The government paid $207 million in health insurance premiums for dead people. For the 18th time.
- $207.5Min Medicaid capitation payments made to managed care insurers on behalf of enrollees already confirmed dead — $138.6 millionof that was the federal taxpayer’s share — HHS OIG, December 2025
- 99 of 100sampled payments were confirmed unallowable in the audit’s statistical sample — HHS OIG sample review
- 18thseparate HHS OIG audit since 2016 finding the same zombie-enrollment payment deficiency — HHS OIG audit history
- $289Mcumulative total in unallowable deceased-enrollee premiums documented across all 18 audits — HHS OIG cumulative findings
- 0systematic fixes deployed — the SSA Death Master File, which would flag deceased enrollees, was available and cross-referenced by auditors but not by the agencies — SSA DMF; HHS OIG finding
For nine years, the federal government has been writing health insurance premium checks to managed care organizations for people who were already dead. The Social Security Administration maintains a database — the Death Master File — that records exactly when Americans die. Medicaid agencies had access to it. They did not use it.
In December 2025, the Department of Health and Human Services Office of Inspector General published its 18th separate audit since 2016 finding this identical deficiency. This time, the nationwide scope produced a staggering figure: $207.5 million in capitation payments — monthly per-enrollee premiums paid to Medicaid managed care insurers — sent for enrollees the SSA had already recorded as deceased. Of that total, $138.6 million was the federal share. Auditors sampled 100 payments; 99 were confirmed unallowable.
This is not a fraud case. No one is alleged to have stolen money. This is a systems failure — the kind of institutional inertia that the federal government has a well-documented gift for sustaining across administrations, across budgets, across audits, and across eighteen separate public reports telling the exact same story. The cumulative documented total since 2016 is now $289 million.
Capitation payments: the mechanics of paying per enrollee, alive or not.
Most Medicaid recipients are enrolled in managed care organizations — private insurers that contract with state Medicaid agencies to coordinate care. Rather than paying for each medical service individually, states pay the insurer a flat monthly premium for each enrolled member. This is called a capitation payment.
The system only works if enrollment rolls are accurate. When an enrollee dies, the state is supposed to terminate their coverage and stop sending premiums. The mechanism to do this exists: the Social Security Administration’s Death Master File is a regularly updated federal database that records deaths and is available to government agencies for exactly this kind of eligibility verification.
When agencies skip the crosscheck — or delay it — premiums keep flowing to the insurer long after the member is gone. The insurer collects a premium. No care is ever delivered. The federal and state governments have paid for coverage that existed only on paper, for a person who no longer exists. HHS OIG auditors identified these payments by doing the DMF crosscheck themselves. It is not a complicated procedure. It is, apparently, an optional one.
Eighteen audits. Nine years. No fix.
The HHS OIG has been issuing reports on deceased Medicaid enrollee capitation payments since 2016. Each report identifies the same root cause — states failing to cross-reference the SSA Death Master File in a timely manner. Each report makes the same recommendation — strengthen data matching and promptly terminate deceased enrollees. The Centers for Medicare and Medicaid Services has acknowledged the findings and issued corrective action plans. The payments have continued regardless.
“The same deficiency. The same recommendation. The same finding. Eighteen times.”
HHS OIG December 2025 audit — editorial summary of recurring finding
CMS provides guidance and oversight to state Medicaid agencies but does not directly manage enrollment databases — states run their own systems. State agencies are required to terminate coverage for deceased enrollees, but federal monitoring of compliance has been insufficient to produce the systematic fix that would end the problem.
The SSA Death Master File is a federal resource. It is updated regularly. It is available to government agencies at no meaningful cost. The technical fix — build a routine crosscheck into state enrollment systems — is not exotic engineering. The gap is institutional: no enforcement mechanism has forced states to implement it, and CMS has not made it a condition of participation that triggers real consequences when violated.
The officials responsible. Named.
The majority of this audit’s fiscal period — and of the entire 18-audit pattern — falls under the tenure of officials appointed by Democratic administrations. The Centers for Medicare and Medicaid Services operates under the Department of Health and Human Services and is the federal agency responsible for Medicaid oversight.
Neither Becerra nor Brooks-LaSure is alleged to have acted improperly. This is a bureaucratic failure — a failure of administrative will to enforce compliance on a known, documented, recurring deficiency. The question is not criminal. The question is managerial: why, after receiving eleven separate OIG audit findings during their combined tenure identifying this specific problem, did the corrective action plans not produce a fix?
CMS has consistently concurred with OIG recommendations. Concurrence is not implementation. Nine years of documented nonconcurrence-via-inaction is its own kind of answer.
Unallowable, improper, wasted. Not stolen.
Precision matters here. This audit documents improper payments— a federal accounting classification for payments made that were not legally authorized. The HHS OIG uses the term “unallowable.” Neither term implies criminal intent. The managed care organizations that received the premiums are not accused of fraud; they billed for enrolled members and received payment. The failure is upstream: enrollment rolls were not updated to reflect deaths.
The legal standard for improper payments under the Improper Payments Information Act and its successors includes any payment made in an incorrect amount, to an ineligible recipient, for an ineligible good or service, or without sufficient documentation to determine eligibility. Paying a monthly premium for a person who has died — and whose death was recorded in a federal database — satisfies the “ineligible recipient” standard clearly.
$207.5 million was paid in Medicaid premiums for dead people in a single nationwide audit. That is the federal and state governments combined sending premium checks — month after month — to insurance companies for enrollees whose deaths were recorded in a government database the agencies had access to.
Auditors did the crosscheck in weeks. Agencies have had nine years. The cumulative documented waste now stands at $289 million.
At some point, the 18th audit is not a warning. It is a verdict.