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Series: Medicaid Managed Care Organizations' Denials

Announced on  | Last Modified on  | Series Number: W-00-24-31535

OBJECTIVE

The State Medicaid agency and the Federal Government are responsible for the financial risk for the costs of Medicaid services. State Medicaid agencies contract with managed care organizations (MCOs) to ensure that beneficiaries receive covered Medicaid services. The contractual arrangement shifts the financial risk from the State Medicaid agency and the Federal Government to MCOs, which can create an incentive for MCOs to deny beneficiaries' access to covered services. Our audits will determine whether Medicaid MCOs complied with Federal requirements when denying access to requested medical and dental services, behavioral health services, and associated drug prescriptions that required prior authorization.

There are 4 projects in this series.

Project titles will remain unpublished until projects are complete and reports are posted.

ACTIVE PROJECTS IN THIS SERIES (1)

COMPLETED PROJECTS IN THIS SERIES (3)

Health Share of Oregon Did Not Always Comply With Requirements When Denying Prior Authorization Requests

Community Behavioral Health

Review of Behavioral Health MCO Denials in Louisiana

TIMELINE

  • February 8, 2024
    Series Number W-00-24-31535 Assigned
  • February 8, 2024
    Project Announced

    Review of Behavioral Health MCO Denials in Louisiana - A-06-24-02000

  • February 20, 2024
    Project Announced

    Community Behavioral Health - A-03-24-00204

  • August 19, 2024
    Project Announced

    Health Share of Oregon Did Not Always Comply With Requirements When Denying Prior Authorization Requests - A-09-24-02007

  • February 5, 2025
    Project Announced

    Project OAS-25-07-039

  • March 30, 2026
    Project Complete - A-06-24-02000

    Review of Behavioral Health MCO Denials in Louisiana complete. Report Published

  • June 8, 2026
    Project Complete - A-03-24-00204

    Community Behavioral Health complete. This audit resulted in 6 recommendations.

  • August 13, 2026
    Project Complete - A-09-24-02007

    Health Share of Oregon Did Not Always Comply With Requirements When Denying Prior Authorization Requests complete. This audit resulted in 4 recommendations.

  • Today
    1 Audit In-Progress
  • Est FY2027
    Estimated Fiscal Year for Series Completion

3 REPORT PUBLISHED

26-A-03-072.01 to CMS - Open Unimplemented
Update expected on 12/07/2026
We recommend that CBH update its policies and procedures to include: (1) a requirement to reconcile discrepancies between addresses of record and addresses given to treatment providers and (2) a process for determining when a change of residency occurs and notifying the CAO accordingly.

26-A-03-072.02 to CMS - Open Unimplemented
Update expected on 12/07/2026
We recommend that CBH implement a process for identifying service requests that are considered approved because a decision notification was not sent within the 21-day window.

26-A-03-072.03 to CMS - Open Unimplemented
Update expected on 12/07/2026
We recommend that CBH coordinate with the State agency to implement a revised initial denial notice that informs enrollees that they have the right to be provided, upon request and free of charge, all documents, records, and other information relevant to the adverse benefit determination as required by 42 CFR section 438.404(b)(2).

26-A-03-072.04 to CMS - Open Unimplemented
Update expected on 12/07/2026
We recommend that CBH revise the language it uses in the denial notice to clarify when services are denied as requested but CBH recommends alternate services that do not require a prior authorization, as opposed to services being completely denied with no alternate services recommended.

26-A-03-072.05 to CMS - Open Unimplemented
Update expected on 12/07/2026
We recommend that CBH update its policies to comply with its HealthChoices Agreement by requiring staff to document the following for enrollees under 21 years of age: (1) steps taken to contact the enrollee's representative to request that the enrollee's representative ask the provider to communicate with CBH, and (2) efforts to reach the provider before issuing denial notices.

26-A-03-072.06 to CMS - Open Unimplemented
Update expected on 12/07/2026
We recommend that the State agency revise the denial notice template in the HealthChoices Agreement to include a statement that the enrollee has the right to be provided, upon request and free of charge, all documents, records, and other information relevant to the adverse benefit determination.

View in Recommendation Tracker

26-A-09-093.01 to CMS - Open Unimplemented
Update expected on 02/12/2027
We recommend that Health Share continue to assess and improve its quarterly reviews of denial notices and related prior authorization documentation by verifying that: denials are made by individuals with the appropriate expertise in addressing the enrollees' medical and oral health needs; denial notices include Health Share's contact information and translated denial notices are provided in non-English languages when appropriate; and denial notices are provided to enrollees and to providers within Federal and State established timeframes.

26-A-09-093.02 to CMS - Open Unimplemented
Update expected on 02/12/2027
We recommend that Health Share require its subcontractors to update their policies to include alternate methods of notifying providers of the denial decision when the providers are not notified verbally or in writing through fax.

26-A-09-093.03 to CMS - Open Unimplemented
Update expected on 02/12/2027
We recommend that Health Share clarify to its subcontractors when to consult with providers to ensure that provider outreach is conducted when insufficient information is provided with the prior authorization request or there are discrepancies in the provided information.

26-A-09-093.04 to CMS - Open Unimplemented
Update expected on 02/12/2027
We recommend that Health Share request its subcontractors to report in the quarterly denial data: the credentials of the individual who made the denial decision to identify whether denials were made by individuals who had appropriate expertise in addressing the enrollees medical and oral needs; and the enrollees' non-English language to identify whether denial notices were sent in the enrollees' non-English language.

View in Recommendation Tracker

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