Department of Health and Human Services 
Office of Inspector General 
One Quarter of Medicaid 
Enrollees with HIV May Not 
Have Received Critical Services 
in 2021 
 
Ann Maxwell  
Deputy Inspector General 
   for Evaluation and Inspections 
August 2023, OEI-05-22-00240  U.S. Department of Health and Human Services 
O  ffice of Inspector General 
 
Data in Brief 
 
A  ugust 2023, OEI-05-22-00240 
 
 
One Quarter of Medicaid Enrollees with HIV May Not Have Received 
Critical Services in 2021 
Why OIG Did This Review 
Key Results 
Human Immunodeficiency Virus (HIV) is a virus that infects tens of 
We identified 265,493 enrollees  thousands of people in the United States (U.S.) each year.  While 
with HIV nationwide. Of these  HIV affects people from all walks of life; the epidemic continues to 
enrollees, in 2021:  disproportionately impact gay and bisexual men; transgender 
  72,391 enrollees (27 percent)  people; youth ages 13-24; and Black and Hispanic/Latino people.1  
may not have received one 
People diagnosed with HIV need regular care to improve their 
of three services critical for 
health outcomes, reduce HIV-related deaths, and ultimately 
achieving viral 
reduce new HIV transmissions. The ultimate goal of HIV care is 
suppressiona medical visit, 
to achieve viral suppressionmeaning that the amount of HIV in 
viral load test, or antiretroviral  the body is very low or undetectable in viral load tests.2  At the 
therapy (ART) prescription. 
individual level, viral suppression allows people with HIV to stay 
  11,316 enrollees (4 percent)  healthy, enjoy an improved quality of life, and live longer than if 
they were not virally suppressed.  At the population level, viral 
may not have received any 
suppression prevents transmission of HIV because people with 
of the three services.   This is 
HIV who reach and maintain viral suppression have effectively no 
particularly concerning 
risk of passing HIV to others.3, 4  Lack of viral suppression among 
because missing these 
people with HIV is often attributed to appropriate care not being 
services may mean that these  initiated or not being regularly received.5, 6  The Department of 
enrollees were at greater risk  Health and Human Services (HHS) recognizes the importance of 
of negative impacts on their  HIV care and developed guidelines on the clinical needs of people 
with HIV to achieve viral suppression.7 
overall health and greater risk 
of transmitting HIV.     The Medicaid program plays a critical role in ensuring that people 
  Enrollees with Medicaid only  with HIV receive care that can improve their ability to achieve and 
were more likely to have  maintain viral suppression.  In 2018, Medicaid covered an 
estimated 40 percent of all nonelderly people with HIV in the U.S.8 
not received critical services 
People with HIV who are covered by Medicaid also tend be part 
compared to dual-eligible 
of populations disproportionately impacted by HIV overall, 
enrollees. 
including Black and Hispanic/Latino people.9 
  All States had enrollees with 
How OIG Did This Review 
HIV who may not have 
We reviewed the extent to which the Medicaid enrollees who had 
received critical services, but 
HIV diagnoses in their Medicaid or Medicare claims data had 
State rates varied widely. 
evidence of critical services in 2021.  This review included both 
enrollees with Medicaid only and those who were enrolled in both 
 
Medicaid and Medicare (dual-eligible enrollees).  We determined 
  whether these enrollees had evidence in their Medicaid and Medicare claims data of three medical 
services that are critical for all people with HIV according to HHS guidelines: (1) medical visits (in-person 
or telehealth), (2) viral load tests, and (3) antiretroviral therapy (ART) prescriptions.  Because inaccuracies 
in claims data could impact our results, we reviewed the completeness of Medicaid claims data for 
these services and removed States from our analysis where we had concerns.  
Why This Matters 
This data brief provides insight into the extent to which people with HIV enrolled in Medicaid had 
evidence of receiving services that are critical for achieving viral suppression, which is vital to the 
overall health of people with HIV and for the prevention of HIV transmission.  Medicaid enrollees 
with HIV may have gaps in care for various reasons.  For example, the COVID-19 public health 
emergency had a widespread impact on the health care system, including recommendations for certain 
patients in seeking care as well as patients access to services.  Our results provide a foundation for 
understanding the scale of potential gaps in care and where further action may be needed to ensure 
that Medicaid enrollees with HIV are receiving critical services to increase their likelihood of viral 
suppression.  Future OIG work will shed light on specific challenges and strategies that impact Medicaid 
programs abilities to ensure HIV care.  
   
   
Primer on HHS Guidelines on HIV Care 
HHS developed clinical guidelines that detail select aspects of medical care that 
people with HIV need to help them achieve and maintain viral suppression.10  HHS 
recommends11 that all people with HIV: 
 
Attend regular medical visits with HIV providers to manage care. 
Monitor their viral load, or the amount of HIV in the body, to determine HIV 
progression and if antiretroviral therapy (ART) is successfully reducing HIV in 
 
the body to achieve and/or maintain viral suppression. 
  Initiate and adhere to ART, medicine prescribed by health care providers to 
reduce the amount of HIV in the body.12 
HHS guidelines do not recommend specific frequencies for these services that should 
apply to all people with HIV.  For example, HHS notes that there are multiple valid 
ways to assess whether people with HIV are attending regular medical visitssuch as 
looking for at least two visits that are at least 90 days apart over 1 year, or looking for 
at least one visit at least every 6 months over a 2-year period.13  The guidelines also 
note that appropriate service frequencies can depend on individual care needs.14, 15 
In this review, we used a conservative approach to assess whether Medicaid enrollees 
with HIV had evidence of services that aligned with these guidelines.  Specifically, we 
determined whether enrollees with HIV had at least one medical visit (in-person or 
telehealth), viral load test, and/or ART prescription filled at any point in 2021.  See 
Methodology for additional details. 
 
 
 
 
 
 
 
 
 
 
 
 
 
  FINDINGS 
In this data brief, Medicaid enrollees with HIV refers to Medicaid enrollees with HIV-
related diagnosis codes in their Medicaid or Medicare claims from 2019 or 2020, and 
evidence of critical services refers to the presence of at least one Medicaid or 
Medicare claim record for a medical visit (in-person or telehealth), viral load test, or 
antiretroviral therapy (ART) prescription filled in 2021.  This review included Medicaid 
fee-for-service and Medicaid managed care plan (MCP) claims, as well as Medicare 
fee-for-service and Medicare Advantage plan claims for dual-eligible enrollees.  See 
Methodology for additional details. 
About one in four Medicaid enrollees with HIV, nationwide, did 
not have evidence of one or more critical services in 2021, with 
the absence of viral load tests being the most common gap in 
care. 
In 2021, 72,391 of the 265,493 Medicaid enrollees with HIV did not have evidence of 
at least one of three services through Medicaid or Medicare in 2021a medical visit, 
a viral load test, and/or a filled antiretroviral therapy (ART) prescription
recommended by HHS for all people with HIV. 
Exhibit 1.  Of the three critical services, enrollees were most frequently 
missing viral load tests in 2021. 
 
