U.S. Department of Health and Human Services 
 Office of Inspector General 
 
Issue Brief 
 
 August 2020, OEI-03-19-00430 
 
CMSs Encounter Data Lack Essential Information That Medicare 
Advantage Organizations Have the Ability to Collect 
This issue brief provides results from our evaluation of Medicare 
Key Results 
Advantage organizations (MAOs) collection and submission of 
National Provider Identifiers (NPIs) for physicians and nonphysician  Identifiers for ordering providers 
practitioners who order and/or refer durable medical equipment,  are an essential tool for 
prosthetics, orthotics, and supplies (DMEPOS); clinical laboratory  safeguarding program integrity but 
are largely missing from the 
services; imaging services; and home health services for Medicare 
encounter data despite evidence 
Advantage (MA) enrollees.  (In this issue brief, we refer to these 
that many Medicare Advantage 
providers as ordering providers.) 
organizations can, and do, already 
Why OIG Did This Review   collect this information.   
NPIs for ordering providers are essential for safeguarding the 
program integrity of DMEPOS, clinical laboratory services, imaging services, and home health services in 
Medicare.  (In this issue brief, we refer to clinical laboratory services as laboratory services.)  For these 
items and services, NPIs are critical for identifying inappropriate billing and ordering patterns among 
providers and investigating fraud and abuse.  Both the Centers for Medicare & Medicaid Services (CMS) 
and the Office of Inspector General (OIG) rely on NPIs for ordering providers to conduct oversight and 
pursue fraud investigations.  Prior OIG work found that ordering provider NPIs were absent from 
63 percent of MA encounter records for DMEPOS and for laboratory, imaging, and home health 
services, and recommended that CMS establish and enforce requirements for MAOs to submit ordering 
provider NPIs for these types of items and services.  Findings from our survey of MAOs may be useful as 
CMS weighs the program integrity benefits of requiring NPIs for ordering providers against the 
potential burden that MAOs would experience from establishing and enforcing these requirements. 
How OIG Did This Review 
To determine the extent to which MAOs submitted ordering provider NPIs on encounter records for 
DMEPOS and for laboratory, imaging, and home health services, we extracted and analyzed 
2018 MA encounter data from CMSs Integrated Data Repository in February 2020.  We also sent an 
online survey to a stratified random sample of 200 MAOs.  We received responses from 179 MAOs.   
What OIG Found 
CMSs MA encounter data continue to lack ordering provider NPIs on records for DMEPOS and for 
laboratory, imaging, and home health services.  However, we found that almost all MAOs have data 
systems that are able to receive and store these NPIs when providers submit them to MAOs on claims 
or encounter records.  In addition, a substantial portion of MAOs reported that providers are already 
submitting the ordering provider NPIs on claims or encounter records for DMEPOS, laboratory services, 
and imaging services.  Further, a majority of MAOs require NPIs to be submitted for their other lines of 
business (such as commercial and private health insurance, Medicaid, and the Childrens Health 
Insurance Program).  Finally, almost half of MAOs believe that NPIs for ordering providers are critical for 
combating fraud.  What OIG Recommends 
OIG recommends that CMS require MAOs to submit the ordering provider NPI on encounter records for 
DMEPOS and for laboratory, imaging, and home health services; and establish and implement reject 
edits that (1) reject encounter records in which the ordering provider NPI is not present when required 
and (2) reject encounter records that contain an ordering provider NPI that is not a valid and active NPI 
in the National Plan and Provider Enumeration System (NPPES) registry.  CMS concurred with the first 
recommendation, but did not concur with the second recommendation.    BACKGROUND
 
