The Mississippi state Medicaid agency claimed over $21 million in unallowable school-based administrative costs over a three-year period, according to an OIG review of the state’s school-based and community-based administrative costs. The improper reimbursement request arose from inadequate documentation and sampling.
For Fiscal Years 2010 through 2012, Mississippi claimed school-based administrative costs, which are considered public assistance costs, totaling nearly $42.4 million. The OIG conducted a review of the state’s administrative costs because of the significant amount claimed and the fact that the state had not submitted a cost allocation plan (CAP). School-based Medicaid administrative costs are reimbursable when the costs are for activities that directly support identifying and enrolling potentially eligible children in Medicaid.
The OIG determined that the state Medicaid agency claimed costs in violation of federal requirements. Specifically, the state agency used statistically invalid random moment sampling (RMS) to allocate its Medicaid costs and did not maintain adequate support to validate its sample results and related extrapolations. When evaluating the legitimacy of the RMS, the OIG found duplications on participant lists, improperly documented employee schedules, and sampling that included improper days like holidays. Additionally, sample data was not properly stored and could not be duplicated to ensure accuracy.
Additionally, under 45 C.F.R. Sec. 95.507(a), states must submit to the division of cost allocation (DCA) a CAP that follows federal requirements. The state submitted $42,399,301 ($21,199,651 in FFP) in school-based Medicaid administrative costs without promptly submitting all of the necessary information to DCA.
The OIG recommended the state agency:
- refund $21,199,651 to the Federal Government;
- revise its implementation plan and amend its CAP to both address the statistical validity issues identified and incorporate CMS’s sampling documentation requirements;
- implement policies and procedures to ensure that its RMS complies with Federal requirements for statistical validity;
- maintain adequate support, including all information necessary to reproduce and verify its sample results, for school-based administrative costs allocated to Medicaid;
- promptly submit to DCA for review and approval its future CAP amendments describing its procedures for identifying, measuring, and allocating costs to Medicaid; and
- review school-based Medicaid administrative costs claimed after the audit period and refund unallowable amounts.
The State agency disagreed with the OIG’s comments but did not address the recommendations. The state agency disagreed that its RMS was statistically invalid and asserted that it was, instead, properly documented.