Source: OIG analysis of Medicaid and Medicare claims among enrollees with HIV, 2021. 
   
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Findings | 1   
 
Of the 265,493 enrollees with HIV, 23 percent (61,854 enrollees) did not 
have evidence of at least one viral load test in 2021, more than for the 
  other two critical services.   
 
Without viral load tests,  
  Medical providers do not know patients viral load levels to 
 
see how well treatment is working and to monitor HIV 
infection.16   
    CMS and State Medicaid programs cannot determine viral 
load suppression rates of enrollees with HIV to gauge if the 
   program is meeting their care needs.17, 18   
  National, State and local public health officials cannot track 
viral suppression of residents and identify where 
improvements are needed.19  
Over 11,000 Medicaid enrollees with HIV did not have evidence 
of any of the three services in 2021, which may mean that they 
were at greater risk of negative health impacts and HIV 
transmission. 
In 2021, 11,316 enrollees, or 4 percent of the 265,493 enrollees in Medicaid with HIV, 
did not have evidence of any of the following: at least one medical visit, viral load 
test, or ART prescription filled through Medicaid or Medicare in 2021.   
Enrollees without evidence of any of these services critical for people with HIV are 
particularly concerning.  Without critical services, enrollees with HIV may not be able 
to achieve and maintain viral suppression.20  If not virally suppressed, people with 
HIV have levels of HIV in their body that negatively impact their health and put them 
at risk for transmitting HIV to HIV-negative sexual partners.21 
   
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Findings | 2  Enrollees with HIV in Medicaid only were more frequently 
missing evidence of critical services than dual-eligible enrollees 
in 2021.   
Exhibit 2: Enrollees with Medicaid only were more likely to be missing one or 
more services compared to dual-eligible enrollees.   
Source: OIG analysis of Medicaid and Medicare claims among enrollees with HIV, 2021. 
 
Enrollees with Medicaid only were also three times more likely to not have 
evidence of any of the three critical services compared to dual-eligible 
enrollees6 percent of 142,307 enrollees compared to 2 percent of 123,186 
enrollees respectively.   
 
Factors related to programmatic differences between Medicaid and Medicare may 
contribute to the differences in evidence of critical services between enrollees in 
Medicaid only and dual-eligible enrollees, for whom Medicare provides primary 
coverage for most care,22 including: 
  Higher Medicare fee-for-service payment rates for physician services 
compared to Medicaid fee-for-service, which may impact access to care as 
providers are more likely to accept new patients with Medicare;23, 24 and 
  Long-term adherence to care among older adults who have lived with HIV 
since younger ages and are eligible for Medicare based on age.25 
 
Differences in data quality and completeness between Medicaid and Medicare claims 
data may also contribute to differences in evidence of critical services between 
enrollees in Medicaid only and the dually enrolled who received services paid by 
Medicare.  Specifically, OIG has raised concerns about the quality and completeness 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Findings | 3  of national Medicaid data available through the Transformed Medicaid Statistical 
Information System (T-MSIS).  However, the Centers for Medicare and Medicaid 
Services (CMS) and State efforts have led to ongoing improvements in T-MSIS data.26, 
27  We conducted checks to assess and account for the quality and completeness of T-
MSIS data used in our study.  Specifically, we reviewed the completeness of codes 
needed for our analysis by State and excluded States with high percentages of 
missing codes to minimize the impact of poor data quality on our resultssee 
Methodology for additional details. 
   
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Findings | 4  All States in this review had enrollees with HIV who did not have 
evidence of one or more critical services in 2021, but State rates 
varied widely. 
All States included in this review, including the District of Columbia, had enrollees in 
Medicaid only and dual-eligible enrollees without evidence of one or more of the 
three critical services in 2021.  See Appendix A and Appendix B for more details on 
evidence of critical services for individual States.  
The proportion of Medicaid-only enrollees missing one or more services varied 
across States, from 16 percent to 87 percent.  We identified four States as outliers on 
the basis of proportions of Medicaid-only enrollees who did not have evidence of one 
of the three critical services that were significantly higher than for other States: 
Arizona (59 percent), Arkansas (60 percent), the District of Columbia (61 percent), and 
Utah (87 percent).  
Exhibit 3: Many (20 of 47 States) State rates for Medicaid-only enrollees 
without evidence of one or more services fell between 24% and 35%. 
 
Source: OIG analysis of Medicaid claims among Medicaid enrollees with HIV, 2021. 
   
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Findings | 5  The proportion of dual-eligible enrollees who did not have evidence of one or more 
services also varied across States, from 9 percent to 53 percent.  We identified three 
States as outliers on the basis of proportions of dual-eligible enrollees who did not 
have evidence of one of the three critical services that were significantly higher than 
for other States: Alaska (38 percent), West Virginia (47 percent), and South Dakota (53 
percent).   
Exhibit 4: Half (26 of 51 States) of State rates for dual-eligible enrollees 
without evidence of one or more services fell between 17% and 22%.  
 
Source: OIG analysis of Medicaid and Medicare claims among dual-eligible enrollees with HIV, 2021. 
 
