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Medicaid managed care capitation and plan accountability (federal, MACPAC / CMS oversight)

57% of Medicaid Now Flows Through Plans States Can't Fully Audit

Summary

MACPAC's June 2026 Report to Congress finds managed care capitation grew from 23.5% to 57.3% of all Medicaid benefit spending between FY2010 and FY2023 -- almost $500 billion a year, with 74.1% of beneficiaries now in full-risk plans. Yet states' reporting of sanctions, corrective action plans, and liquidated damages against noncompliant plans is, in MACPAC's words, inconsistent and incomplete. No public database lets , states, or beneficiaries see which plans are actually held to account.

By Locusta · October 1, 2026

Medicaid now routes 57.3% of its benefit spending⧉ -- almost $500 billion a year -- through managed care plans in FY2023, up from 23.5% in FY2010. It is the report states can't fully audit: MACPAC's own review found plans' sanction records "inconsistent and incomplete."⧉

MACPAC's June 2026 chapter⧉ traces the shift: 74.1% of beneficiaries⧉ sat in full-risk plans in FY2023, up from 48.3% in FY2010. The federally mandated Managed Care Program Annual Report is supposed to log every sanction, corrective action plan, and liquidated damage against a noncompliant plan. It doesn't.

Capitation share of Medicaid benefit spending, FY2023
57.3%
up from 23.5% in FY2010 -- now almost $500 billion a year
Beneficiaries in full-risk managed care, FY2023
74.1%
up from 48.3% in FY2010
One state's MCPAR sanction total vs. its own dashboard
$2,500
the state's own site showed $33.8M in liquidated damages the MCPAR never captured
Capitation's share of Medicaid benefit spending doubled
Managed care capitation payments as a share of Medicaid benefit spending
FY2010
23.5%
FY2023
57.3%
Source: MACPAC, Report to Congress on Medicaid and , Ch. 3 (June 2026), p.67 -- MACPAC 2026b, 2013b
View data as table
Capitation grew from 23.5% of Medicaid benefit spending in FY2010 to 57.3% in FY2023 -- a 33.8-percentage-point swing that moved the majority of Medicaid's benefit dollars into full-risk plans.
FY201023.5%Under a quarter of Medicaid benefit spending
FY202357.3%Over half -- almost $500 billion in capitation payments

Across the 34 states⧉ that reported for 2023, MACPAC counted 737 accountability actions -- 359 corrective action plans, 187 liquidated damages, 106 civil penalties. But the counts don't reconcile. One state's report⧉ logged a single $2,500 sanction while its own website showed $33.8 million in liquidated damages the federal filing never captured. A separate study found about 25% of reported sanctions⧉ listed no remediation at all.

What 34 states reported doing about noncompliant plans
Accountability actions in performance year 2023 MCPARs, by type
Corrective action plans
359
Liquidated damages
187
Civil monetary penalties
106
Compliance letters
66
CAP + liquidated damages
19
Source: MACPAC, Report to Congress on Medicaid and , Ch. 3 (June 2026), Table 3-2 -- analysis of state-submitted MCPARs, performance year 2023 (34 states)
View data as table
The 34 reporting states logged 737 accountability actions against plans in performance year 2023 -- but MACPAC found the counts inconsistent and incomplete, with liquidated damages and informal interventions reported unevenly from state to state.
Corrective action plans35925 states; only 12 carried a financial penalty
Liquidated damages18710 states; average sanction $37,962
Civil monetary penalties10611 states; average sanction $402,833
Compliance letters668 states; no financial penalty attached
CAP + liquidated damages19Just 2 states reported this combined action

There is no publicly available database⧉ linking the data so , states, or beneficiaries can see which plans are actually held to account. MACPAC's fix is two recommendations: define what belongs in the report, and build the database that doesn't exist.

  • The money moved; the oversight didn't follow. Capitation went from 23.5% to 57.3% of Medicaid benefit spending in 13 years -- roughly 2.4x -- yet the federal report meant to track plan accountability is inconsistent and incomplete by MACPAC's own account.
  • The sanction ledger doesn't reconcile. One state's MCPAR captured a $2,500 sanction while its own dashboard showed $33.8 million in liquidated damages -- an understatement of more than 13,000-fold -- and about a quarter of reported sanctions list no remediation.
  • No one can see the whole picture. With 74.1% of beneficiaries in full-risk plans, there is still no public database linking the reported data -- so , states, and enrollees can't tell which plans are being held to account.

Figures are MACPAC's June 2026 Report to Congress, Chapter 3. Spending and enrollment shares span FY2010-FY2023; the sanction counts (Table 3-2) come from MACPAC's analysis of Managed Care Program Annual Reports for performance year 2023, covering 34 states. The state with the $33.8M discrepancy is unnamed here per MACPAC's own presentation.

Sources(2) ▾
  • Medicaid and CHIP Payment and Access Commission (MACPAC), State and Federal Tools for Ensuring Accountability of Medicaid Managed Care Plans (Report to Congress on Medicaid and CHIP, Ch. 3) (2026-06-01) — Chapter 3 of MACPAC's June 2026 Report to Congress. Traces managed care's rise (capitation from 23.5% to 57.3% of Medicaid benefit spending, FY2010-FY2023; enrollment 48.3% to 74.1%), analyzes the sanctions and corrective-action data states submit on the Managed Care Program Annual Report (MCPAR) for 34 states in performance year 2023 (Table 3-2), and documents that reporting is inconsistent and incomplete. Source of every load-bearing figure here. macpac.gov · original document
  • Medicaid and CHIP Payment and Access Commission (MACPAC), State and Federal Tools for Ensuring Accountability of Medicaid Managed Care Plans (publication landing page) (2026-06-01) — MACPAC's official landing page for the chapter, hosting the PDF and the two Commission recommendations (3.1: clarify MCPAR sanction reporting; 3.2: build a publicly available managed care performance database). Confirms authorship and publication date. macpac.gov · original document
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