Corrective Action Plans

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2024-021 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: Use of Tax Return Resources Three MAGI beneficiaries - DOM did not verify self-employment income reported on tax return One of the 180 MAGI beneficiaries - reported self-employment income, DOM did not request a tax return DOM Does Not Concur. OSA compared eligibility data to state income tax returns. DOM is prohibited from accessing state income tax records per Mississippi Code Annotated 27-3-73 and currently, is not allowed to have access to federal income tax records. For eligibility, DOM asserts compliance with the CMS-approved state plan. During the audit period, the state used the CMS MAGI Based Verification plan to confirm income reports using all available electronic data sources according to CMS's reasonable compatibility standard. DOM must accept applicant information and use CMS-approved verification methods to check its accuracy. If self-employment income is not reported and DOM's tools do not detect it, DOM has met eligibility and compliance standards set by CMS. In addition, tax returns are considered outdated and not relevant to DOM. Six of the 180 MAGI beneficiaries - income was not verified through Mississippi Department of Employment Security DOM Partially Concurs. Four beneficiaries' income was not verified through Mississippi Department of Employment Security (MDES). DOM requested MDES on the identified beneficiaries and found no new information that would have affected the eligibility decision. DOM does not concur with two of the findings as MDES was requested on those beneficiaries. Each finding will be reviewed with the individual team members and additional communication has been provided to all Eligibility Team Members. Twelve of the 300 beneficiaries - the beneficiary's case file did not contain a completed application. DOM Concurs. DOM was unable to locate and provide the auditors the original application for the twelve beneficiaries. These documents do not impact the redetermination of eligibility. All redetermination decisions have been verified as accurate. Six of the 300 beneficiaries - DOM could not provide a case file. DOM Concurs. DOM was unable to locate and provide the auditors the case files for six beneficiaries. These documents do not impact the redetermination of eligibility. All redetermination decisions have been verified as accurate. One ABD beneficiary - resources were not verified through AVS at the time of redetermination. DOM Concurs. DOM has since requested AVS records for the beneficiary in question. No bank accounts were found, which indicates there was no impact to eligibility. The Eligibility Team Member will be coached to ensure appropriate processes are followed for all future cases. One hundred thirty-five beneficiaries were not included on all of the required quarterly Public Assistance Reporting Information System (PARIS) file transmissions for fiscal year 2024. DOM Partially Concurs. DOM does not concur with a number of these findings as they were appropriately absent from the PARIS request file because they were in a denied status, had retroactive coverage, or was absent due to the timing of the case approval. DOM concurs with some of the findings. Findings related to COE 29 - Family Planning were addressed in late 2023, which was after the approval of these cases. This issue was resolved in late 2023. There were findings that occurred due to the timing of the PARIS file. DOM has submitted a change request to submit the PARIS file based on the run date not based on the end of the previous month. All previously missed members were added to the 11/1/2025 PARIS outgoing data file, and this report was provided to the auditors. No eligibility decisions were affected by the 11/1/2025 returned PARIS file. DOM Corrective Action Plan: a. DOM submitted a change request to submit the PARIS file based on the eligibility end date of the previous quarter rather than the actual run date. This has been completed. All individual issues identified will be reviewed with the appropriate team member. b. Brian Whitmire c. March 31, 2026

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2023-024 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: Use of Tax Return Resources Seven MAGI beneficiaries - DOM did not verify self-employment income reported on tax return DOM Does Not Concur. OSA compared eligibility data to state income tax returns. DOM is prohibited from accessing state income tax records per Mississippi Code Annotated §27-3-73 and currently, is not allowed to have access to federal income tax records. DOM maintains that for determining eligibility, it has complied with the CMS-approved state plan. Using the approved CMS MAGI Based Verification plan in effect during the audit time period, the state sought to verify the reported income to the standard of reasonable compatibility, as defined by CMS, through all available electronic data sources. Further, DOM is required to accept the