While these State-specific rates provide a means of comparison across States that 
account for population differences, they can hide differences in the actual number of 
enrollees with HIV who did not have evidence of services across States.  For example, 
South Dakota had a higher rate (34 percent) of Medicaid-only enrollees without 
evidence of one or more critical services than Louisiana (23 percent); however, South 
Dakota had far fewer actual Medicaid-only enrollees (25) without evidence of critical 
services than did Louisiana (1,663). 
Data quality and completeness may contribute to differences in evidence of critical 
services for Medicaid enrollees with HIV across States.  As previously discussed, OIG 
has raised concerns about T-MSIS data quality and completeness, although 
improvements have been made over time.  Even with the data quality checks we 
conducted for this study, State differences in T-MSIS data quality and completeness 
may impact our results.  
The types of challenges States face in improving HIV care for their enrollees, as well as 
the most effective strategies for doing so, may also depend on the specific 
characteristics of each States Medicaid program and enrollee population.  State 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Findings | 6  Medicaid programs vary significantly in size (e.g., number of enrollees, staff, and 
resources) and structure (e.g., use of managed care, eligibility for Medicaid, and other 
policy options), and this variation could impact the feasibility or value of different 
approaches across States.28, 29  For example, States that have very few enrollees with 
HIV missing critical services may be able to conduct individual outreach, while this 
may not be practical in States with hundreds or thousands of enrollees missing critical 
services.  Our future work will dig deeper into the specific challenges States face in 
ensuring care for enrollees with HIV and strategies they use to try to overcome those 
challenges. 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Findings | 7  CONCLUSION 
Our finding in this data briefthat in 2021, over a quarter of Medicaid enrollees with 
HIV did not have evidence in their claims data of receiving one or more critical 
servicesdemonstrates that further action is needed to ensure that enrollees are 
receiving appropriate HIV care.  Of particular concern, over 11,000 enrollees did not 
have evidence of receiving any of the three services we reviewed.  These services are 
recommended by HHS for all people with HIV, and are vital to their overall health as 
well as the prevention of HIV transmission within the general population. 
Future OIG work will examine efforts by State Medicaid agencies, Medicaid managed 
care plans, and CMS to ensure that Medicaid enrollees with HIV receive critical 
services.  That work will cover strategies used and challenges faced, and will focus on 
actionable steps that these entities can take to improve HIV care in Medicaid.  
CMS and States may wish to consider taking more immediate steps to address the 
potential gaps in care that we found.  For example, States may wish to follow-up with 
Medicaid-only enrollees with HIV who do not have evidence of critical services, or 
with their providers, to ensure that these enrollees can readily access all necessary 
care.  Similarly, CMS may wish to follow-up with dual-eligible enrollees with HIV who 
do not have evidence of critical services, given Medicares role as the primary payer 
for their services. 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Conclusion | 8  METHODOLOGY 
We based this review on an analysis of data from (1) the Transformed Medicaid 
Statistical Information System (T-MSIS)the national Medicaid claims and encounter 
database for all 50 States and D.C., and (2) Medicare National Claims History (NCH) 
files, Medicare Encounter data, Medicare Prescription Drug Event (PDE) data, and the 
Medicare Enrollment DataBase (EDB).30, 31, 32, 33  This review includes services and 
prescriptions that Medicaid enrollees received through Medicaid (including the 
Childrens Health Insurance Program (CHIP)) and Medicare (if enrolled in both 
programs).   
T-MSIS Data Quality 
Because of ongoing concerns with the quality of T-MSIS data, we assessed the 
completeness of key variables used in our analysis to ensure that incomplete claims 
did not significantly limit our ability to identify evidence of critical HIV services for 
Medicaid-only enrollees.    
For the viral load tests and medical visit measures, we first identified the claim types 
most frequently associated with procedure codes for these two services among all 
2021 claims for enrollees with HIV.  We found that medical visits were almost always 
associated with professional (i.e., physician office) claims, whereas viral load tests were 
associated with both professional claims and hospital outpatient claims.  We then 
reviewed the completeness of the procedure code variable for both professional and 
hospital outpatient claims in each State.  For the ART measure, we reviewed the 
completeness of the National Drug Code (NDC) variable (used to identify ART 
prescriptions) for RX claims in each State.34   
We removed States from measures in our analysis if the completeness of the key 
variable for associated claims fell below thresholds that CMS uses in the Data Quality 
(DQ) Atlas to identify high concern or unusable data for similar claim types.35  On 
the basis of these criteria, we excluded four States (Illinois, Maryland, New York, and 
Vermont) from the viral load test measure in our analysis due to high rates of missing 
procedure codes in their hospital outpatient claims.  We did not exclude any States 
from the ART or medical visit measures in our analysis.   
We further excluded Medicaid-only enrollees in these four States from our national 
analyses across all three measures.  Dual-eligible enrollees in these States were 
included in the national analyses because Medicare provides primary coverage for 
most care.36  Though they are not included in our national analyses, we report results 
for the ART and medical visit measures for Medicaid-only enrollees in these States in 
Appendix B.  
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Methodology | 9  Identifying Enrollees with HIV 
To identify enrollees with HIV, we reviewed 2019 and 2020 Medicaid and Medicare 
claims data for enrollees with HIV-related diagnosis codes and Diagnosis Related 
Group (DRG) codes as defined in CMSs Chronic Conditions Data Warehouse (CCW) 
algorithm.37  We made minor modifications to the algorithm by adding codes to 
include pregnant people with HIV and excluding obsolete codes.   
We looked for HIV diagnoses in 2019 and 2020, instead of 2021, so that our analysis 
of enrollees with documented HIV diagnosis did not include people who were newly 
diagnosed with HIV in the same year that we looked for services.  Newly diagnosed 
people with Medicaid may have what appear to be gaps in their care in the year of 
diagnosis that are related to when they were diagnosed (i.e., earlier in the year versus 
later) and/or the onset of HIV treatment (e.g., a delay in starting ART to allow a person 
with HIV and their provider to assess and address potential barriers to treatment 
adherence).38  
For enrollees identified with HIV, we used 2021 Medicaid enrollment data to 
