Department of Health and Human Services 
OFFICE OF 
 
INSPECTOR GENERAL 
 
 
 
 
 
 
 
CMS P S
S  ROCESS FOR  HARING 
 
  INFORMATION ABOUT  
 
T P  
ERMINATED  ROVIDERS 
 
 
N I
EEDS  MPROVEMENT 
 
Daniel R. Levinson   
Inspector General  
 
March 2014  
OEI-06-12-00031     
EXECUTIVE SUMMARY: 
CMSs Process for Sharing Information About Terminated Providers Needs 
Improvement 
OEI-06-12-00031 
 
WHY WE DID THIS STUDY 
The Patient Protection and Affordable Care Act (ACA) requires the Centers for Medicare  
& Medicaid Services (CMS) to establish a process for sharing information about terminated 
providers. To meet this requirement, CMS established a Web-based portal, the Medicaid 
and Childrens Health Insurance Program State Information Sharing System (MCSIS).  
Sharing terminated provider data among States prevents terminated providers in one State 
from enrolling in another State.  CMS and State agencies can submit information about 
providers that meet CMSs criteria for having been terminated for cause from Medicare, 
Medicaid, or the Childrens Health Insurance Program (CHIP).  State Medicaid agencies can 
use these data to identify these providers and subsequently terminate them from their 
Medicaid programs as required under another section of the ACA.  In November 2013, 
subsequent to the timeframe we examined for this study, CMS revised its process for sharing 
information about terminated providers.  The findings and recommendations in this report 
remain relevant to the new process.   
 
HOW WE DID THIS STUDY  
We examined all provider records contained in MCSIS as of June 1, 2013.  We  
(1) determined the extent to which CMS and State Medicaid agencies submitted records to 
MCSIS; (2) identified records that did not meet CMS criteria for reporting providers 
terminated for cause from Medicare, Medicaid, or CHIP; and (3) assessed whether records 
had complete identifying information about providers, including National Provider 
Identifiers (NPIs), provider types, and provider addresses. 
 
WHAT WE FOUND 
As of June 1, 2013, MCSIS contained records on terminated providers submitted by CMS 
and 33 State Medicaid agencies and did not contain records from the remaining State 
Medicaid agencies. Contrary to CMS guidance, about one-third of the 6,439 records in 
MCSIS did not relate to providers terminated for cause.  Over half of MCSIS records did 
not contain NPIs, a critical data element for accurately identifying providers.  Additionally, 
one-third of MCSIS records did not identify the provider types and one quarter had no 
provider addresses. 
 
WHAT WE RECOMMEND   
Our findings suggest that CMSs process for sharing information on terminated providers 
needs improvement to make it more useful to State Medicaid agencies in identifying 
providers that must be terminated pursuant to Federal law because they were terminated for 
cause by Medicare, Medicaid, or CHIP. Therefore, we recommend that CMS (1) require 
each State Medicaid agency to report all terminated providers, (2) ensure that the shared 
information contains only records that meet CMSs criteria for inclusion, and  
(3) take action to improve the completeness of records shared through the process.  CMS 
concurred with all recommendations. 
     
 
 
 
TABLE OF CONTENTS 
 
Objectives.................................................................................................... 1 

Background ................................................................................................. 1 

Methodology ............................................................................................... 5 

Findings....................................................................................................... 7 

CMS and 33 State Medicaid agencies submitted records on  

terminated providers to MCSIS; the remaining State agencies  

did not submit such records .............................................................. 7 

Almost one-third of records contained in MCSIS did not relate          

to providers terminated for cause ................................................ 7 

Over half of MCSIS records did not contain NPIs or other   

identifying information ................................................................... 9 

Conclusion and Recommendations ........................................................... 13 

Agency Comments and Office of Inspector General Response ................ 15 

Appendix ................................................................................................... 16 

A: MCSIS Records, as of June 1, 2013........................................ 16 

B: Agency Comments ................................................................... 21 

Acknowledgments ..................................................................................... 24 

     
OBJECTIVES 
1. 	  To determine the extent to which the Centers for Medicare  
& Medicaid Services (CMS) and State Medicaid agencies  
(State agencies) reported provider information to the Medicaid and 
Childrens Health Insurance Program State Information Sharing 
System (MCSIS). 
2.	   To identify MCSIS records not related to providers terminated for 
cause from Medicare, Medicaid, or the Childrens Health Insurance 
Program (CHIP). 
3.	   To assess the completeness of provider identifying information in 
MCSIS records, including National Provider Identifier (NPI), provider 
type, and provider address. 
BACKGROUND 
Section 6401(b)(2) of the Patient Protection and Affordable Care Act 
(ACA) requires CMS to establish a process to make available to State 
agencies information about individuals and entities1 terminated from  
participating in the Medicare, Medicaid, or CHIP programs.2  To meet this  
requirement, CMS established MCSIS, a secure Web-based portal, used 
for the specific purposes of storing information about terminated providers 
and making that information available to State Medicaid agencies.3    
During interviews, CMS officials indicated that they expected MCSIS to 
be a temporary database for use while CMS developed a more permanent 
process for sharing data on terminated providers.  In November 2013, 
subsequent to our data collection and analysis for this report, CMS revised 
the process and moved the function of sharing information about 
terminated providers from MCSIS to another automated system.  Although 
this report focuses on MCSIS, its findings and recommendations are 
applicable to the revised process.  
Section 6401(b)(2) of the ACA specifies that the process for sharing 
information on terminated providers must include the name of the 
 
1 76 Fed. Reg. 5862, 5943 (Feb. 2, 2011).  CMS interpreted the term individuals and  
entities to include providers, suppliers, and eligible professionals.  In this report, we use 
the term provider to refer to providers, suppliers, and eligible professionals.   
2 ACA, P.L. 111-148  6401(b)(2)  (Mar. 23, 2010), as amended  by the Health Care and  
Education Reconciliation Act of 2010, P.L. 111-152  (Mar. 30, 2010).  

3 CMS, CPI-B 11-05, ACA Program Integrity  ProvisionsGuidance to States
 
Section 6501Termination of Provider Participation Under Medicaid if Terminated
  
Under Medicare or Other State Plan, May 31, 2011.  

CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     1      
terminated provider, the providers NPI,4 and other identifying 
information.  Access to this information can assist State agencies in 
complying with section 6501 of the ACA, which requires State Medicaid 
programs to terminate participation of providers if terminated under 
Medicare, another State Medicaid program, or CHIP.5, 6    
ACA Provider Termination Requirement 
Section 6501 of the ACA requires that, effective January 1, 2011, each 
State must terminate the participation of any individual or entity from the 
State Medicaid program if that provider or entitys participation has been 
terminated from Medicare, another State Medicaid program, or CHIP.7   
Terminations occur when: 
	   Medicare, Medicaid, or CHIP programs revoke a providers billing 
privileges, 
	   the provider has exhausted all applicable appeal rights or the 
timeline for such appeal has expired,  
	   there is no expectation by any party that the termination is 

temporary, and  

	   the provider would be required to reenroll to have billing privileges 
reinstated.8    
The requirement for States to terminate applies only in cases when 
providers, suppliers, or eligible professionals were terminated or had their 
billing privileges revoked for cause.  For cause terminations, as 
defined by CMS in implementing regulations, means terminations or 
revocations of billing privileges for reasons that may include, but are not 
limited to, fraud, integrity, or quality.9  For cause terminations do not 
include State program removal of inactive providers from provider 
enrollment files or cases when providers voluntarily end their participation  
 
4 69 Fed. Reg. 3434, 3440 (Jan. 23, 2004).  The NPI is a standardized  Federal unique 
 
identifier for individual and organizational  health care providers.   Federal regulations 

require an NPI for transmitting health  information electronically for Medicare and 

Medicaid services. 

5 ACA  6501, the Social Security Act (SSA)    1902(a)(39),  42 U.S.C.  1396a(a)(39). 

6 76 Fed. Reg. 5862, 5943 (Feb. 2, 2011).  Although section  6501  of the ACA does not 

specifically require terminations  of CHIP providers, CMS included such terminations  

from CHIP in  Federal regulations. 
 
7 ACA  6501, SSA  1902(a)(39), 42 U.S.C.   1396a(a)(39). 

8 Ibid.   42 CFR   455.101. 
 
9 76 Fed. Reg. 5862, 5943 (Feb. 2, 2011).   42  CFR   455.416(c).  CMS, CPI-B 12-02, 

ACA Program Integrity  ProvisionsGuidance to StatesSection 6501Termination of
  
Provider Participation Under Medicaid if Terminated Under Medicare or Other State 

Plan, January  20, 2012.  CMS provided examples of for cause terminations, some of 

which are fraudulent conduct, abuse of billing privileges, misuse of billing numbers, 

falsification of medical records, and falsification  on enrollment applications. 

CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     2      
in the program, except when a provider takes this voluntary action to 
avoid a sanction, such as revocation or termination.10  
Submitting Records to MCSIS  
CMS made MCSIS available to accept submissions of records in 2011.  
CMS could submit records about providers terminated from Medicare, and 
State agencies could submit records about providers terminated from  
Medicaid or CHIP. CMS and State agencies could submit records by 
uploading or manually entering records into the database, and they could 
edit previously submitted records.11  Neither Federal law nor CMS policy 
requires States to submit records about terminated providers to CMS.  
However, CMS encouraged State agencies to submit such records to 
MCSIS and thus make information about terminated providers available to 
other State agencies to facilitate compliance with section 6501 of the 
ACA.12  CMS clarified to State agencies that for cause terminations 
shared with other States should be limited to terminations based upon 
fraud, integrity, or quality.13 Although CMS did not verify the 
information that State agencies submitted to MCSIS, it issued a User 
Manual with instructions to State agencies for submitting records to 
MCSIS.14     
Using Information Contained in MCSIS  
If State agencies submitted records to MCSIS as CMS encouraged them to 
do, other State agencies could use the information stored in MCSIS to 
identify providers that they must terminate from Medicaid pursuant to 
section 6501.15  To obtain information, a State agency could either search 
MCSIS for particular providers or export the MCSIS database to conduct 
matches against the State agencys roster of providers.  These data 
matches could identify providers by name and further verify possible 
matches by checking the NPI or other identifying information, such as 
provider type and address. The more data elements that matched, the 
 
10 Ibid. 

11 CMS, CPI-B 12-02, ACA Program Integrity  ProvisionsGuidance to States
 
Section 6501Termination of Provider Participation Under Medicaid if Terminated
  
Under Medicare or Other State Plan, January 20, 2012. 
 
12 Section 1902(a)(41)  of the SSA, 42  U.S.C.   1396a(a)(41), requires broadly that all 

Medicaid State plans provide that whenever  a provider  of services or any  other person is  
terminated, suspended, or otherwise sanctioned or prohibited  from participating under the 
State plan, the  State agency shall promptly notify the Secretary and, in the case of a  
physician  and notwithstanding paragraph (7), the State medical  licensing board of such  
action.  
13 Ibid. 

14 CMS, CMS Medicaid and Childrens Health Insurance Program (CHIP) State 

Information Sharing System  (MCSIS)  User Manual. Initial publication  Version  1.0, 
           
January 14, 2011; Version 2.9 published June 9, 2012. 
  
15 76 Fed. Reg. 5862, 5943 (Feb. 2, 2011).  42 CFR  455.416(c). 

CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     3      
greater the confidence a State agency could have that it identified the same  
provider terminated for cause by Medicare or another State program.  
MCSIS Data Fields 
MCSIS contained multiple data fields for storing information about 
terminated providers.  These fields included the two data elements 
specifically required by the ACA:  provider name and NPI.16  The ACA  
specifically requires CMSs information-sharing process to include NPI, 
which is the primary provider identifier used for submitting claims to 
Medicare, Medicaid, and many other health care payers.  However, not all 
types of providers are required to have an NPI (e.g., home health aides), 
meaning that an NPI may not have been available for every record 
submitted to MCSIS.17  MCSIS contained additional fields that captured 
other information, such as provider type, provider address, and the name  
of the reporting State. MCSIS also included fields associated with the 
providers termination, including termination date, length of termination, 
reason for termination, and program from which the provider was 
terminated (i.e., Medicare, Medicaid, or CHIP).18    
Seven MCSIS data fields, shown in  Table 1, were mandatory, meaning 
that record submissions had to contain information in those fields to be 
accepted into the database.  MCSIS would reject a record submitted with  
any mandatory fields empty.19   
Three fields shown in Table 1 were optional; MCSIS would accept a 
submission that did not contain information for NPI, provider type, and/or 
State provider ID. 
Some fields in MCSIS offered drop-down menus with a list of choices.  
For example, MCSIS had 14 choices for the reason for a providers 
termination, such as abuse of billing privileges, felony conviction, and 
State exclusion/debarment.  The field for provider type included 
26 choices, such as Physician, Nonphysician Practitioner, and Home  
Health Agency, as well as Other.   Additional fields with drop-down 
menus included the terminating program (i.e., Medicare, Medicaid, or 
CHIP) and the code for the reporting State.    
 
