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MassHealth's Eligibility Determination Process for Healthcare Services

October 17, 2012 · Office of Medicaid (MassHealth) · Read the full official report (PDF) ↗ · official site ↗

Published October 17, 2012 Audit covers July 1, 2009 – December 31, 2011 Under Suzanne M. Bump · 2011–2023

In plain English
The audit says MassHealth needed stronger checks to make sure people getting benefits actually met income and Massachusetts residency rules.
source
“As a result of the weaknesses we identified in the process MassHealth uses to verify applicant/member income, MassHealth cannot ensure that all of its applicants/members meet the income requirements for enrollment or continued participation in its program.”
Read the plain-English breakdown
What is this?

This is a 2012 Massachusetts State Auditor report reviewing how MassHealth decided whether people qualified for healthcare benefits.

“This audit concerns public healthcare costs being borne by the Commonwealth’s Medicaid program that is administered in Massachusetts by an agency within the state’s Executive Office of Health and Human Services (EOHHS) called MassHealth.”
Why was it audited?

The Auditor looked at whether MassHealth had enough rules and controls to verify eligibility and possibly save taxpayer money by preventing improper benefits.

“The Office of the State Auditor (OSA) initiated an audit of MassHealth’s eligibility determination process to (1) assess the adequacy of the policies and internal controls MassHealth has established relative to this process and (2) if possible, identify opportunities for developing more effective policies and internal controls aimed at ensuring that only eligible applicants receive benefits, which could result in savings to the Commonwealth’s taxpayers.”
Why it matters

MassHealth covers many residents and costs billions, so weak eligibility checks can affect taxpayers and public trust.

“The effectiveness of the policy decisions and the internal controls that MassHealth establishes over its eligibility determination process are essential in addressing these concerns and maintaining the public’s confidence in the integrity of the administration of MassHealth programs.”
What's in it for me?

For an ordinary Massachusetts taxpayer or resident, the issue is whether public healthcare money is going only to people who qualify.

“In fiscal year 2011, MassHealth paid in excess of $12.2 billion to healthcare providers, of which approximately 35% was funded with Commonwealth funds.”
The bottom line

The Auditor found problems in how MassHealth checked income, residency, and conflicting information, creating a risk that ineligible people received benefits.

“As a result, MassHealth may be providing millions of dollars in benefits each year to individuals who are not entitled to receive these benefits.”
What happens next

The Auditor recommended that MassHealth use data matches, request more documentation when needed, and formally document how conflicts are resolved.

“In order to address our concerns in this area, we recommend that MassHealth establish formal procedures on how to address conflicts in information provided by applicants/members, including a requirement to document in each case file the specific measures taken to address such conflicting information.”
Why it's significant

The report says enrollment is a major driver of MassHealth costs, so eligibility errors can have a large financial impact.

“The evidence we have for the Commonwealth is that enrollment is the single most important cost driver for the program and that CMS expects enrollment to further drive costs after 2014, when PPACA is fully implemented.”

9 figure(s) pending source verification - not shown

What the Auditor checked

What the Auditor found

MassHealth did not adequately verify applicants’ and members’ self-reported income.
eligibility determinationinternal controlsrecordkeeping/documentation

Why it matters: MassHealth could provide benefits to people who do not meet income eligibility requirements.

Standard: MassHealth regulations 130 CMR 506 and 130 CMR 516.006(D), and federal Medicaid regulations 42 CFR 435.940 through 435.965, including 42 CFR 435.948 and 435.952. ( 130 CMR 506; 130 CMR 516.006(D); 42 CFR 435.948(b) and 435.952(a); 130 CMR 501.010(B) )

4 recommendations
  • Perform data matches with DOR for all applicants and family members at the time of application.agency: partially agreed
  • Use DOR 14-Day New Hire and Quarterly Wage reports within 45 days instead of only at annual redetermination.agency: partially agreed
  • Establish data matches with the IRS and Office of the State Treasurer to verify unearned income and lottery winnings.agency: partially agreed
  • Require applicants reporting zero household income to explain how they pay daily living expenses.agency: partially agreed
Agency response & Auditor reply
Agency: "MassHealth agrees with the Auditor Report that it should continue to review and improve the current process for verifying income, particularly in light of the opportunities created by the Integrated Eligibility System made possible by the Affordable Care Act."
Auditor: "As a result of these issues, we believe that the process currently being used by MassHealth to verify both earned and unearned income of applicants and members is deficient and ineffective in ensuring that only individuals who meet MassHealth’s income eligibility requirements receive services."
MassHealth did not effectively verify applicants’ Massachusetts residency.
eligibility determinationinternal controlsrecordkeeping/documentation

Why it matters: Non-residents may have received MassHealth benefits, costing the Commonwealth millions of dollars.

Standard: MassHealth residency regulations 130 CMR 503.002 and 130 CMR 517.002, and federal documentation requirements in 42 CFR 435.913(a). ( 130 CMR 503.002 and 130 CMR 517.002; 42 CFR 435.913(a); 42 CFR §435.403 )

3 recommendations
  • Use electronic data matches at application to verify self-declared residence.agency: disagreed
  • Require documentation of residency when electronic matching is not possible.agency: disagreed
  • Verify member residency quarterly and require documentation to resolve conflicts.agency: disagreed
Agency response & Auditor reply
Agency: "MassHealth’s process for verifying residency is fully compliant with federal law and, as a policy matter, ensures that eligible Massachusetts residents are able to access needed MassHealth benefits without unnecessary barriers."
Auditor: "Although MassHealth’s policy of accepting an applicant’s self-declaration is permissible under federal law, for the reasons stated in our report, we believe that MassHealth should take measures to strengthen its controls over the process its uses to establish an applicant’s residency status."
MassHealth did not adequately resolve conflicting residency and income information in applicant and member records.
eligibility determinationinternal controlsrecordkeeping/documentationdata privacy

Why it matters: MassHealth may be paying millions of dollars annually for benefits to people who are not eligible.

Standard: Federal regulation 42 CFR 435.913 and MassHealth regulations requiring investigation of conflicting information, including 130 CMR 517.002. ( 42 CFR 435.913; 130 CMR 517.002; 42 U.S.C. § 1396b(v)(2) )

1 recommendation
  • Establish formal procedures for resolving conflicting applicant and member information and documenting the steps taken in each case file.agency: disagreed
Agency response & Auditor reply
Agency: "MassHealth therefore disagrees with the Audit’s conclusion that any individual with a foreign passport would not be eligible for MassHealth Limited coverage…"
Auditor: "We disagree with MassHealth’s assertion that the test for state residency is distinct from an individual’s citizenship and immigration status."

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