determine whether anyone was not continuously enrolled in Medicaid for all 365 days 
of 2021.  We excluded enrollees who were not continuously enrolled from our analysis 
to limit the possibility that evidence of missing care was due to enrollment gaps.  In 
2021, most enrollees were continuously enrolled, as coverage for Medicaid coverage 
was protected under the COVID-19 public health emergency.39 
Gaps in Critical Services Analysis 
For each person with HIV, we used their 2021 Medicaid FFS and managed care plan 
(MCP) claims (and Medicare FFS and Medicare Advantage plan claims, if they were 
enrolled in Medicaid and Medicare) to find evidence of the three critical services.  We 
adapted and operationalized HHS care guidelines in claims data (e.g., codes, 
timeframe, scope) to meet our study objective.  To do so, we consulted with Health 
Resources and Services Administration (HRSA) experts to learn about specific code 
sets and expectations for frequencies of services based on their experiences 
operationalizing measurement of these three critical services as part of their Ryan 
White HIV/AIDS Program performance measures.40  From this learning, we used a 
conservative approach to our review by searching for evidence of just one instance of 
each of the three critical services at any point in 2021.  Specifically, we reviewed 2021 
claims data for:  
  At least one claim with a code indicating an outpatient medical visit (in-person 
or telehealth) for evaluation and management; 
  At least one claim with a procedure code for a quantitative viral load test; and 
  At least one claim with a National Drug Code (NDC) associated with an HIV 
antiretroviral therapy (ART) prescription that was filled. 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Methodology | 10  We then calculated the proportion of enrollees who did not have evidence of all three 
critical services nationally, by type of enrollment (Medicaid only or dual-eligible), and 
by State.   
To determine national results, we summed the number of enrollees who did not have 
evidence of at least one of the three critical services in 2021 and divided it by the total 
number of enrollees with HIV.  We also summed the number of enrollees who did not 
have evidence of any of the three critical services in 2021 and divided by the total 
number of enrollees with HIV.  
To determine results by type of enrollment, we calculated the proportion of enrollees 
who did not have evidence of all three critical services by Medicaid and Medicare 
enrollment.  Specifically, we used Medicaid and Medicare enrollment files to 
determine if enrollees with HIV were enrolled in Medicaid only or dual-eligible in 
2021.  Then, we summed the total number of enrollees with HIV with Medicaid only 
who did not have evidence of at least one of the three services in 2021 and divided it 
by the total number of enrollees with HIV who were enrolled in Medicaid only.  
Further, we summed the total number of these Medicaid-only enrollees who did not 
have evidence of any of the three services in 2021 and divided by the total number of 
enrollees with HIV who were enrolled in Medicaid only.   
We conducted similar calculations for dual-eligible enrollees.  We summed the total 
number of dual-eligible enrollees who did not have evidence of at least one of the 
three services in 2021 and divided it by the total number of dual-eligible enrollees 
with HIV.  Further, we summed the total number of these dual-eligible enrollees who 
did not have evidence of any of the three services in 2021 and divided by the total 
number of dual-eligible enrollees with HIV.   
To determine results by State, we calculated the proportion of enrollees with HIV who 
did not have evidence of each of the three services and evidence of all three critical 
services across States.  We conducted this analysis separately for enrollees with 
Medicaid only and dual-eligible enrollees.  To do so, we identified the States in which 
enrollees with HIV were enrolled and received services in 2021.  We excluded 
enrollees who were enrolled or received services in multiple States from this State-
level analysis.  Then we summed the number of enrollees in each State who did not 
have evidence of at least one of the three critical services in 2021 and divided by the 
total number of enrollees with HIV in the State.  Similarly, we summed the number of 
enrollees in each State who did not have evidence of any of the three critical services 
in 2021 and divided by the total number of enrollees with HIV in the State.  See 
Appendix A.  Finally, we summed the number of enrollees with Medicaid only and 
dual-eligible enrollees in each State who did not have evidence of each service in 
2021 and divided by the total number of Medicaid-only and dual-eligible enrollees 
with HIV in the State.  See Appendix B.  We also used the Tukey method to identify 
outliers in States proportion of enrollees with HIV who (1) were missing one or more 
of the critical services or did not have evidence of all three critical services (see 
Appendix A) and (2) did not have evidence of each of the three individual services 
(see Appendix B).41 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Methodology | 11  Limitations 
Our review focuses on three services critical for all people with HIV; however, 
individual care needs could warrant different recommendations.  For example, 
providers may delay ART prescriptions briefly for some people with HIV with specific 
infections.42  Also, Federal guidance in 2021 on considerations for COVID-19 advised 
people with HIV to weigh the risks and benefits of attending versus not attending in-
person HIV-related clinic appointments.43  However, our analysis does include medical 
visits provided via telehealth, which was used to help continue care during the 
COVID-19 public health emergency.44  
Further, this analysis is based on Medicaid and Medicare claims data available; it is not 
based on a review of medical records.  Any inaccuracies in claims data could impact 
our analysis.  For example, some claims may have incorrectly included HIV-related 
diagnosis codes, leading us to determine that the enrollee had HIV when they, in fact, 
did not.  Also, if service claims were missing, incorrect, or billed through bundled 
payments, we could have underestimated actual evidence of critical services.  Further, 
because OIG has raised concerns about T-MSIS data quality and completeness in the 
past, we reviewed our Medicaid data for completeness and made some exclusions to 
minimize the impact of incomplete data on our results.  
Finally, this review only covers services paid for by Medicare or Medicaid.  It does not 
capture any services and prescriptions enrollees received that were not paid for by 
Medicaid or Medicare, such as those covered by TRICARE or paid for out of pocket.  
Enrollees who received critical services that were not paid for by Medicaid or 
Medicare, including Medicaid-only enrollees with limited benefits, may have what 
appear to be gaps in their services.   
Standards 
We conducted this study in accordance with the Quality Standards for Inspection and 
Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.  
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Methodology | 12  APPENDIX A 
Enrollees without Evidence of Services by State 
       