information provided by the applicant and utilize the available verification methods as detailed in the CMS-approved state plan to evaluate the accuracy of the information provided. If an applicant does not report self-employment income, and the tools available to DOM do not reveal such, DOM has performed its due diligence in the eligibility process and complied with the requirements of CMS, DOM's federal regulatory and oversight agency. Additionally, tax return information is outdated and not deemed applicable to DOM. Four of the 180 MAGI beneficiaries - Income was not verified through Mississippi Department of Employment Security DOM Concurs. This oversight was reviewed with the employees. Additionally, DOM Eligibility staff will be reminded of the MOES response time to ensure that when a MOES request is generated the adequate response time is waited prior to processing an application. Two of the 300 beneficiaries - The beneficiary's case file did not contain a completed application. DOM Concurs. This file could not be located. One of the 300 beneficiaries - DOM could not provide a case file. DOM Concurs. This file could not be located. Fifteen ABD beneficiaries - Resources were not verified through A VS at the time of redetermination. DOM Concurs. This was a previous finding that DOM concurred with. In June 2022, the eligibility system change request list was updated to include asset checks within the system processing workflow to eliminate the manual request process and facilitate asset verification through A VS. This process was implemented June of 2022 for redetermination contacts. Application contacts are a manual process. DOM did not perform resource verification through A VS for the beneficiaries in question prior to this implementation. However, after being notified DOM ran A VS for all applicants, which resulted in no change in the eligibility determination. One hundred ninety-five beneficiaries were not included on all of the required quarterly Public Assistance Reporting Information System (PARIS) me transmissions for fiscal year 2023. Of the 195 beneficiaries, one beneficiary was not included on any quarterly PARIS me transmissions during fiscal year 2023. DOM Does not Concur. PARIS jobs run on February 1, May 1, August 1, and November 1. PARIS will not be pulled on a beneficiary if the case is closed at the time the file is generated or if there is no SSN on file. Additionally, while the records are sent, not all the cases return a match. Our vendor confirmed that a PARIS request was sent for the open cases with SSN numbers on file with one exception. One case was in COE 29-Family Planning. The omission was identified in a previous audit and was corrected in late 2023. DOM Corrective Action Plan: a. All issues identified will be reviewed with regional office staff. Examples of these issues will be included in annual training sessions performed by Eligibility staff. Further, DOM is implementing an electronic storage system to house all documents associated with applicants/beneficiary files. b. Cindy Bradshaw c. December 31, 2024

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2022-025 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: DOM acknowledges OSA's concern regarding the initial review of case files and the prompt action to select and provide a new sample of cases. Historically, DOM has provided a hardcopy of the actual beneficiary case files to OSA. Since those cases were active, an inventory control process, which included a notation in the electronic beneficiary file of the request to send the physical folder to the central office, was implemented. Likewise, upon arrival in the central office, notation of receipt of the files are added to the system prior to providing said files to the auditor. Occasionally, there are multiple files depending on the office with whom a beneficiary communicates, and multiple individual files associated with a family case. Additionally, cases in the sample may also be undergoing redetermination. To ensure that OSA has all the documentation needed for their case review, DOM staff reviews the files prior to sending them to central office. If an adverse eligibility determination is discovered, DOM has an obligation to correct at the time of discovery. As such, changes to the files are noted in the case history, which is available to the auditors. DOM will be transitioning to a paperless environment, which should alleviate any concerns during future audits. Use of Tax Return Resources DOM Does Not Concur. OSA compared eligibility data to state income tax returns. DOM is prohibited from accessing state income tax records per Mississippi Code Annotated ?27-3-73 and currently, does not have access to federal income tax records. DOM maintains that for determining eligibility, it has complied with the CMS-approved state plan. Using the approved CMS MAGI Based Verification plan in effect during the audit time period, the state sought to verify the reported income to the standard of reasonable compatibility, as defined by