16 ACA  6401(b)(2).  

17 45 CFR   162.103,  162.404,  162.410.  NPIs are required  only for  health care  

providers satisfying the Health  Insurance Portability and  Accountability Acts (HIPAAs) 

definition  of covered entities, which means (1) a health  plan, (2) a health care 

clearinghouse,  or (3) a health care provider that transmits health information in electronic 

form in connection with a transaction covered by HIPAA.   Thus, some providers are not 
 
required to obtain an NPI because they do  not meet this definition. 

18 MCSIS contained a few other data fields that were not relevant  for purposes of this 
 
report. 
 
19 CMS, MCSIS User Manual, Version 2.9, June 9, 2012, p. 61. 

CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     4      
Table 1: Selected Data Fields Available for Records in MCSIS 
Terminated Provider Information  Mandatory   Optional  
Name (Individual or Organization)   X    
NPI  X  
Other Identifying Information:     
 Address (Mailing/Practice)  X   
     Provider Type     X 
State Code   X   
     State Provider ID     X 
Termination Information:     
     Length of Termination  X   
     Program Type (Medicare, Medicaid, or CHIP)   X   
     Termination Date  X   
     Termination Reason  X   
 
Source:  CMS MCSIS User Manual, Version 2.9, June 9, 2012. 
METHODOLOGY 
Scope 
For this report, we examined all records contained in MCSIS as of  
June 1, 2013. We identified the extent to which MCSIS contained records 
from CMS and State agencies about providers terminated for cause from 
Medicare and from Medicaid.  We also examined the completeness of 
information in MCSIS data fields and attempted to verify the accuracy of 
submitted NPIs.  This report focuses on records contained in MCSIS.  A  
separate Office of Inspector General (OIG) report (forthcoming) will 
address State agencies termination of providers pursuant to section 
6501.20  
Data Collection and Analysis 
To examine records contained in MCSIS, we first identified the number of 
records submitted by CMS and State agencies.  We calculated the 
percentage of records associated with Medicare and Medicaid providers.21   
We also examined the reason for termination listed in each record to 
identify any terminated providers not related to for cause terminations.   
To assess the completeness of records contained in MCSIS, we examined 
the contents of each data field for each record.  We calculated the 
percentages of complete fields and empty fields, across all records and by 
the reporting entity.  When records contained N/A in a data field, which 
 
20 OIG,  OIG Workplan, Fiscal  Year 2013; OIG, State Terminations of Providers 
Terminated by Medicare  or by  Other States, OEI-06-12-00030, publication expected in  
2014. 
21 At the time of our review, June 1, 2013, MCSIS did not contain any CHIP records.  
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     5      
could be an indication that the information was not available or not 
applicable, we considered these data fields to be empty.    
To the extent possible, we verified the accuracy of the NPIs contained in 
MCSIS. For this analysis, we compared the NPI contained in MCSIS to 
the NPI listed for the provider in CMSs National Plan and Provider 
Enumeration System (NPPES), the database that CMS uses for assigning 
NPIs to individual providers and entities.22    
Limitations 
This study has two limitations.  First, with the exception of the NPIs, we 
did not verify the accuracy of the information submitted to MCSIS.  
Second, given the temporary status of MCSIS and the voluntary 
participation by State agencies, we did not attempt to determine the extent 
to which MCSIS contained records for all providers terminated for 
cause. 
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of the Inspectors General 
on Integrity and Efficiency. 
   
 
22 CMS (Medicare Learning Network), The National Provider Identifier (NPI): What 
You Need to Know.   Accessed at http://www.cms.gov/Outreach-and-Education/Medicare-
Learning-Network-MLN/MLNProducts/downloads/NPIBooklet.pdf  on  April 28, 2013.  
CMS developed the NPPES to assign unique identifiers to providers, and  CMS stores this  
information in  a searchable database known as the NPI Registry.  To avoid assigning the 
same NPI to more than  one provider, the NPPES tracks individual  providers using unique  
personal identifiers, such as  date of birth (DOB), place of birth, Social Security number 
(SSN), and Taxpayer Identification number (TIN).  
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     6      
FINDINGS 

MCSIS contained records on terminated providers 
submitted by CMS and 33 State Medicaid agencies and 
did not contain records from the remaining State 
Medicaid agencies  
As of June 1, 2013, MCSIS contained 6,439 provider records submitted by 
CMS and 33 State agencies.  CMS submitted 27 percent of MCSIS 
records (1,726) about providers terminated from Medicare.  Combined, the 
33 State agencies submitted the remaining 73 percent (4,713) of records.  
Four States accounted for 72 percent (3,413 of 4,713) of the Medicaid 
records contained in MCSIS:  California (2,074), New York (597), 
Pennsylvania (442), and Illinois (300).   See Appendix A, Table A-1, for 
the number of provider records submitted by CMS and State agencies. 
MCSIS did not contain records from the remaining State agencies as of  
June 1, 2013. CMS policy does not require State agencies to submit data 
on terminated providers through CMSs information-sharing process.   
Almost one-third of records contained in MCSIS did 
not relate to providers terminated for cause 
Of the 6,439 records contained in MCSIS, over 2,000 records did not 
relate to providers terminated for cause.  As mentioned above, CMS 
provided guidance with criteria about for cause terminations and 
specified that the information shared in MCSIS should be limited to 
providers terminated for cause.  However, many records in MCSIS 
pertained to individuals who were not enrolled in or had not been 
terminated from the Medicaid program in the States submitting the 
records, and others pertained to providers whose termination from  
Medicare did not meet CMSs criteria for for cause termination.  
   
