The CMS requires State Medicaid agencies to use the Social Security Administration’s Death Master File to screen and verify all providers. It should be noted that the CMS says its prudent for providers, CMO’s and state Medicaid agencies to use it to check for beneficiary deaths, as well. Florida didn’t use the Death Master File and, despite having systems and policies in place to identify deceased beneficiaries, still had trouble verifying a beneficiary’s date of death in time to stop managed care payments.
The State of Florida continued to make monthly payments to Medicaid managed care organizations for beneficiaries who had died, according to an audit report released by the Office of the Inspector General (OIG) .
Insurers and providers alike must learn from Florida’s experience and consider whether they have used all the tools available to them to verify date of death — especially the Death Master File.
OIG’s Audit in Florida: Payments for Deceased Beneficiaries
The audit looked at a sample of records in which a managed care payment was made after a beneficiary’s date of death.
In a little over half of the cases sampled for the audit, payments were made even though the Florida Medicaid Management Information Systems (FMMIS) had a correct date of death. Either the date of death was not updated in time or the beneficiary was enrolled in managed care for that month despite having a date of death in the FFMIS. In the rest of the cases, Florida had conflicting or missing date of death information.
As a result of the OIG’s audit, Florida was required to recover over $26 million in payments from the managed care organizations and refund over $15 million to the federal government.
Challenges in Verifying the Date of Death
The audit report stated that Florida had been using three data sources to learn about beneficiary deaths: the Florida Bureau of Vital Statistics, the Florida Department of Children and Families, and the Social Security Administration’s State Data Exchange (SDX) for SSI beneficiaries. The FMMIS has an algorithm that prioritizes conflicting data from these sources.
The problem? The FMMIS would leave the date of death blank until the inconsistency was resolved because the state didn’t want to incorrectly deny benefits. Without a reliable and timely way to resolve the inconsistencies, the state continued to make payments for beneficiaries who had died.
Using the Social Security Death Master File
One approach to timely resolution is to verify death data with the Social Security Administration Death Master File. The Death Master File includes the name, social security number, date of birth and date of death for anyone with a social security number who has died.
For the Florida audit, the OIG used the Death Master File to resolve inconsistencies they found. The U.S. Government Accountability Office said that states should use the Death Master File to check regularly for deceased beneficiaries. Organizations would be wise to take this recommendation and do regular checks before an audit is needed, avoiding payment recovery, a damaged reputation and loss of the public’s trust.
To use the Death Master File, your organization must be certified by the Social Security Administration. Alternatively, organizations can contract with a company to work with the Death Master File on their behalf. Streamline Verify already has the software needed to search the raw data files, keeping costs down for clients while ensuring quality. Learn more about Streamline Verify’s Death Master File search services.
Even careful organizations can run into trouble with verifying the date of death in time to prevent incorrect payments for services. The Death Master File is a good way to verify date of death and avoid Florida’s mistake.
Check out this great resource for all questions on the Florida OIG Exclusion List.