Improper payment rate (PERM) exposure
Eligibility Span Drift
8,876
Members affected
$19.6M
Estimated exposure
3.6
Avg months at risk
$14.0M–23M
Exposure range
What this is
Member exists in both systems, but enrollment spans disagree by more than 30 days — MMIS keeps paying past the CBES termination, or starts paying before approval.
Why single-system review misses this
Both systems show a plausible, internally valid span. The gap only exists in the comparison — no single-system report ever computes it.
One member, two systems
Member CAS-00000029 — the eligibility record and the payment record, on one clock. The hatched window is the seam.
CBES eligibility spanMMIS enrollment spanthe seam — payment during span disagreement
The exposure math, in the open
members × avg monthly capitation × avg months of span disagreement
8,876members×$612avg per month×3.6avg months≈$19.6Mestimated exposure
Example members:CAS-00000029CAS-00000062CAS-00000066CAS-00000274CAS-00000314