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     7      
California submitted records to MCSIS for providers that were 
not enrolled in and had not been terminated from the State 
Medicaid program 
California submitted numerous records (2,000 or more)23 for providers that 
were not enrolled in the Medicaid program.  Therefore, these providers 
were not terminated for cause and would not warrant termination by 
another State Medicaid program pursuant to section 6501.  When 
contacted, State agency officials explained that the agency deemed these 
individual providers and organizations ineligible for enrollment in the 
State Medicaid program.24  Although these officials recognized that the 
records the agency had submitted to MCSIS did not meet the criteria for 
provider terminations, they explained that they wanted to make other State 
agencies aware of the providers status as ineligible for enrollment in 
California. 25    
CMS submitted records to MCSIS for deceased providers that 
were not terminated for cause 
Of the Medicare provider records submitted to MCSIS, 4 percent (71 of  
1,726) pertained to providers listed as deceased.  CMS provides a 
disclaimer in MCSIS acknowledging that deceased providers do not meet 
the guidance it issued regarding for cause terminations for purposes of 
section 6501. The disclaimer indicates that States should use the 
information to ensure that they are not paying for services billed on behalf  
of deceased providers.26   See Appendix A, Tables A-2 and A-3, for 
termination reasons submitted to MCSIS by Medicare and State agencies. 
 
23 It is  not  possible to determine precisely how many of the 2,074 records submitted by  
the California Medicaid program pertained to  providers that were not enrolled and had  
not been  terminated.  However, State agency  officials indicated that, by the definition of  
suspended and ineligible, the vast majority  of  these providers were not participating  in, 
and had not been terminated from, Medicaid.    
24 State of California Welfare and Institutions Code,  14043.6 and 14123. 
25  We  followed up with officials in California on this issue because MCSIS contained so  
many California records.   However, we did not contact the other State agencies about this  
issue because it was beyond the scope of the planned data collection for this report.  
Other State agencies may also  have submitted records for providers that were  not 
terminated for cause.  
26 MCSIS contains the following disclaimer about records for deceased providers:  In 
addition to sharing information  regarding Medicare providers that have  had their 
Medicare billing privileges revoked for  cause, CMS will also be  sharing information  
about providers that have had their Medicare  billing privileges deactivated because our 
data indicates they are deceased.  While the  requirement of section 6501 of the  
Affordable Care Act do not apply per se, States should  use the information regarding  
deceased  providers to ensure they are not paying for any services that were billed as if 
they were rendered by such  deceased providers.  Providers that have had their Medicare 
enrollment deactivated due  to death will be  designated as deceased provider under the 
reason for termination. 
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     8      
Over half of MCSIS records did not contain NPIs or 
other identifying information 
Although all MCSIS records included the name of a provider, many 
records did not contain information that would be useful when State 
agencies attempt to identify providers required to be terminated by 
section 6501.  Key information missing from MCSIS records included 
NPI, provider type, and address. Overall, 59 percent (3,831 of 6,439) of 
MCSIS records were blank (i.e., contained no information) for at least 1 of 
these fields. 
Over half of records in MCSIS did not contain NPIs, and some 
NPIs appeared to be inaccurate 
Overall, 59 percent (3,771 of 6,439) of MCSIS records did not contain 
NPIs. Most provider types (e.g., physicians, nurse practitioners, home 
health agencies) must have NPIs to bill Medicare and Medicaid, 
suggesting that submitters omitted the NPIs from many of these records.27   
For 15 State agencies, more than 50 percent of submitted records did not 
contain NPIs. 
The remaining 41 percent of MCSIS records contained an NPI.  All 
1,726 records submitted by CMS for Medicare providers contained NPIs, 
as did all records submitted by 8 States.  See Table 2 for the number and 
percentage of MCSIS records without NPIs. 
Additionally, 3 percent (93 of the 2,668) of NPIs in MCSIS records 
appeared to be inaccurate when compared to NPI data contained in 
NPPES, the database that CMS uses for assigning NPIs to individual 
providers and entities. Three percent (73) of the NPIs in MCSIS were 
listed in NPPES as belonging to different providers, and another 1 percent 
(20) of the NPIs in MCSIS did not match any provider in NPPES.  Both 
Medicare and Medicaid provider records had NPI inaccuracies in MCSIS.      
 
   
 
27 It was not  possible to confirm whether some provider records in MCSIS legitimately 
did not include NPIs, such as  records involving types of providers that are not  required to  
obtain NPIs, because many of the records missing NPIs were also missing information on 
the provider types.  
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     9      
 Table 2: Number and Percentage of MCSIS Records Without NPIs, by 
Program Type  
Percentage of  MCSIS 
State Medicaid 
Number Without NPI  Total Records  Records 
Program  
Lacking NPI  
CA  2,018   2,074   97%  
NY   399  597  67%  
PA  333  442  75%  
IL  300  300  100%  
AL  167  190  88%  
OH   128  263  49%  
NJ  100  159  63%  
AR  92  93  99%  
MD  65  122  53%  
NE  40  43  93%  
MI  24  146  16%  
IA  20  21  95%  
AK  16  16  100%  
ID  15  22  68%  
VT  13  14  93%  
MS  10  32  31%  
FL  8  9  89%  
GA   7  20  35%  
MO  3  18  17%  
VA  3  6  50%  
ME  3  4  75%  
AZ  2  12  17%  
CT  2  5  40%  
IN  2  4  50%  
WI  1  43  2%  
WA  0  18  0%  
NV  0  18  0%  
DE  0  14  0%  
KS  0  2  0%  
MA  0  2  0%  
TN  0  2  0%  
LA  0  1  0%  
RI  0  1  0%  
Medicaid Total   3,771   4,713   80%  
Medicare Total   0   1,726   0%  
Medicare and 
3,771   6,439   59%  
Medicaid Total  
Source:  OIG analysis of MCSIS data  as of June 1, 2013. 
 
 
 
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     10      
One-third of MCSIS records did not contain provider type 
information, and many other records listed the provider type 
as Other 
Although MCSIS offers a drop-down menu for selecting the type of 
provider for each record, the provider type field was blank for 33 percent 
(2,107) of MCSIS records. Fourteen State agencies submitted the records 
with missing provider type information.28   Another 19 percent of records 
(1,221) contained Other in the provider type field, potentially making 
these records less useful for verifying  database matches.  (See Table 3.)  
Programs with records listing the provider type as Other included both 
Medicare (355 records) and Medicaid (866 records).  The Other label is 
appropriate for records that do not fit under any of the other 25 specific 
provider type choices in the drop-down menu.  However, it is possible that 
some States overused the Other label.  For example, Arkansas used 
Other in 95 percent of its submitted records (88 of 93), and Florida did 
so for 78 percent of its records (7 of 9).  See Appendix A, Tables A-4 and 
A-5, for listings of provider types submitted to MCSIS by Medicare and 
State agencies. 
Table 3: Total Number and Percentage of MCSIS Records by  

Contents of  Provider Type Field
  
Provider Type   Records   Percentage  
Provider Type Was Listed (Not Listed 
3,111  48%  
as Other) 
Blank  2,107   33%  
Provider Type Listed As Other   1,221   19%  
Total    6,439   100%  
Source:  OIG analysis of MCSIS data  as of June 1, 2013. 
Among records that contained information on provider type, physician 
was the most common provider type listed, indicated in over 30 percent of 
the records. The only other provider types accounting for more than 1 
percent of MCSIS records were Nonphysician Practitioners (5.8 percent), 
Personal Care Attendants (3.8 percent), Psychologists (1.7 percent), 
Dentists (1.6 percent), and Pharmacists (1.2 percent).   
   