State  Enrollees with HIV  Missing One or More Services  Missing All Three Services 
  Medicaid Only  Dual-Eligible   Medicaid Only  Dual-Eligible  Medicaid Only  Dual-Eligible 
  n  n  n  %  n  %  n  %  n  % 
Alabama  1289  1820  292  23%  327  18%  70  5%  33  2% 
Alaska  226  98  65  29%  37  38%  14  6%  -  - 
Arizona  3994  1738  2341  59%  340  20%  329  8%  30  2% 
Arkansas  745  716  450  60%  195  27%  225  30%  21  3% 
California  28596  13792  8514  30%  2997  22%  2026  7%  242  2% 
Colorado  2602  1014  691  27%  208  21%  199  8%  22  2% 
Connecticut  3085  1939  614  20%  266  14%  125  4%  16  1% 
Delaware  831  543  188  23%  105  19%  45  5%  15  3% 
District of 
4134  1952  2528  61%  415  21%  269  6%  46  2% 
Columbia 
Florida  11806  16655  4929  42%  3389  20%  987  8%  374  2% 
Georgia  4407  5305  1915  43%  1358  26%  280  6%  104  2% 
Hawaii  445  300  126  28%  28  9%  32  8%  -  - 
Idaho  190  153  30  16%  26  17%  -  -  -  - 
Illinois  NR  3758  NR  NR  1023  27%  NR  NR  106  3% 
Indiana  2332  1541  660  28%  275  18%  139  6%  23  1% 
Iowa  707  393  131  19%  44  11%  41  6%  -  - 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Appendix A | 13  Kansas  177  334  33  19%  48  14%  -  -  -  - 
Kentucky  1978  789  536  27%  152  19%  119  6%  16  2% 
Louisiana  7116  3364  1663  23%  589  18%  464  7%  59  2% 
Maine  400  400  80  20%  42  11%  18  5%  -  - 
Maryland  NR  3359  NR  NR  700  21%  NR  NR  36  1% 
Massachusetts  5810  4220  2409  41%  730  17%  477  8%  47  1% 
Michigan  5120  2239  1645  32%  565  25%  275  7%  46  2% 
Minnesota  1933  884  415  21%  117  13%  66  3%  16  2% 
Mississippi  1050  1502  274  26%  256  17%  53  5%  21  1% 
Missouri  1061  1886  227  21%  276  15%  50  5%  26  1% 
Montana  166  81  70  42%  13  16%  -  -  -  - 
Nebraska  174  202  28  16%  35  17%  -  -  -  - 
Nevada  2298  721  903  39%  188  26%  178  8%  22  3% 
New Hampshire  219  134  39  18%  26  19%  -  -  -  - 
New Jersey  6118  2824  1657  27%  616  22%  218  4%  57  2% 
New Mexico  1145  550  357  31%  83  15%  81  7%  13  2% 
New York  NR  16266  NR  NR  3926  24%  NR  NR  207  1% 
North Carolina  3420  4352  1248  36%  632  15%  301  9%  58  1% 
North Dakota  73  39  17  23%  -  -  -  -  -  - 
Ohio  6517  2808  1815  28%  592  21%  316  5%  48  2% 
Oklahoma  464  679  139  30%  143  21%  41  9%  18  3% 
Oregon  1772  1004  495  28%  170  17%  91  5%  -  - 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Appendix A | 14  Pennsylvania  10045  5240  3040  30%  934  18%  359  4%  59  1% 
Rhode Island  681  411  137  20%  58  14%  22  3%  -  - 
South Carolina  1776  2350  448  25%  283  12%  147  3%  22  1% 
South Dakota  73  87  25  34%  46  53%  -  -  -  - 
Tennessee  1925  2184  567  29%  452  21%  89  5%  65  3% 
Texas  5810  7437  1894  33%  1665  22%  461  8%  170  2% 
Utah  396  208  343  87%  40  19%  29  6%  -  - 
Vermont  NR  156  NR  NR  31  20%  NR  NR  -  - 
Virginia  4184  2126  1630  39%  423  20%  222  5%  36  2% 
Washington  2973  1403  778  26%  227  16%  152  5%  28  2% 
West Virginia  528  295  283  54%  138  47%  34  6%  11  4% 
Wisconsin  1494  893  362  24%  114  13%  87  6%  -  - 
Wyoming  22  42  -  -  -  -  -           -  -  - 
NR Not Reported due to concerns with T-MSIS data quality.  
Shaded cells are rates that we identified as outliers compared to those of other States.   
-Number of enrollees was 10 or under and therefore results not reported to protect enrollee privacy.45 
 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Appendix A | 15  APPENDIX B 
Enrollees without Evidence of Each Service by State 
         