 
DMEPOS and laboratory, imaging, and home health 
services are vulnerable to fraud 
DMEPOS and laboratory, imaging, and home health services have a history of being 
vulnerable to fraud.  For these items and services that are at high risk for fraud, ordering 
providers should act as gatekeepers against inappropriate payments, as they determine 
whether these items and services are medically necessary and appropriate for the 
patients they treat.  Having access to identifiers for these ordering providers is essential 
for effective oversight of these items and services; analysis of ordering provider NPIs is 
critical for identifying inappropriate billing and ordering patterns among providers.  Both 
CMS and OIG rely on these identifiers to conduct oversight and enforcement work.  For 
example, NPIs for ordering providers were integral in identifying DMEPOS suppliers that 
allegedly paid kickbacks to providers who ordered medically unnecessary DMEPOS for 
Medicare beneficiaries, potentially defrauding taxpayers out of $900 million.1  In addition, 
a separate scheme involved a laboratory that allegedly paid kickbacks to ordering 
providers and fraudulently billed Medicare $1.7 billion for genetic tests that were not 
medically necessary.2 
CMS requires NPIs for ordering providers in the Medicare 
fee-for-service program, but not in MA 
In the Medicare fee-for-service program, CMS requires NPIs for ordering providers on 
claims for DMEPOS and for laboratory, imaging, and home health services.  Since 2014, 
CMS does not pay such claims unless the claim has a valid NPI for an ordering provider.3  
In addition, CMS uses NPIs for ordering providers as part of its analyses to identify actual 
or potential payment errors or fraud.  Examples of these analyses may include identifying 
telemedicine providers who order unlikely combinations of items or services that are at 
high risk for fraud (e.g., orthotics, genetic testing, and compound medicines) or 
identifying providers who have ordered unusually high volumes of items or services.   
For MA, MAOs submit encounter records to CMS that contain information regarding 
services provided for MA beneficiaries.  CMS has not designated the ordering providers 
NPI as a required data element for encounter data.4  CMS does perform an 
informational edit during the submission process for DMEPOS encounter records.  (An 
edit is an automated system process.)  This informational edit notifies MAOs when an 
ordering provider NPI is missing from DMEPOS encounter records, but it does not reject 
these records.   
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430  Background | 3  Prior OIG work found that NPIs for ordering providers were 
frequently absent from 2014 encounter data 
Prior OIG work found that NPIs for ordering providers were absent from 63 percent of 
MA encounter records for DMEPOS and for laboratory, imaging, and home health 
services from the first quarter of 2014.5  As a result, OIG recommended that CMS 
establish and implement what are known as reject edits for certain types of encounter 
records, such as those related to DMEPOS and laboratory, imaging, and home health 
services.  Such edits would (1) reject records in which the NPI and/or name for the 
ordering provider is not present; and (2) reject records that contain an ordering provider 
NPI that is not a valid and active NPI in the NPPES registry.6   
CMS did not concur with this recommendation, noting that because MAOs do not always 
require ordering provider NPIs on the claims that providers submit to them, MAOs often 
do not have these NPIs available to submit to CMS.  CMS stated that it would explore 
whether identifiers for ordering providers are necessary for program integrity purposes 
and would consider requiring them in the future.  In January 2020, CMS stated that 
ordering provider NPIs are essential for the program integrity of DMEPOS encounters in 
the MA program.7  CMS also stated that the lack of ordering provider information 
provided in MAOs encounter records for laboratory services, imaging services, and 
home health services hinders program integrity efforts.  Despite recognizing the 
importance of NPIs for ordering providers, CMS has yet to implement OIGs 
recommendation. 
 
 
 
 
 
 
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430  Background | 4   
 
RESULTS 
 
Ordering provider NPIs continue to be frequently absent from 
the MA encounter data 
Overall, 60 percent of the 2018 encounter records for DMEPOS and for laboratory, 
imaging, and home health services were missing an NPI for an ordering provider, 
whichalthough not currently requiredis recognized by CMS and OIG as essential to 
effective program oversight.  Ordering provider NPIs were absent from records for 
DMEPOS at a greater rate than from records for the three types of services, as shown in 
Exhibit 1.  In total, of the 25.4 million records for DMEPOS in 2018, 18.1 million 
(71 percent) were missing an NPI for an ordering provider.   
Exhibit 1: Ordering provider NPIs were often missing from the 2018 encounter data  
  
 
 
 
 
 Source:  OIG analysis of 2018 MA encounter data.   
 