 
28 California records accounted for 97  percent  (2,049  of 2,107) of the records missing 
provider type information.  
 
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     11      
Almost one-quarter of MCSIS records did not contain 
addresses for the providers 
Although MCSIS includes fields for reporting an individuals practice 
address, a business address, or both, 22 percent of MCSIS records (1,448) 
contained neither.29  California submissions accounted for all the records 
without addresses and instead contained N/A (presumably meaning not 
applicable) in address fields. 30  The remaining 78 percent of records 
contained addresses, with street numbers or P.O. box numbers, cities, 
States, and ZIP Codes.  31  Our review did not attempt to verify the 
accuracy of the address information contained in MCSIS records.  
 
29 As mentioned earlier, the address field in MCSIS was a mandatory  data field.  
However, it appeared that MCSIS accepted submissions as long as the records contained 
any characters  typed in the provider or  organization address field.    
30 A small number (62  of 6,439)  of the records from States other than California 
contained somewhat incomplete address information, such as containing  only the name of  
an institution  or facility or missing street numbers or cities. 
31 As a result of  rounding, the total number of records without addresses (23 percent) and 
total with addresses (78  percent) do  not sum to 100  percent.  
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     12   CONCLUSION AND RECOMMENDATIONS 
As required by the ACA, CMS established a process for sharing 
information about terminated providers by creating MCSIS, a Web-based 
portal. Our findings suggest that CMSs information-sharing process 
needs improvement to make it useful to State agencies to identify 
providers that the States must terminate from Medicaid pursuant to 
section 6501.  Although CMS and 33 State agencies submitted over 
6,400 provider records to MCSIS, the remaining State agencies had not 
submitted any records on terminated providers as of June 1, 2013.  
Further, many of the records contained in MCSIS did not relate to 
providers terminated for cause, a requisite factor for State termination 
under section 6501. Moreover, many MCSIS records had empty data 
fields, including fields critical for identifying providers, including NPI, 
provider type, and address. 
Although CMS recently revised its process for sharing information about 
terminated providers, our findings are applicable to the revised process.  
To maximize the usefulness of its process, CMS should address the issues 
identified in this report.   
Therefore, we recommend that CMS: 
Require each State Medicaid agency to report all terminated 
providers 
As directed by section 6401(b)(2) of the ACA, CMS established a process 
to make available information about health care providers that State 
Medicaid agencies must terminate under section 6501 of the 
ACA. However, we found that many State agencies did not submit 
information about any providers terminated from their programs during 
the period that we reviewed: as a result, MCSIS included only a portion of 
providers terminated for cause.   
To date, CMS has encouraged, rather than required, State agencies to 
submit terminated provider records.  However, CMS has broad authority 
under section 1902(a)(41) of the SSA to require State agency reporting of 
information about terminated providers. CMS should use this authority to 
ensure that the process established under section 6401(b)(2) of the ACA  
includes all providers terminated by State and Federal programs for 
reasons involving fraud, integrity, or quality. 
 
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     13      
 
 
Ensure that the shared information contains only records that 
meet CMS criteria for inclusion 
To date, CMS guidance has been clear that terminations shared through its 
information-sharing process should be limited to for cause terminations 
for reasons involving fraud, integrity,  or quality.  By definition, for 
cause terminations are not final until the provider has exhausted all 
applicable appeal rights or the timeline for such appeal has expired.  To  
ensure that its information-sharing process does not include inappropriate 
records, such as those for individuals who were not enrolled or who had 
not been terminated, CMS should adhere to its criteria and remove any 
existing records that do not meet the criteria.  Such actions would assure 
State agencies that the providers listed as terminated for cause must be 
terminated under section 6501.  Further, because deceased providers do 
not meet the criteria for for cause termination, CMS should remove the 
Medicare records for deceased providers from its information-sharing 
process. We do not recommend a change in criteria for submissions.  Still, 
if CMS chooses to include records for deceased providers or to otherwise 
expand its information-sharing process beyond for cause terminations, it 
should issue new regulations or guidance and implement a mechanism to 
clearly identify those providers that a State must terminate under section 
6501. 
Take action to improve the completeness of records shared 
through the process, especially in data fields critical to 
identifying terminated providers 
Incomplete recordsespecially those missing NPIs, provider types, and 
addressesmake CMSs information-sharing process far less useful to 
States attempting to identify providers that warrant termination under 
section 6501. Without at least some  of this essential information, data 
matches of State provider rosters against CMSs data would likely require 
confirmation using other sources.  To  improve the quality of records, CMS 
could further educate State agencies about the importance of submitting 
complete records.  CMS could also consider automated changes within the  
process, such as making more data fields mandatory to complete a 
submission or embedding warnings when submissions are blank in certain 
data fields.  Additionally, because some providers terminated for cause 
do not have unique NPIs, CMS should consider adding data fields for 
other identifying information, such as SSN, TIN, Employer Identification 
Number (EIN), and DOB, and should make any necessary changes to the 
process to ensure the security of added personally identifiable information.   
   