State  Enrollees with HIV  Missing Medical Visits  Missing Viral Load Tests  Missing ART Prescription Filled 
  Medicaid Only  Dual-Eligible   Medicaid Only  Dual-Eligible  Medicaid Only  Dual-Eligible  Medicaid Only  Dual-Eligible 
  n  n  n  %  n  %  n  %  n  %  n  %  n  % 
Alabama  1289  1820  118  9%  53  3%  240  19%  294  16%  195  15%  166  9% 
Alaska  226  98  19  8%  -  -  64  28%  35  36%  23  10%  -  - 
Arizona  3994  1738  871  22%  65  4%  2153  54%  307  18%  578  15%  141  8% 
Arkansas  745  716  357  48%  53  7%  343  46%  170  24%  267  36%  87  12% 
California  28596  13792  4096  14%  1143  8%  7410  26%  2215  16%  3596  13%  1033  8% 
Colorado  2602  1014  337  13%  43  4%  614  24%  185  18%  365  14%  78  8% 
Connecticut  3085  1939  239  8%  59  3%  510  17%  207  11%  284  9%  112  6% 
Delaware  831  543  84  10%  23  4%  161  19%  98  18%  104  13%  51  9% 
District of 
4134  1952  1219  30%  147  8%  2101  51%  341  18%  419  10%  174  9% 
Columbia 
Florida  11806  16655  2208  19%  790  5%  4222  36%  3052  18%  1821  15%  1514  9% 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Appendix B | 16  Georgia  4407  5305  483  11%  238  5%  1797  41%  1266  24%  598  14%  434  8% 
Hawaii  445  300  55  12%  -  -  91  20%  22  7%  73  16%  -  - 
Idaho  190  153  -  -  -  -  29  15%  23  15%  -  -  12  8% 
Illinois  8738  3758  1600  18%  252  7%  NR  NR  908  24%  1672  19%  529  14% 
Indiana  2332  1541  256  11%  41  3%  578  25%  257  17%  292  13%  120  8% 
Iowa  707  393  58  8%  -  -  116  16%  37  9%  81  12%  20  5% 
Kansas  177  334  12  7%  -  -  29  16%  42  13%  17  10%  22  7% 
Kentucky  1978  789  210  11%  36  5%  456  23%  130  17%  282  14%  70  9% 
Louisiana  7116  3364  813  11%  145  4%  1438  20%  537  16%  860  12%  265  8% 
Maine  400  400  27  7%  -  -  75  19%  37  9%  37  9%  18  5% 
Maryland  7707  3359  1048  14%  132  4%  NR  NR  610  18%  743  10%  284  9% 
Massachusetts  5810  4220  1230  21%  150  4%  1472  25%  647  15%  1299  22%  205  5% 
Michigan  5120  2239  604  12%  95  4%  1484  29%  532  24%  604  12%  257  12% 
Minnesota  1933  884  156  8%  27  3%  369  19%  107  12%  151  8%  49  6% 
Mississippi  1050  1502  75  7%  48  3%  250  24%  234  16%  142  14%  106  7% 
Missouri  1061  1886  94  9%  57  3%  200  19%  250  13%  116  11%  145  8% 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Appendix B | 17  Montana  166  81  17  10%  -  -  68  41%  12  15%  22  13%  -  - 
Nebraska  174  202  -  -  -  -  27  16%  34  17%  13  8%  20  10% 
Nevada  2298  721  371  16%  54  8%  777  34%  164  23%  404  18%  88  12% 
New Hampshire  219  134  -  -  -  -  34  16%  24  18%  19  9%  15  11% 
New Jersey  6118  2824  516  8%  136  5%  1454  24%  557  20%  759  12%  324  12% 
New Mexico  1145  550  170  15%  24  4%  324  28%  76  14%  154  13%  35  6% 
New York  34644  16266  5902  17%  1095  7%  NR  NR  3296  20%  3616  10%  1203  7% 
North Carolina  3420  4352  505  15%  126  3%  798  23%  567  13%  855  25%  302  7% 
North Dakota  73  39  -  -  -  -  17  23%  -  -  -  -  -  - 
Ohio  6517  2808  648  10%  114  4%  1648  25%  539  19%  749  12%  243  9% 
Oklahoma  464  679  69  15%  34  5%  119  26%  124  18%  76  16%  80  12% 
Oregon  1772  1004  192  11%  37  4%  445  25%  147  15%  182  10%  57  6% 
Pennsylvania  10045  5240  1192  12%  194  4%  2485  25%  821  16%  820  8%  384  7% 
Rhode Island  681  411  41  6%  15  4%  120  18%  47  11%  57  8%  29  7% 
South Carolina  1776  2350  225   13%  53  2%  362  20%  243  10%  275  16%  142  6% 
South Dakota  73  87  -  -  -  -  24  33%  45  52%  20  27%  45  52% 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Appendix B | 18  Tennessee  1925  2184  160  8%  109  5%  485  25%  401  18%  297  15%  249  11% 
Texas  5810  7437  873  15%  437  6%  1595  28%  1463  20%  1036  18%  730  10% 
Utah  396  208  35  9%  -  -  88  22%  34  16%  338  85%  22  11% 
Vermont  156  156  17  11%  -  -  NR  NR  27  17%  24  15%  15  10% 
Virginia  4184  2126  416  10%  78  4%  1507  36%  382  18%  476  11%  180  9% 
Washington  2973  1403  305  10%  64  5%  691  23%  203  15%  293  10%  91  7% 
West Virginia  528  295  55  10%  15  5%  268  51%  135  46%  77  15%  44  15% 
Wisconsin  1494  893  156  10%  15  2%  312  21%  104  12%  156  10%  45  5% 
Wyoming  22  42  -  -  -  -  -  -  -  -  -  -  -  - 
NR Not Reported due to concerns with T-MSIS data quality.  
Shaded cells are rates that we identified as outliers compared to those of other States.   
-Number of enrollees was 10 or under and therefore results not reported to protect enrollee privacy.46 
 