CMS, through all available electronic data sources. Further, DOM is required to accept the information provided by the applicant and utilize the available verification methods as detailed in the CMS-approved state plan to evaluate the accuracy of the information provided. If an applicant does not report self-employment income, and the tools available to DOM do not reveal such, DOM has performed its due diligence in the eligibility process and complied with the requirements of CMS, DOM's federal regulatory and oversight agency. OSA questioning DOM's determinations based on information that DOM was not provided nor have access to is shortsighted and does not align with the federal regulations that are imposed on this agency. While DOM is only required to use tax return information in certain circumstances, the agency continues to pursue the authority to review state and/or federal tax return information. To date, DOM has not been provided statutory authority to access Mississippi Department of Revenue tax information and is still awaiting IRS approval of the Safeguard Security Risks document. DOM plans to continue to follow the approved federal/state plan for eligibility determinations and will utilize additional resources as they become available. One MAGI beneficiary - DOM did not use taxable unearned income reported on tax return DOM Concurs. The application on file states neither parent has earned income. Although, the unearned income was not included in the initial calculation, adding it did not result in the beneficiary being ineligible. One MAGI beneficiary - self-employment income was reported to MDOM, but MDOM did not request a tax return from the beneficiary. DOM Concurs. The tax return was not requested for this particular beneficiary. This was an oversight, and the issue has been corrected. Two of the 180 MAGI beneficiaries - income was not verified through Mississippi Department of Employment Security DOM Concurs. There were multiple transactions associated with each of the beneficiaries identified. As a result, DOM's eligibility vendor is investigating to determine the reason the MDES search was not performed. One of the 180 MAGI beneficiaries - the beneficiary's case file did not contain an application or verification of income. DOM Concurs. This file could not be located. One of the 300 beneficiaries - auditors were unable to verify that any eligibility redeterminations have been performed since 2018. DOM Does not Concurs. A redetermination was not completed prior to the PHE. During the PHE, DOM was not allowed to performed redeterminations, which would have allowed DOM to update this file. Nine instances - resources were not verified through AVS at the time of redetermination. DOM Does not Concur. This is a prior finding from OSA 2021-041. Please note that all redeterminations in question occurred prior to the OSA audit period (FY22) and were suspended due to the public health emergency from March 2020 to June 2023. The eligibility system was updated in June 2022, after finding 2021-041, to include automatic asset checks within the system processing workflow to eliminate the manual request process and facilitate asset verification through AVS. Again, each instance identified above occurred prior to this implementation. In addition, AVS was checked on the 9 instances OSA sited, which resulted in no change in the eligibility determination. One instance - the beneficiary's case file did not contain a current level of care decision. DOM Does not Concur. DOM disagrees with this finding as redeterminations for the category of eligibility in question were suspended due to the public health emergency from March 2020 to June 2023. The date in question is from July 2021, which falls within this timeframe, and the child would have been eligible regardless. Seventy-three beneficiaries were not included on all of the required quarterly Public Assistance Reporting Information System (PARIS) file transmissions for fiscal year 2022. Of the 73 beneficiaries, six beneficiaries were not included on any quarterly PARIS file transmissions during fiscal year 2022. DOM Does not Concur. Per an amendment to DOM's CMS-approved State Plan, DOM is only required to verify Title XIX applicants and individuals eligible for covered Title XIX services. The above members were covered in Family Planning, which is not considered Title XIX, and did not receive Title XIX services. Therefore, these members should not have been included on any of the PARIS file transmissions. DOM Corrective Action Plan: a. All issues identified will be reviewed with regional office staff. Further, examples of these issues will be included in annual training sessions performed by Eligibility. DOM will continue to work with the vendor to ensure that income is verified through MOES, as applicable, and to implement controls that will limit this issue in the future. Further, DOM is implementing an electronic storage system to house all documents associated with applicants/beneficiary files. b. Cindy Bradshaw c. December 31, 2024