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     14      
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL  
RESPONSE 
CMS concurred with all of our recommendations. 
In response to our recommendation that CMS require each State Medicaid 
agency to report all terminated providers, CMS acknowledged its authority 
under section 1902(a)(41) of the SSA to require State Medicaid agencies 
to report terminations of Medicaid and CHIP providers.  Accordingly, it 
will explore options available to implement mandatory State reporting of  
data on for cause terminations from Medicaid and CHIP. 
In response to our recommendation that CMS ensure that the process for 
sharing information contains only records that meet the criteria for 
inclusion, CMS stated that it has a new process for sharing information on 
terminated providers, effective November 25, 2013.  According to CMS, 
this processintended for use by staff from CMS, State Medicaid 
agencies, and CHIPwill allow information on terminated providers to be  
shared securely.  Under the new process, CMS plans to require States to 
submit a copy of the Medicaid termination letter issued to the provider.   
After submission, CMS intends to review each termination to ensure that it 
meets criteria for inclusion.   
In response to our recommendation to take action to improve the 
completeness of records, especially in data fields critical to identifying 
terminated providers, CMS stated that the new process requires States to 
submit information in critical data fieldssuch as the field for the NPI 
as well as a copy of the Medicaid termination letter.  We reiterate that 
CMS should consider adding data fields, such as SSN, TIN, EIN and 
DOB, for identifying providers when an NPI is not available. 
We removed a fourth recommendation listed in our draft reportfor CMS 
to establish a timeframe for replacing MCSISgiven that CMS has now 
revised the process and moved it to another automated system.     
For the full text of CMSs comments, see Appendix B.   
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     15      
APPENDIX A 
MCSIS Records, as of June 1, 2013 
Table A-1: Number and Percentage of MCSIS Records  
by Year Submitted and Program Submitting  
State Medicaid  Submission Year  Number of  
Percentage  
Program   2011  2012   2013*  Records  
AK  0  16  0   16  0.3%  
AL  0  166  24  190  4.0%  
AR  16  67  10  93  2.0%  
AZ  0  0  12  12  0.3%  
CA  0  2,056   18  2,074   44.0%  
CT   5  0  0  5  0.1%  
DE  0  14  0  14  0.3%  
FL   0  9  0  9  0.2%  
GA    0  2  18  20  0.4%  
IA  0  17  4  21  0.4%  
ID  10  3  9  22  0.5%  
IL  0  288  12  300  6.4%  
IN  1  3  0  4  0.1%  
KS  0  2  0  2  <0.1% 
LA  1  0  0  1  <0.1%  
MA  0  2  0  2  <0.1% 
MD  24  67  31  122  2.6%  
ME  0  4  0  4  0.1%  
MI  57  62  27  146  3.1%  
MO  0  12  6  18  0.4%  
MS   0  15  17  32  0.7%  
NE  29  2  12  43  0.9%  
NJ  22  111  26  159  3.4%  
NV  0  18  0  18  0.4%  
NY   443  74  80  597  12.7%  
OH   0  263  0  263  5.6%  
PA  173  187  82  442  9.4%  
RI  0  1  0  1  <0.1% 
TN    0  2  0  2  <0.1%  
VA  3  0  3  6  0.1%  
VT  1  8  5  14  0.3%  
WA  3  13  2  18  0.4%  
WI   0  28  15  43  0.9%  
Medicaid Total   788  3,512   413  4,713   73%  
Medicare Total   0  233  1,493   1,726   27%  
Medicare and 
788  3,745   1,906   6,439   100%  
Medicaid Total  
Source:  OIG analysis of MCSIS data  as of June 1, 2013. 

*Data include submissions from January  1, 2013, to June 1, 2013. 

 
 
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     16      
Table A-2: Number and Percentage of  MCSIS Records by Termination 
Reason and Program Type  
Medicare  Percentage 
Termination Reason Listed in 
Medicare  Medicaid   and  of MCSIS 
MCSIS 
Medicaid   Records  
State exclusion/debarment, etc.  0  2,693   2,693   41.8%  
Loss of license or other State action  1,492   601  2,093   32.5%  
Federal exclusion/debarment, etc.   157  962  1,119   17.4%  
Felony conviction  0  188  188  2.9%  
Other   0  106  106  1.6%  
Action taken by  Medicare  5  91  96  1.5%  
Deceased provider   71  0  71  1.1%  
Noncompliance  0  37  37  0.6%  
Action taken by  Medicaid/CHIP  0  18  18  0.3%  
False or misleading information   1  9  10  0.2%  
Abuse of billing privileges   0  7  7  0.1% 
Misuse of billing number   0  1  1  <0.1% 
Failure to report a change of 
0  0  0  0%  
address/ownership 
Onsite review/provider is no longer 
0  0  0  0%  
operational  
Total   1,726  4,713  6,439   100%  
Source:  CMS MCSIS User Manual and OIG analysis of MCSIS data as of  June 1, 2013. 
 
   
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     17      
Table A-3: Number and Percentage of  MCSIS Records by Program and the 
Termination Reason Listed in MCSIS  
    n
           SMPtreaodtgeicr aamid     State exclusion/debarment, etc. Loss of license or other State actio  Federal exclusion/debarment, etc.  Felony conviction  Other  Action taken by Medicare Deceased provider  Noncompliance  Action taken by Medicaid/CHIP  False or misleading information   Abuse of billing privileges Misuse of billing number 
                       
AK  1  0  1  4  3  0  0  7  0  0  0  0 
AL  1  30  62  4  1  88  0  0  2  0  2  0 
AR  0  0  1  61  31  0  0  0  0  0  0  0 
AZ  4  8  0  0  0  0  0  0  0  0  0  0 
CA  2,056   0  0  0  18  0  0  0  0  0  0  0 
CT   2  0  0  2  0  0  0  0  1  0  0  0 
DE  14  0  0  0  0  0  0  0  0  0  0  0 
FL   0  1  0  3  0  0  0  3  0  2  0  0 
GA   0  0  1  19  0  0  0  0  0  0  0  0 
IA  3  1  1  16  0  0  0  0  0  0  0  0 
ID  10  0  0  3  0  0  0  4  0  0  5  0 
IL  89  0  211  0  0  0  0  0  0  0  0  0 
IN  0  1  0  0  0  0  0  3  0  0  0  0 
KS  0  0  1  0  0  0  0  1  0  0  0  0 
LA  0  0  0  0  0  0  0  0  0  1  0  0 
MA  0  0  0  0  0  0  0  0  2  0  0  0 
MD  39  39  36  7  0  0  0  0  0  0  0  1 
ME  3  0  0  1  0  0  0  0  0  0  0  0 
MI  2  134  5  0  2  2  0  0  1  0  0  0 
MO  0  4  2  5  1  0  0  0  0  6  0  0 
MS  0  9  0  11  11  1  0  0  0  0  0  0 
NE  27  0  0  0  0  0  0  16  0  0  0  0 
NJ  7  47  83  3  19  0  0  0  0  0  0  0 
NV  4  0  1  0  1  0  0  1  11  0  0  0 
NY   292  148  131  15  9  0  0  2  0  0  0  0 
OH   72  75  116  0  0  0  0  0  0  0  0  0 
PA  55  51  306  26  4  0  0  0  0  0  0  0 
RI  1  0  0  0  0  0  0  0  0  0  0  0 
TN   0  1  0  1  0  0  0  0  0  0  0  0 
VA  0  0  1  5  0  0  0  0  0  0  0  0 
VT  11  0  1  2  0  0  0  0  0  0  0  0 
WA  0  17  0  0  0  0  0  0  1  0  0  0 
WI  0  35  2  0  6  0  0  0  0  0  0  0 
Medicaid   2,693   601  962  188  106  91  0  37  18  9  7  1 
Medicare   0  1,492   157  0  0  5  71  0  0  1  0  0 
Medicare 
and  2,693   2,093   1,119   188  106  96  71  37  18  10  7  1 
Medicaid  
Source:  CMS MCSIS User Manual and OIG analysis of MCSIS data as of  June 1, 2013.  
   
