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DoHS’s Bureau for Medical Services to Audit Medicaid Waiver Providers on ARPA Funding

CHARLESTON, W.Va. – The West Virginia Department of Human Services (DoHS), Bureau for Medical Services announced it will begin auditing Medicaid waiver providers on American Rescue Plan Act (APRA) funds that were received during the COVID-19 pandemic. Providers were notified of this intention by letter on Friday, April 12, 2024.

BMS will conduct the audit to ascertain how ARPA funds were spent, and to assure that 85% of those funds were provided directly to the direct care workforce in the form of wages or other incentives. The purpose of the audit is to monitor that ARPA funds have been spent properly and will be expended by March 31, 2025. Ultimately, any unused or misused funds will need to be returned. 

ARPA funds that equaled a 50% increase in rates during the pandemic were provided to waiver programs from April 1, 2021, through June 30, 2022, with the understanding that 85% of those funds were to be passed on to the Direct Care Workforce. The 85% pass-through must have benefited workers that provide or bill for the services that received the rate increases, but could also include workers that provide other Medicaid and state-funded Home and Community-Based Services (HCBS). Organizations who received those funds attested to their agreement with this requirement.

Close to $390 million worth of ARPA funds were distributed with $200 million directed to Intellectual/Developmental Disabilities Waiver (IDDW) providers, $116 million to Aged and Disabled Waiver (ADW) providers, $73 million to Personal Care providers, and $984,000 to Traumatic Brain Injury Waiver (TBIW) providers. These providers were notified they had until the March 2025 deadline to utilize the ARPA funds for direct care workers and other costs carrying them through Fiscal Year (FY) 2024 and the majority of FY2025. 

The timeline for these reviews and details for submitting supporting documentation will be shared with providers on or after May 15, 2024. Details regarding the final reconciliation process will also be provided at that time.

It is important to note that DoHS and BMS do not pay wages; they reimburse for services. Rates are paid to providers who then make business decisions about rates of pay and how to pay employees out of reimbursements.