It is somehow fitting that today, the first day of Summer, serves as the birthday of Brian Wilson, the now-70-year-old musical engine behind the great songs of The Beach Boys. I’d love to be at the beach right now, belly-surfing like a seal in the semi-clean waters that surround the North American continent, but this dream will have to be deferred for today. I’ll give you a song you can listen to to put you in that place while I document the latest audit atrocity.
I made reference in a past posting about the poor showing of the Medicaid Integrity Program, as reviewed by the OIG. The two reports from the OIG seemed to criticize the selection of audit targets by CMS that were eventually referred to the Audit Medicaid Integrity Contractors (MIC). The biggest suggestion that came out of those reports was for CMS to pursue collaborative audits between CMS, the OIG, the MIC’s and the individual Medicaid State Fraud Control Units.
In the past week, criticism of the program came from another portion of the Oversight Universe, that being the Government Accountability Office (GAO). According to a report released on June 14th (just in time for Flag Day), conducting Medicaid fraud audits since 2008 has cost the government $102 million, and has led to the collection of less than $20 million. Unlike the previous OIG reports, the GAO pointed a finger at the data retrieved from the Medicaid Statistical Information System (MSIS), which CMS has used to identify audit targets.
The MSIS system includes raw claims data, but excludes such important elements as “to which provider do these suspect claims belong?”. Remember kids, the only way you can identify anything in this world is to give it a name in a form you can recognize, as I learned when I was small when someone told that the instrument I was playing was in fact a trumpet, and not a “blowy, push-button thingy”.
As an additional point, the GAO indicated that the National Medicaid Audit Program is desperately in need of redesign, which is a fact that the Medicaid Integrity Group (MIG) has acknowledged and attempted to commence. To date, no details have been reported to Congress as to what changes are being made and why. The GAO criticized the audit program for its lack of transparency based on this, as well as other related factors.
Providers continue to feel the jellyfish-like sting from an alphabet soup of government audit initiatives. The many programs serve mainly as a burden to providers who wish to do the right thing, but instead encounter programs whose design predetermines their ongoing failure. Like waves crashing on the sand at nightfall, every type of audit repaints claims data with a heavy and indifferent brush. With various government agencies finding problems with the design and execution of government audits, it appears providers have very little opportunity to move away from the surf to safety anytime soon.