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     18      
Table A-4: Number and Percentage of MCSIS Records by Provider Type 
and Program Type  
Medicare  Percentage 
Provider Type  Listed in MCSIS   Medicare   Medicaid   and  of MCSIS 
Medicaid   Records  
Field left blank  0  2,107   2,107   32.7%  
Physician  1,169   789  1,958   30.4%  
Other  355  866  1,221   19.0%  
Nonphysician practitioner (e.g., Nurse 
Practitioner, Physician Assistant, 
65  307  372  5.8%  
Certified Nurse Anesthetist, Certified 
Nurse Midwife, etc.) 
Personal Care Agency/Attendant   0  244  244  3.8%  
Psychologist  95  14  109  1.7%  
Dentist  8  98  106  1.6%  
Pharmacy   0  75  75  1.2%  
Comprehensive Outpatient 
Rehabilitation Facility/Outpatient  0  53  53  0.8%  
Rehabilitation Facility  
Therapist (Physical Therapist, 
Occupational Therapist, Speech  15  33  48  0.7%  
Language Pathologist) 
Non-Emergency Transportation   0  46  46  0.7%  
Durable Medical Equipment  0  30  30  0.5%  
Licensed Mental Health Provider   14  16  30  0.5%  
Home Health Agency  0  15  15  0.2%  
Community Mental Health Center   0  5  5  0.1%  
Hospice  0  5  5  0.1%  
Rural Health Clinic  0  3  3  <0.1%  
Ambulatory Surgical Center   3  0  3  <0.1% 
Ambulance  0  2  2  <0.1%  
Independent Diagnostic Testing Facility   2  0  2  <0.1% 
Intermediate Care Facility for Persons 
0  2  2  <0.1%  
with Mental Retardation  
Skilled Nursing Facility/Nursing Facility   0  2  2  <0.1% 
Rehabilitation Center (Inpatient)  0  1  1  <0.1% 
Hospital  0  0  0  0%  
Laboratory  0  0  0  0%  
Residential Treatment 
Facility/Psychiatric Residential  0  0  0  0%  
Treatment Facility 
Federally  Qualified Health Center   0  0  0  0%  
Total   1,726   4,713   6,439   100%  
Source: CMS MCSIS User Manual and OIG analysis of MCSIS data as of  June 1, 2013. 
 
   
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     19      
Table A-5: Number and Percentage of  MCSIS Records by  Provider Type Listed in MCSIS, Program Type, and State 
Medicaid Program  
State Medicaid Program    Field left blank  Physician Other       Nonphysician Practitioner (e.g., NP, PA,     CRNA, Certified Nurse Midwife, etc.)   Personal Care Agency/Attendant  Psychologist     Dentist    Pharmacy   Comprehensive Outpatient Rehab Facility/    Outpatient Rehab Facility    Non-Emergency Transportation      Therapist (Physical Therapist, Occupational   Therapist, Speech Language Pathologist)    Durable Medical Equipment      Licensed Mental Health Provider   Home Health Agency     Community Mental Health Center Hospice    Rural Health Clinic    Ambulatory Surgery Center  Independent Diagnostic Testing Facility  Ambulance    Intermediate Care Facility for Persons with       Mental Retardation     Skilled Nursing Facility/Nursing Facility   Rehabilitation Center (Inpatient)   
AK  0  0  8  3  5  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
AL  0  30  148  2  0  0  3  1  0  0  0  4  1  0  0  1  0  0  0  0  0  0  0 
AR  2  2  88  0  0  0  1  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
AZ  0  6  3  3  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
CA  2,049   13  0  0  0  1  0  2  0  1  6  2  0  0  0  0  0  0  0  0  0  0  0 
CT   0  2  0  0  0  0  1  0  0  0  0  0  0  0  0  0  0  0  0  0  0  2  0 
DE  0  10  0  1  0  0  2  0  0  0  0  0  0  1  0  0  0  0  0  0  0  0  0 
FL  0  1  7  0  0  0  0  0  0  0  1  0  0  0  0  0  0  0  0  0  0  0  0 
GA  7  1  4  2  1  0  0  0  0  0  1  1  1  0  2  0  0  0  0  0  0  0  0 
IA   1  0  2  0  18  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
ID  8  0  3  2  0  0  0  0  0  5  0  0  0  0  3  0  0  0  0  0  0  0  1 
IL   0  167  32  2  0  1  19  1  53  21  0  0  0  0  0  0  3  0  0  0  1  0  0 
IN  0  0  3  0  0  0  0  0  0  1  0  0  0  0  0  0  0  0  0  0  0  0  0 
KS  1  0  0  0  0  0  0  0  0  0  0  0  0  1  0  0  0  0  0  0  0  0  0 
LA  0  0  1  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
MA  0  1  1  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
MD  3  64  41  4  2  0  1  0  0  0  0  2  5  0  0  0  0  0  0  0  0  0  0 
ME  0  0  3  0  0  1  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
MI  2  48  58  5  1  0  3  24  0  0  1  1  0  3  0  0  0  0  0  0  0  0  0 
MO  0  5  1  0  0  2  0  0  0  0  2  1  1  5  0  0  0  0  0  0  1  0  0 
MS  9  9  9  1  0  0  0  0  0  0  0  0  0  0  0  4  0  0  0  0  0  0  0 
NE  0  0  1  1  40  0  0  0  0  1  0  0  0  0  0  0  0  0  0  0  0  0  0 
NJ  18  52  48  1  0  2  19  13  0  0  0  1  1  4  0  0  0  0  0  0  0  0  0 
NV  3  2  8  0  5  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
NY  0  173  143  164  19  4  31  30  0  5  15  9  3  1  0  0  0  0  0  0  0  0  0 
OH  0  76  3  46  117  0  5  2  0  12  0  1  0  0  0  0  0  0  0  1  0  0  0 
PA  2  92  243  58  26  3  10  1  0  0  4  2  0  0  0  0  0  0  0  1  0  0  0 
RI   0  1  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
TN  0  2  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
VA  1  3  1  0  1  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
VT  0  0  3  0  9  0  1  1  0  0  0  0  0  0  0  0  0  0  0  0  0  0  0 
WA   0  11  3  1  0  0  2  0  0  0  1  0  0  0  0  0  0  0  0  0  0  0  0 
WI   1  18  1  11  0  0  0  0  0  0  2  6  4  0  0  0  0  0  0  0  0  0  0 
Medicaid   2,107   789  866  307  244  14  98  75  53  46  33  30  16  15  5  5  3  0  0  2  2  2  1 
Medicare   0  1,169   355  65  0  95  8  0  0  0  15  0  14  0  0  0  0  3  2  0  0  0  0 
Medicaid  
and  2,107   1,958   1,221   372  244  109  106  75  53  46  48  30  30  15  5  5  3  3  2  2  2  2  1 
Medicare  
Source:  CMS MCSIS User Manual and OIG analysis of MCSIS data as of  June 1, 2013.  
 