 
 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Appendix B | 19  ACKNOWLEDGMENTS AND CONTACT 
Acknowledgments 
Lisa Minich and Danielle Noriega served as the team leaders for this study, and 
Jonathan Carroll served as lead analyst.  Others in the Office of Evaluation and 
Inspections who supported this study include Rebecca Gorges and Kayla Phelps.  
Office of Evaluation and Inspections headquarters staff who provided support include 
Kevin Manley, Lyndsay Hopper, and Sara Swisher.  
This report was prepared under the direction of Laura Kordish, Regional Inspector 
General for Evaluation and Inspections in the Chicago regional office; Adam Freeman, 
Deputy Regional Inspector General; and Hilary Slover, Assistant Regional Inspector 
General. 
Contact 
To obtain additional information concerning this report, contact the Office of Public 
Affairs at Public.Affairs@oig.hhs.gov.  OIG reports and other information can be found 
on the OIG website at oig.hhs.gov. 
Office of Inspector General 
U.S. Department of Health and Human Services 
330 Independence Avenue, SW 
Washington, DC 20201 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Acknowledgments and Contact | 20  ENDNOTES 
 
1 CDC, HIV by Group, 2022.  CDC identified certain groups that are at higher risk for HIV including intersectionality of 
demographics.  Accessed at https://www.cdc.gov/hiv/group/index.html#print on February 3, 2023.   
2 CDC, Understanding the HIV Care Continuum, 2019.  See What is the HIV Care Continuum?  Accessed at 
https://www.cdc.gov/hiv/pdf/library/factsheets/cdc-hiv-care-continuum.pdf on May 15, 2023.  
3 Ibid. 
4 CDC, HIV Treatment as Prevention, 2023.  Accessed at 
https://www.cdc.gov/hiv/risk/art/index.html#:~:text=If%20taken%20as%20prescribed%2C%20HIV,HIV%20per%20milliliter%20
of%20blood on August 11, 2023. 
5 Hughes, For adults with HIV, lack of viral suppression linked to lower care engagement and increased barriers to care, 2021.  
Accessed at https://www.wolterskluwer.com/en/news/for-adults-with-hiv-lack-of-viral-suppression-linked-to-lower-care-
engagement on May 3, 2023.  Resource based on Dasgupta et al., Barriers to HIV Care by Viral Suppression Status Among US 
Adults with HIV: Findings from the Centers for Disease Control and Prevention Medical Monitoring Project, 2021.  Accessed at 
https://journals.lww.com/janac/Citation/2021/10000/Barriers_to_HIV_Care_by_Viral_Suppression_Status.5.aspx on May 3, 2023.  
6 Only 66 percent of people diagnosed with HIV are virally suppressed due to poor adherence to the continuum of care and to 
ART.  See Introduction on page 387/L-2 of HHS, Guidelines for the Use of Antiretroviral Agents in Adults and Adolescents with 
HIV, 2022.  Accessed at https://clinicalinfo.hiv.gov/sites/default/files/guidelines/documents/adult-adolescent-arv/guidelines-
adult-adolescent-arv.pdf on May 3, 2023.  
7 HHS, Guidelines for the Use of Antiretroviral Agents in Adults and Adolescents with HIV, 2022.  See page 15/A1 for overview of 
the guidelines.  Accessed at https://clinicalinfo.hiv.gov/sites/default/files/guidelines/documents/adult-adolescent-
arv/guidelines-adult-adolescent-arv.pdf on May 3, 2023. 
8 KFF, Medicaid and People with HIV, 2023.  Accessed at https://www.kff.org/hivaids/fact-sheet/medicaid-and-hiv/#footnote-
432737-5 on May 26, 2021. 
9 KFF, Insurance Coverage and Viral Suppression Among People with HIV, 2018.  See Figure 5.  Accessed at 
https://www.kff.org/hivaids/issue-brief/insurance-coverage-and-viral-suppression-among-people-with-hiv-2018/ on May 3, 
2023. 
10 HHS, Guidelines for the Use of Antiretroviral Agents in Adults and Adolescents with HIV, 2022.  See page A1 for overview of 
the guidelines.  Accessed at https://clinicalinfo.hiv.gov/sites/default/files/guidelines/documents/adult-adolescent-
arv/guidelines-adult-adolescent-arv.pdf on February 6, 2023. 
11 CDC and HRSA also endorse ART, regular medical visits, and viral load testing for people with HIV.  See CDC, Understanding 
Care, 2021.  Accessed at https://www.cdc.gov/hiv/basics/livingwithhiv/understanding-care.html on February 8, 2023.  Also see 
HRSA, HIV/AIDS Bureau Performance Measures, 2019.  Accessed at 
https://ryanwhite.hrsa.gov/sites/default/files/ryanwhite/grants/core-measures.pdf on January 2, 2023. 
12 HHS, Guidelines for the Use of Antiretroviral Agents in Adults and Adolescents with HIV, 2022.  See pages 30-31/C-9-10 for 
guidelines on viral load monitoring, pages 64/E-1 and 65/E-2 for ART recommended for all people with HIV, and pages 387/L-
2 and 388-389/L-3-L-4 for details on engaging in appointments (retention in care).  Accessed at 
https://clinicalinfo.hiv.gov/sites/default/files/guidelines/documents/adult-adolescent-arv/guidelines-adult-adolescent-arv.pdf 
on May 11, 2023. 
 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Endnotes | 21    
13 HHS, Guidelines for the Use of Antiretroviral Agents in Adults and Adolescents with HIV, 2022.  See pages 387/L-2 and 388-
389/L-3-L-4 for details on engaging in appointments (retention in care).  Accessed at 
https://clinicalinfo.hiv.gov/sites/default/files/guidelines/documents/adult-adolescent-arv/guidelines-adult-adolescent-arv.pdf 
on April 17, 2023. 
14 Regarding the recommended frequency for viral load testing, for example, HHS guidelines note that people with HIV who 
are on ART and have been virally suppressed for over a year may monitor their viral load levels every 6 months, while those 
who are starting an ART regimen or are not yet virally suppressed may monitor their levels more frequently.  HHS, Guidelines 
for the Use of Antiretroviral Agents in Adults and Adolescents with HIV, 2022.  See page 22/C-1 and Table 3, page 24/C-3, for 
recommended schedule of viral load tests.  Accessed at 
https://clinicalinfo.hiv.gov/sites/default/files/guidelines/documents/adult-adolescent-arv/guidelines-adult-adolescent-arv.pdf 
on April 17, 2023. 
15 Though HHS recommends that all people with HIV initiate ART, it also recommends that clinicians consider patients 
readiness for ART including assessments of substance use, social support, mental health, etc., and manage those factors 
accordingly.  See HHS, Guidelines for the Use of Antiretroviral Agents in Adults and Adolescents with HIV, 2022.  See pages 19/B-
1 for ART recommended for all people with HIV and recommendation to initiate ART immediately after HIV diagnosis.  Also see 
page 20/B-2 for recommendation to assess patient readiness for ART.  Accessed at 
https://clinicalinfo.hiv.gov/sites/default/files/guidelines/documents/adult-adolescent-arv/guidelines-adult-adolescent-arv.pdf 
on January 3, 2022.  
16 MedlinePlus, HIV Viral Load.  Accessed from https://medlineplus.gov/lab-tests/hiv-viral-
load/#:~:text=A%20viral%20load%20test%20is%20needed%20to%20guide%20treatment%20decisions.&text=This%20informa
tion%20helps%20your%20provider,if%20the%20medicines%20are%20working on December 23, 2022. 
17 CMS included HIV viral suppression in its 2023/2024 core set of adult health care quality measures for Medicaid.  This list 
includes measures to assess and improve health care quality.  Medicaid, 2023 and 2024 Core Set of Adult Health Care Quality 
Measures for Medicaid (Adult Core Set).  Accessed at https://www.medicaid.gov/medicaid/quality-of-care/downloads/2023-
adult-core-set.pdf on February 8, 2023.  Also, for the purpose of the core measures, see CMS, Core Measures.  Accessed at 
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/QualityMeasures/Core-Measures  on 
February 8, 2023.    
18 CMS, Monitoring and Improving Viral Load Suppression Among PLWH, Opportunities to Improve HIV Prevention and Care 
Delivery to Medicaid and CHIP Beneficiaries, December 1, 2016.  See page 13.  Download document at  
