Finding 1205098 (2025-004)

Material Weakness Repeat Finding
Requirement
G
Questioned Costs
-
Year
2025
Accepted
2026-03-31

AI Summary

  • Core Issue: Claims for Group VIII expenditures incorrectly applied a 90% FMAP rate for Parent/Caretaker beneficiaries, who should have been claimed at a lower rate (76%-77.5%).
  • Impacted Requirements: Compliance with federal matching requirements under 42 CFR §433 and the Medicaid State Plan is at risk due to improper eligibility classification.
  • Recommended Follow-Up: Conduct a review of past claims, return any overclaimed funds, establish clear procedures for eligibility classification, and ensure new system controls are documented and reviewed.

Finding Text

Finding Number- 2025-004 Group VIII Matching Agency Department of Health & Human Services Federal Program Medicaid Cluster ALN 93.778 Compliance Requirement Matching Type of Finding Internal Control over Compliance / Compliance Category Significant Deficiency Criteria Per 42 CFR §433 and the approved State Plan under the Medicaid program, federal reimbursement must be claimed using the appropriate Federal Medical Assistance Percentage (FMAP) applicable to each eligibility category. Under the Affordable Care Act expansion provisions, expenditures related to Childless Adults under Group VIII are eligible for a 90% FMAP during the audit period. However, expenditures related to the Parent/Caretaker eligibility category are subject to the regular FMAP rate applicable to the state during the audit period (approximately 76%–77.5%). Therefore, claims submitted to the federal government must properly distinguish eligibility categories to ensure the correct matching percentage is applied. Condition During our testing of federal reimbursement claims, we identified five (5) invoices in which the description of the expenditure referenced Group VIII, which includes the following eligibility categories: ✓ Childless Adults ✓ Children age 19–20 ✓ Parent/Caretaker All five invoices were claimed at the enhanced FMAP rate of 90%. However, Parent/Caretaker expenditures during the audit period were eligible only for the regular FMAP rate (76%–77.5%). As a result, expenditures that may have corresponded to Parent/Caretaker beneficiaries were included in claims submitted at the enhanced 90% rate without documented support demonstrating proper eligibility classification. Cause The condition resulted from system limitations and the absence of automated eligibility classification during the period prior to MMIS implementation. The lack of system functionality to segregate eligibility categories within Group VIII resulted in all related expenditures being claimed at the enhanced FMAP rate. Effect Claiming expenditures at an incorrect FMAP rate may result in: • Potential overstatement of federal reimbursement • Noncompliance with federal matching requirements • Risk of repayment to the federal government if amounts are determined to be ineligible. Questioned Costs Indeterminable Perspective Information Due to the absence of beneficiary-level segregation and supporting documentation distinguishing eligibility categories within Group VIII during the audit period, we were unable to determine the portion, if any, of the tested expenditures attributable to the Parent/Caretaker category that may have been claimed at an incorrect FMAP rate. Prior Year Audit Finding This is not a repeat finding. Recommendation We recommend that management: 1. Perform a retrospective analysis of Group VIII expenditures during the audit period to determine whether any Parent/Caretaker expenditures were improperly claimed at the 90% FMAP rate. 2. Quantify and return any overclaimed federal funds, if applicable. 3. Implement formal written procedures to ensure that eligibility categories are properly classified prior to submission of federal claims. 4. Ensure that the enhanced MMIS segregation controls implemented in Q3 2024 are formally documented and subject to periodic supervisory review. Views of Responsible Officials and Planned Corrective Actions The PRDH’s management agrees with this finding. Please refer to the corrective action on pages 57-60.

Corrective Action Plan

PRMP partially concurs with this finding and emphasizes that claims submitted to the federal government must accurately distinguish eligibility categories to ensure the appropriate federal matching percentage is applied. A corrective action plan has already been implemented as part of the Phase 3 rollout of the MMIS project, initiated in May 2024. This phase focuses on establishing a comprehensive Financial Management solution within PRMMIS. The enhanced system capabilities support the calculation, production, and distribution of capitation and supplemental payments to carriers, including automated adjustments and reconciliations. Stabilization activities have also included the conversion and reconciliation of legacy system data to facilitate a seamless transition.

