do not cover because they were for residential monitoring rather than medical treatment.

Standard: 130 CMR 401.411(B)(5). ( 130 CMR 401.411(B)(5) )

2 recommendations
  • MassHealth should work with BSAS officials to ensure that it does not pay for drug tests for residential monitoring.
  • MassHealth should periodically review laboratory drug test order forms and result reports to monitor whether laboratories are billing for medically necessary drug tests.
Agency response & Auditor reply
Agency: "MassHealth disagrees with the finding that it may have improperly paid $741,621 for members residing in sober homes."
Auditor: "Our audit found that MassHealth may have improperly paid at least $741,621 for drug tests for members living in either certified or non-certified privately owned sober homes or recovery homes."
MassHealth paid for drug tests that lacked required order and result documentation.
recordkeeping/documentationinternal controlsvendor oversight

Why it matters: Without this information, MassHealth cannot ensure that these tests are medically necessary and meet its requirements for covered services.

Standard: 130 CMR 401.416(A), 130 CMR 401.416(C), and 130 CMR 401.417. ( 130 CMR 401.416(A); 130 CMR 401.416(C); 130 CMR 401.417 )

2 recommendations
  • MassHealth should work with drug test laboratories to ensure that they obtain and retain proper documentation of drug test orders and results for each drug test provided to a MassHealth member.agency: already implemented
  • MassHealth should collaborate with the laboratory in question to establish a plan for repayment of the $21,073 in overpayments for improper laboratory drug test billings.agency: agreed
Agency response & Auditor reply
Agency: "MassHealth requested and received the claim examples identified by OSA as not having required documentation and will recover any payments for claims lacking the necessary documentation."

Verified dollar findings

Questioned costs $741,621

Costs the audit could not support as allowable, pending the entity's response.

$741,621 - questioned costs

Prior findings revisited

Still a problem
"A previously issued OSA audit report (No. 2012-1374-3C) disclosed significant weaknesses in MassHealth’s claim-processing system for drug tests, which resulted in millions of dollars in potentially improper payments."

More audits of this entity

Other Office of the State Auditor reports on Office of Medicaid (MassHealth) , including the prior audits referenced above.

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