Almost all MAOs can receive and store ordering provider NPIs 
when providers submit them 
Overall, 98 percent of MAOs in our sample (176 of 179) 
Exhibit 2: Almost all MAOs can 
reported that their data systems can receive and store 
collect ordering provider NPIs 
ordering provider NPIs when providers submit them to 
MAOs on their claims or encounter records, as shown in 
Exhibit 2, either always (123 MAOs) or sometimes 
(53 MAOs).8  (We use the term claims/encounters in 
this report to refer to these claims or encounter 
records.)  Only 2 percent of MAOs stated that their 
systems are not capable of receiving and storing this 
information.  Among the 24 MAOs that did not submit 
any ordering provider NPIs to the 2018 MA encounter 
  data for all 4 areas, 17 stated that their data systems are 
Source:  OIG analysis of MAO responses to 2020 
always able to receive and store ordering provider NPIs 
OIG survey. 
  on MA claims/encounters and another 4 could receive 
and store these NPIs sometimes. 
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect  
OEI-03-19-00430  Results | 4   
The majority of MAOs reported that providers submit ordering 
provider NPIs on at least half of the claims/encounters for 
DMEPOS, laboratory services, and imaging services 
Fifty-eight percent of MAOs in our sample (103 of 179) reported that suppliers or 
providers of DMEPOS, laboratory services, and imaging services submit an ordering 
provider NPI on at least half of MA 
Exhibit 3: Many MAOs already collect 
claims/encounters, as shown in Exhibit 3.  
ordering provider NPIs 
However, most of these MAOs did not 
submit all these ordering provider NPIs to 
the MA encounter data, as CMS does not 
require them to do so.  Among these 
103 MAOs, only 25 included ordering provider 
NPIs on at least half of their records for 
DMEPOS, laboratory services, and imaging 
services in the 2018 MA encounter data.    
Many of the MAOs that lacked ordering    
provider NPIs in their encounter data        
reported having these NPIs on their MA 
Source:  OIG analysis of MAO responses to  
claims/encounters.  There were 57 MAOs 
2020 OIG survey. 
that did not submit any ordering provider   
NPIs for on records for DMEPOS, laboratory services, and imaging services in the 2018 
encounter data.  Of these, 27 MAOs (47 percent) reported that providers submit ordering 
provider NPIs on at least half of their MA claims/encounters for each of these 3 areas.   
Compared to suppliers or providers of DMEPOS, laboratory services, and imaging 
services, providers of home health services submitted ordering provider NPIs to MAOs 
less frequently.  Across all 179 MAOs in our sample, the median percentage of MA 
claims/encounters for which providers submitted ordering provider NPIs to MAOs 
ranged from 26 to 80 percent, as shown in Exhibit 4. 
Exhibit 4: Median 
percentage of 
claims/encounters for 
which providers 
submitted ordering 
provider NPIs 
 
 
Source:  OIG analysis of MAO responses to 2020 OIG survey. 
 
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect  
OEI-03-19-00430  Results | 5   
Many MAOs believe that ordering provider NPIs are critical for 
combating fraud and require these NPIs in their other lines of 
business 
Forty-four percent of MAOs (78 of 179) reported that the ordering provider NPI is a 
critical piece of data for preventing and detecting fraud and abuse related to DMEPOS, 
laboratory services, imaging services, and/or home health services.  Furthermore, among 
the 163 MAOs that had other lines of business (such as commercial and private health 
insurance, Medicaid, and the Childrens Health Insurance Program), 83 MAOs 
(51 percent) require providers to submit ordering provider NPIs on claims/encounters for 
another line of business.  Specifically, these MAOs most often required ordering provider 
NPIs for DMEPOS and for laboratory, imaging, and home health services in their 
Medicaid lines of business. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect  
OEI-03-19-00430  Results | 6   
 
CONCLUSION AND RECOMMENDATIONS 
 
 
In a January 2020 memo, CMS acknowledged that a lack of ordering provider information 
in encounter records for DMEPOS and laboratory, imaging, and home health services 
hinders potential program integrity efforts.9  In Medicare fee-for-service, CMS does not 
pay claims for these items or services unless the claim has a valid NPI for an ordering 
provider.  In addition, ordering provider NPIs are critical for identifying patterns of 
questionable billing and pursuing fraud investigations in service areas that have a history 
of being vulnerable to fraud.  
However, in the MA programwhich covers a third of Medicare beneficiariesCMS has 
not designated the ordering provider NPI as a required data element for encounter data.  
As a result, CMS continues to lack information on ordering provider NPIs in the MA 
encounter data for these items and services that are at high risk for fraud.  This hinders 
CMSs and others use of the ordering provider NPIs as a program integrity tool, which 
leaves the MA program vulnerable to losses from fraudulent providers and suppliers.   
OIG previously recommended that CMS establish and enforce requirements for MAOs to 
submit ordering provider NPIs for certain types of encounter records, such as those for 
DMEPOS and for laboratory, imaging, and home health services.  Findings from our recent 
survey of MAOs may be useful as CMS weighs the program integrity benefits of requiring 
ordering provider NPIs against the potential burden that MAOs would experience from 
establishing and enforcing these requirements.  We found that almost all MAOs reported 
that their data systems are able to receive and store ordering provider NPIs when 
providers submit them on MA claims/encounter.  In addition, almost half of MAOs 
reported that providers submit NPIs for ordering providers on at least half of the MA 
claims/encounters for DMEPOS, laboratory services, and imaging services.   
 