Categories

Eligibility Cash Management Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1205097 2025-003
    Material Weakness Repeat
  • 1205099 2025-005
    Material Weakness Repeat
  • 1205100 2025-006
    Material Weakness Repeat
  • 1205101 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $4.40B
10.557 Special Supplemental Nutrition Program for Woman, Infants and Children $211.52M
93.767 Medicaid-Children's Health Insurance Program (CHIP) $56.81M
93.323 COVID-19 Epidemiology and Laboratory Capacity $32.90M
66.468 Fund of Drinking Water $29.69M
93.994 Maternal and Child Health Services Block Grant to the State $12.98M
93.268 Immunization and Vaccines PPHF $11.73M
93.323 Epidemiology and Laboratory Capacity $8.19M
93.940 Integrated HIV Surveillance And Prevention Programs $8.10M
93.967 COVID-19 Strengthening US Public Health $5.60M
93.069 Public Health Crisis Response $5.16M
84.181 Special Education - Grant for Infants and Families $3.21M
97.036 Hurricane Maria $3.19M
93.255 Children's Hospitals Graduate Medical Education Payment Program $2.83M
93.354 COVID-19 Workforce Supplementary Funding $2.60M
93.391 COVID-19 Health Disparities $2.46M
93.917 HIV Care Formula Grants $2.41M
93.991 Preventive Health Services Block Grant $2.29M
93.889 National Bioterrorism Hospital $2.22M
93.967 Strengthening US Public Health $1.62M
93.235 State Sexual Risk Avoidance Education $1.32M
93.977 PRDOH Strengthening STD Prevention And Control $1.22M
93.791 Money Follows Person Rebalance $1.06M
93.377 Prevention & Control Of Chronic Disease And Associated Risk Factor In PR $1.04M
93.870 ACA-Maternal Infant and Early Childhood Home Visiting $1.02M
93.136 PR Overdose Data to Action $959,187
66.432 State Public Water System Supervision $916,745
93.777 Health Insurance Benefits Program $886,201
93.136 PR Comprehensive Suicide Prevention $801,744
93.977 COVID-19 PRDOH Strengthening STD Prevention And Control $591,450
20.607 Alcohol Toxicology Laboratory $583,518
93.889 Hospital Preparedness Program $485,243
93.136 PR Sexual Violence Prevention and Education $479,905
93.008 National Association of County and City Health Officials $478,869
93.998 Puerto Rico Autism and Development $464,678
93.243 PR Broad-Based Approach to Suicide Prevention in Adults $458,509
93.336 PR BRFSS Surveillance System $449,385
93.777 Clinical Laboratory Services $431,958
93.270 Integrated Viral Hepatitis Surveillance and Prevention Program $390,286
93.092 Affordable Care Act (ACA) Personal Responsibility Education Program $375,665
93.197 PR Childhood Lead Poisoning $355,179
93.944 Medical Monitoring Project $344,694
93.354 Public Health Crisis Response $335,816
93.944 HIV Care Formula Grants $331,205
93.116 Puerto Rico Tuberculosis Program $298,354
93.870 COVID-19 American Rescue Plan Act Funding $297,406
93.946 PR Maternal Mort Rev Committee Deaths Prevention $256,437
93.354 PHER-Monkey Pox $218,238
93.251 Universal Newborn Hearing Screening $217,564
93.946 PR - Pregnancy Risk Assessment Monitoring System $151,238
93.130 State Primary Care Offices $132,615
93.334 Alzheimer Disease PR $125,375
93.314 Enhancement of the EHDI-is for Documentation and use of $119,056
93.497 Administration for Families and Children (ADFAN) $109,441
93.940 Ending HIV Epidemic in SJ $98,627
93.110 Promotion Administration State Stable - Help Center for Rape Victims $95,957
93.387 Optimize PRQ Tabacco Education $88,333
14.241 Housing Opportunities for Persons with AIDS $72,554
93.945 Social Determinants of Health $60,177
93.734 Prevention & Control Of Chronic Disease And Associated Risk Factor In PR $40,743
93.048 Promotion of Independence Living $19,936
93.777 IMPACT Award $12,148
93.354 COVID-19 Public Health Crisis Response $11,933
97.036 Hurricane Irma $1,250
93.070 Puerto Rico Comprehensive Public Health Approach to Asthma Control $0
93.136 COVID-19 PR Sexual Violence Prevention and Education $-5,292
93.268 COVID-19 Immunization and Vaccines PPHF $-21,538
97.036 COVID-19 Pandemic $-875,721
93.778 COVID-19 Medical Assistance Program $-3.26M