at https://www.hhs.gov/guidance/document/opportunities-improve-hiv-prevention-and-care-delivery-medicaid-and-chip-
beneficiaries on February 9, 2023.  
19 CDC, Importance of Complete Laboratory Reporting and How Selected National HIV Care Outcomes are used to Monitor 
Progress and Identify Needs, Selected National HIV Prevention and Care Outcomes in the United States, July 2019.  Accessed 
at https://www.cdc.gov/hiv/pdf/library/factsheets/cdc-hiv-national-hiv-care-outcomes.pdf on December 23, 2022. 
20  An estimated 34 percent of people diagnosed with HIV are not virally suppressed due to poor adherence to the continuum 
of care and to ART.  See Introduction on page 387/L-2 of HHS, Guidelines for the Use of Antiretroviral Agents in Adults and 
Adolescents with HIV, 2022.  Accessed at https://clinicalinfo.hiv.gov/sites/default/files/guidelines/documents/adult-adolescent-
arv/guidelines-adult-adolescent-arv.pdf on May 3, 2023. 
21 NIH, 10 Things to Know About HIV Suppression, June 12, 2020.  Accessed at https://www.niaid.nih.gov/diseases-
conditions/10-things-know-about-hiv-suppression on December 23, 2022.  
22 CMS, Medicare and Other Health Benefits: Your Guide to Who Pays First, 2021.  See pages 6 and 11.  Accessed at 
https://www.medicare.gov/sites/default/files/2021-10/02179-Medicare-and-other-health-benefits-your-guide-to-who-pays-
first.pdf on June 16, 2023. 
 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Endnotes | 22    
23 The Commonwealth Fund, How Differences in Medicaid, Medicare, and Commercial Health Insurance Payment Rates Impact 
Access, Health Equity, and Cost, August 17, 2022.  Accessed at https://www.commonwealthfund.org/blog/2022/how-
differences-medicaid-medicare-and-commercial-health-insurance-payment-rates-impact%20 on February 9, 2023. 
24 MACPAC, Physician Acceptance of New Medicaid Patients.  See slides 6-7.  Accessed at http://www.macpac.gov/wp-
content/uploads/2019/01/Physician-Acceptance-of-New-Medicaid-Patients.pdf on January 25, 2023. 
25 KFF, Medicare Eligibility for People with HIV, Medicare and People with HIV, 2023.  See details under Impact on People with 
HIV for the Individuals age 65 and older category in Table 1.  Accessed at https://www.kff.org/hivaids/fact-sheet/medicare-
and-hiv/ on January 26, 2023. 
26 OIG, CMS-Medicaid, OIGs Top Unimplemented Recommendations: Solutions to Reduce Fraud, Waste, and Abuse in HHS 
Programs, 2022.  See #12 of Top Unimplemented Recommendations, document pages 20-21.  Accessed at 
https://oig.hhs.gov/reports-and-publications/compendium/files/compendium2022.pdf on February 6, 2023. 
27 OIG, 5: Harnessing and Protecting Data and Technology To Improve the Health and Well-Being of Individuals, Top 
Management and Performance Challenges Facing HHS, 2022.  See Improving access to HHS data, second paragraph, 
document page 32.  Accessed at https://oig.hhs.gov/reports-and-publications/top-challenges/2022/2022-tmc.pdf on February 
6, 2023. 
28 KFF, 10 Things to Know About Medicaid, June 2023.  See sections 2, 4, 5, 6, and 7 for details on ways in which Medicaid 
programs vary.  Accessed at https://www.kff.org/medicaid/issue-brief/10-things-to-know-about-medicaid-setting-the-facts-
straight/ on February 6, 2023. 
29 CMS, January 2023 Medicaid and CHIP Enrollment Trends Snapshot.  Accessed at 
https://www.medicaid.gov/medicaid/national-medicaid-chip-program-information/downloads/january-2023-medicaid-chip-
enrollment-trend-snapshot.pdf on May 3, 2023.  
30 CMS, NCH and MEDPAR Data Dictionary, 2022.  Accessed at https://www.cms.gov/research-statistics-data-systems/nch-and-
medpar-data-dictionary on February 9, 2023. 
31 Chronic Conditions Data Warehouse, CCW Medicare Encounter Data File User Guide.  Accessed at 
https://www2.ccwdata.org/web/guest/user-documentation on February 9, 2023. 
32 CMS, What are Prescription Drug Event (PDE) data?, Questions and Answers on Obtaining Prescription Drug Event (PDE) 
Data.  Accessed at https://www.cms.gov/medicare/prescription-drug-
coverage/prescriptiondrugcovgenin/downloads/partdclaimsdataqa.pdf on February 9, 2023. 
33 ASPE, Enrollment DataBase, Centers for Medicare and Medicaid Services.  Accessed at https://aspe.hhs.gov/centers-
medicare-medicaid-services on February 9, 2023. 
34 We did not assess whether values populated in States claims data were valid procedure or NDC codes.  
35 We referenced CMSs thresholds for high concern and unusable State assessments for National Drug Code  RX, Procedure 
Codes  OT Professional, and Procedure Codes  OT Institutional.  See these topics accessed at https://www.medicaid.gov/dq-
atlas/landing/topics/info on March 13, 2023.  
36 CMS, Medicare and Other Health Benefits: Your Guide to Who Pays First, 2021.  See pages 6 and 11.  Accessed at 
https://www.medicare.gov/sites/default/files/2021-10/02179-Medicare-and-other-health-benefits-your-guide-to-who-pays-
first.pdf on June 16, 2023. 
37 Chronic Conditions Data Warehouse, Human Immunodeficiency Virus and/or Acquired Immunodeficiency Syndrome 
(HIV/AIDS), Other Chronic Health, Mental Health, and Potentially Disabling Conditions Algorithms, 2022.  Accessed by 
downloading HIV/AIDS PDF from https://www2.ccwdata.org/web/guest/condition-categories-other on February 9, 2023. 
 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Endnotes | 23    
38 HHS, Initiation of Antiretroviral Therapy, Guidelines for the Use of Antiretroviral Agents in Adults and Adolescents with HIV.  
Accessed at https://clinicalinfo.hiv.gov/en/guidelines/adult-and-adolescent-arv/initiation-antiretroviral-therapy?view=full on 
May 10, 2022. 
39 Families First Coronavirus Response Act, H.R. 6201, 116th Congress.   6008(b)(3)(2020).  Accessed at 
https://www.congress.gov/116/plaws/publ127/PLAW-116publ127.pdf on February 9, 2023. 
40 HRSA, Performance Measure Portfolio, 2022.  See Core Measures PDF.  Accessed at 
https://ryanwhite.hrsa.gov/grants/performance-measure-portfolio on February 6, 2023.  
41 Tukey, John W., Exploratory Data Analysis, Vol. 2, 1977.  
42 HHS recommends initiating ART immediately or as soon as possible.  In limited cases, such as those of people with HIV who 
have cryptococcal and TB meningitis, HHS notes that a short delay before initiating ART may be warranted.  See Concerns 
regarding immune reconstitution inflammatory syndrome (IRIS) under Antiretroviral Therapy for Persons with Acute 
Opportunistic Infections and Malignancies.  Accessed at https://clinicalinfo.hiv.gov/en/guidelines/hiv-clinical-guidelines-adult-
and-adolescent-arv/initiation-antiretroviral-therapy on January 9, 2023.  
43 HHS, Clinic or Laboratory Monitoring Visits Related to HIV Care, Guidance for COVID-19 and People with HIV, 2021.  
Accessed at https://clinicalinfo.hiv.gov/sites/default/files/guidelines/archive/covid-19-hiv-2021-02-26.pdf on October 13, 2022.  
44 HHS, Guidelines for the Use of Antiretroviral Agents in Adults and Adolescents with HIV, see page 389/L-4, second paragraph 
under Improving Retention in Care, for more information about use of telehealth for HIV care during the COVID-19 public 
health emergency.  Accessed at https://clinicalinfo.hiv.gov/sites/default/files/guidelines/documents/adult-adolescent-
arv/guidelines-adult-adolescent-arv.pdf on January 4, 2023. 
45 ResDAC, CMS Cell Size Suppression Policy, 2017.  Accessed at https://resdac.org/articles/cms-cell-size-suppression-policy on 
February 6, 2023. 
46 ResDAC, CMS Cell Size Suppression Policy, 2017.  Accessed at https://resdac.org/articles/cms-cell-size-suppression-policy on 
February 6, 2023. 
Data Brief: One Quarter of Medicaid Enrollees with HIV May Not Have Received Critical Services in 2021 
OEI-05-22-00240  Endnotes | 24