Finally, many MAOs believe that ordering provider NPIs are a critical piece of data for 
preventing and detecting fraud and abuse.  In fact, among MAOs that have other lines of 
business (such as commercial and private health insurance, Medicaid, and the Childrens 
Health Insurance Program), half require providers to submit ordering provider NPIs on 
claims/encounters for another line of business.   
Taken together, our findings indicate that (1) MAOs have data systems that are able to 
collect ordering provider NPIs; (2) a majority of MAOs already collect ordering provider 
NPIs on a portion of their claims/encounters; and (3) many MAOs agree that collecting 
ordering NPIs is important and often collect them for their other lines of business. 
 
 
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect  
OEI-03-19-00430                             Conclusion and Recommendations | 7   
We continue to recommend that CMS:   
Require MAOs to submit the ordering provider NPI on encounter 
records for DMEPOS and for laboratory, imaging, and home health 
services.   
Establish and implement reject edits that (1) reject encounter 
records in which the ordering provider NPI is not present when 
required and (2) reject encounter records that contain an ordering 
provider NPI that is not a valid and active NPI in the NPPES registry. 
   
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430         Conclusion and Recommendations | 8   
 
AGENCY COMMENTS AND OIG RESPONSE 
 
 
 
CMS concurred with our first recommendation and is exploring implementation of a 
requirement for MAOs to submit the ordering, referring, or certifying provider NPI on 
encounter data records for DMEPOS and for laboratory, imaging, and home health 
services.  CMS did not concur with our second recommendation and stated that it would 
be premature to establish and implement reject edits prior to the exploration of a 
requirement discussed in the first recommendation.  
OIG understands that CMS must implement a requirement for MAOs to submit the 
ordering provider NPIs on applicable encounter records prior to its implementation of 
edits that reject encounter records lacking these required NPIs.  However, in order to 
utilize ordering provider NPIs for preventing and detecting fraud and abuse, it is 
important for CMS to implement reject edits that ensure these NPIs are present and valid 
when required.  Therefore, OIG continues to recommend that CMS establish and 
implement reject edits once it requires MAOs to submit the ordering provider NPI on 
encounter records for DMEPOS and for laboratory, imaging, and home health services. 
Appendix A provides the full text of CMSs comments. 
 
   
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430  Agency Comments and OIG Response | 9   
 
APPENDIX A 
 
Agency Comments 
 
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430  Appendix A | 10   
 
 
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430  Appendix A | 11   
 
METHODOLOGY 
 
 
Analysis of the 2018 MA Encounter Data 
We extracted MA encounter records from CMSs Integrated Data Repository in February 
2020 for all records with dates of service in 2018 to determine the extent to which MAOs 
submitted the ordering provider NPI on encounter records for DMEPOS and for 
laboratory, imaging, and home health services.10  Data elements for ordering provider 
NPIs are located in both the header and service line portion of a service record.  For 
DMEPOS, laboratory, and imaging records, we considered an encounter record to be 
missing an ordering provider NPI if it was missing from the header as well as from all the 
service lines.  For home health records, we considered an encounter record to be missing 
an ordering provider NPI if it was missing all of the three following data elements from 
the header and all service lines: (1) ordering provider NPI, (2) attending provider NPI, and 
(3) other provider NPI.11 
MAO Survey 
From February to March 2020, we administered an online survey to a stratified random 
sample of 200 MAOs.  We selected MAOs that were (1) active as of January 1, 2017, and 
continued to be active in 2020;12 (2) offered coordinated care plans, medical savings 
accounts, or private fee-for-service plans;13 and (3) submitted 2017 encounter records for 
DMEPOS, laboratory services, imaging services, and/or home health services.14  The first 
stratum included all 33 of the MAOs that did not have an ordering provider NPI on any of 
their 2017 encounter records.  The second stratum included 167 MAOs randomly selected 
from the 361 MAOs that had at least 1 ordering provider NPI on their 2017 encounter 
records.  Analysis of the survey data was based on the responses of 179 MAOs, 29 from 
the first stratum and 150 from the second stratum.  
Limitations 
Our sample of MAOs included all of the MAOs that did not submit a single ordering 
provider NPI to the 2017 encounter data, which makes our survey results 
over-representative of MAOs that do not submit ordering provider NPIs to CMS.15  In 
addition, when MAOs reported the percentage of MA claims/encounter records on which 
suppliers or providers submit ordering provider NPIs for each service type, most of these 
percentages were estimates.  Finally, our methods for identifying ordering provider NPIs 
for home health services in the 2018 encounter data counted all attending provider NPIs 
as ordering provider NPIs, which may have resulted in overestimates of the prevalence of 
ordering provider NPIs on home health records because not all attending providers are 
necessarily the provider who certified/recertified the patients eligibility for a home 
health service.   
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430                       Methodology | 12   
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. 
   
