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States face ongoing challenges in meeting third-party liability requirements for ensuring that Medicaid functions as the payer of last resort
States face ongoing challenges in meeting third-party liability requirements for ensuring that Medicaid functions as the payer of last resort
Why OIG Did This Audit. Medicaid is generally the payer of last resort. This means that if a Medicaid enrollee has another source of health care coverage, that source should pay its share before Medicaid pays. Federal regulations refer to amounts owed by non-Medicaid payers as third-party liability (TPL). Prior OIG and Government Accountability Office reports identified several challenges State Medicaid agencies have encountered in their efforts to meet TPL requirements to help ensure that Medicaid functions as the payer of last resort. Some of the more recent reports suggest that many of these challenges are ongoing and that billions of dollars are at risk. The objectives of our audit were to identify challenges States have experienced in their efforts to meet TPL requirements and actions they have taken to address those challenges. In addition, we were to determine whether States reported Medicaid TPL amounts on the CMS-64 statement according to Federal requirements. How OIG Did This Audit. We sent questionnaires to State agency officials from all 50 States and the District of Columbia (collectively referred to as States) to inquire about TPL challenges each State has incurred and to gather information on how they responded to those challenges. We also reviewed States’ TPL reporting during Federal FYs 2019 and 2020.
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