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     20   APPENDIX 8 
AGENCY COMMENTS 
..,.....
~ 
(,._~ 
DEPARTMENT OF HEALTII & HUMAN SERVICES  Centers for Medicare & Medicaid Services 
Administrator 
Washington, DC 20201 
JAN 17  Z014 
DATE: 
TO:  Daniel R. Levinson 
Inspector General 
FROM:  Marilyn TaV&lll1er 
Administrutor 
SUBJECT:  Office oflnspector General (OIG) Draft Report: "CMS System for Sharing 
Information About Terminated Providers Needs Improvement" 
(OEI-06-12-00031) 
The Centers for Medicare & Medicaid Services (CMS) appreciates the opportunity to review and 
comment on the above-referenced OIG draft report. The purpose of this report is to determine 
the extent to which CMS and state Medicaid agencies reported provider information to the 
Medicaid and Children's Health Insurance Program (CHIP) State Information Sharing System 
(MCSIS), to identify MCSIS records not related to providers who were terminated "for cause," 
and to assess the completeness of provider identifying information in the MCSIS records. 
In accordance with section 6401(b)(2) ofthe Affordable Care Act, CMS is committed to 
facilitating state reporting of Medicaid and CHIP "for cause" termination data. CMS phased out 
MCSIS and transitioned to the OnePT portal on November 25, 2013. The new delivery and 
storage process will allow for state-to-state information on terminated providers to be securely 
shared by way ofthe OnePI portal and is intended for use by CMS, state Medicaid, and CHIP 
staff.  States will be able to view and download Medicare revocations, previous MCSIS data, and 
state terminations. Medicaid termination letters will also be available for download through the 
new system. 
We appreciate OIG's efforts in working with CMS to ensure that the system for sharing 
information about terminated providers is useful and effective for state Medicaid agencies.  Our 
response to each of the OIG recommendations follows. 
OIG Recommendation 
The OIG recommends that CMS, to make complete information available, require each state 
Medicaid agency to report all terminated providers. 
CMS's Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)  21     
 
 
   
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     22      
   
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     23      
ACKNOWLEDGMENTS 
This report was prepared under the direction of Kevin K. Golladay,  
Regional Inspector General for Evaluation and Inspections in the Dallas 
regional office; Blaine Collins, Deputy Regional Inspector General; and 
Ruth Ann Dorrill, Deputy Regional Inspector General.  
Deborah Cosimo served as the team leader for this study, and 
Maria Balderas served as the lead analyst.  Central office staff who 
provided support include Clarence Arnold, Kevin Manley, and 
Christine Moritz.  
We would also like to acknowledge the contributions of other Office of 
Evaluation and Inspections regional office staff, including Nathan Dong.  
CMSs Process for Sharing Information About Terminated Providers Needs Improvement (OEI-06-12-00031)     24      
Office of Inspector General
http://oig.hhs.gov  
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as  
amended, is  to protect the integrity of the Department of  Health and Human Services  
(HHS)  programs, as well as the health and welfare of beneficiaries  served by those 
programs.  This statutory mission  is  carried  out through  a nationwide network  of  audits, 
investigations, and inspections conducted by the  following operating components: 
Office of Audit Services 
The Office  of  Audit Services  (OAS) provides auditing services  for HHS, either by  conducting  
audits  with its own audit resources or by  overseeing  audit work done by others.  Audits  
examine the performance of HHS programs and/or its grantees and contractors in carrying  
out their respective responsibilities and are intended  to provide independent assessments of 
HHS programs and operations.  These assessments help reduce waste, abuse, and  
mismanagement and promote economy and efficiency  throughout  HHS. 
Office of Evaluation and Inspections 
The Office  of  Evaluation and Inspections (OEI)  conducts national evaluations to  provide 
HHS, Congress, and the public with timely, useful, and reliable information on significant 
issues.  These evaluations focus on preventing fraud,  waste, or abuse  and promoting  
economy, efficiency, and effectiveness of departmental programs.  To promote impact, OEI 
reports also present practical recommendations for improving program operations.  
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations  
of  fraud and misconduct  related to HHS programs, operations, and beneficiaries.  With 
investigators working in all 50 States and the District of Columbia, OI  utilizes its resources 
by actively  coordinating with the Department  of Justice  and other Federal, State, and local 
law enforcement authorities.  The investigative efforts of OI often lead to  criminal 
convictions, administrative sanctions,  and/or  civil monetary  penalties.  
Office of Counsel to the Inspector General 
The Office of Counsel to the  Inspector  General (OCIG) provides general legal services to 
OIG, rendering  advice and opinions on HHS programs and operations and  providing all  
legal support for OIGs  internal operations.  OCIG represents  OIG in all civil and 
administrative fraud and abuse cases involving HHS programs,  including False Claims Act, 
program exclusion, and civil monetary penalty cases.  In  connection with these cases, OCIG 
also negotiates and monitors corporate integrity agreements.  OCIG renders advisory 
opinions, issues compliance program  guidance, publishes fraud alerts, and provides other  
guidance  to  the health care industry concerning the anti-kickback statute and other  OIG  
enforcement authorities.