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430                       Methodology | 13   
 
ACKNOWLEDGMENTS AND CONTACT 
 
Acknowledgments 
Maria Johnson served as the team leader for this study.  Others in the Office of 
Evaluation and Inspections who conducted the study include Robert Kirkner.  Office of 
Evaluation and Inspections staff who provided support include Joe Chiarenzelli, 
Althea Hosein, and Christine Moritz.  
This report was prepared under the direction of Linda Ragone, Regional Inspector 
General for Evaluation and Inspections in the Philadelphia regional office, and 
Joanna Bisgaier, Deputy 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 
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430                    Acknowledgments and Contact | 14   
 
E  NDNOTES 
 
 
1 OIG, Media Materials: Nationwide Brace Scam, April 2019.  Accessed at https://www.oig.hhs.gov/newsroom/media-
materials/2019/bracescam/ on December 18, 2019. 
2 CMS, Operation Double Helix Takes Action in One of the Largest Health Care Fraud Schemes Ever Charged, September 2019.  
Accessed at https://www.cms.gov/About-CMS/Components/CPI/CPI-Spotlight.html on December 18, 2019. 
3 CMS, MLN Matters Number SE1305 Revised, Full Implementation of Edits on the Ordering/Referring Providers in Medicare 
Part B, DME, and Part A Home Health Agency (HHA) Claims (Change Requests 6417, 6421, 6696, and 6856), October 2015.  
Accessed at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-
MLN/MLNMattersArticles/Downloads/SE1305.pdf on April 13, 2020. 
4 CMS, Encounter Data Submission and Processing Guide, March 2019.  Accessed at 
https://www.csscoperations.com/internet/csscw3_files.nsf/F/CSSCED_Submission_Processing_Guide_20190321.pdf/$FILE/ED_Su
bmission_Processing_Guide_20190321.pdf on June 25, 2020.  
5 OIG, Medicare Advantage Encounter Data Show Promise for Program Oversight, But Improvements Are Needed,  
OEI-03-15-00060, January 2018. 
6 NPPES assigns NPIs; maintains and updates information about health care providers with NPIs; and disseminates the NPI 
Registry and NPPES downloadable files.  See CMS, Medicare Learning Network, NPI: What You Need to Know, December 2016.  
Accessed at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/NPI-
What-You-Need-To-Know.pdf on June 1, 2020.   
7 CMS, Referring Provider Identifiers for Medicare Part C Durable Medical Equipment (DME) Encounters, January 2020.  
8 We use the term MAO to refer to a unique MA contract. 
9 CMS, Referring Provider Identifiers for Medicare Part C Durable Medical Equipment (DME) Encounters, January 2020. 
10 For encounter records with dates of service in 2018, we identified DMEPOS records as records with claim type code 4800 and 
at least one service line with a Berenson-Eggers Type of Service (BETOS) codes D1A through D1G; laboratory records as 
records with claim type code 4700 and at least one service line with BETOS codes T1A through T1H; imaging records as records 
with claim type code 4700 and at least one service line with BETOS codes I1A through I4B; and home health records as records 
with claim type codes 4032, 4033, or 4034.    
11 For Medicare fee-for-service home health claims, CMS requires both the attending physician NPI and other provider NPI 
fields unless the patients designated attending physician is the same as the physician who certified/recertified the patients 
eligibility, in which case only the attending physician is required to be reported.  The health care industry often uses the terms 
ordered, referred, and certified interchangeably.  See CMS, Medicare Claims Processing Manual, Pub. No. 100-04, ch. 10, 
 40.2.  Accessed at https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c10.pdf on 
October 1, 2019. 
12 We used the 2017 Contract Information Extract from CMSs Health Plan Management System to determine MAOs with 
contract dates effective as of January 1, 2017, and we used the 2020 Contract Information Extract to confirm which MAOs 
continued to be active in 2020.  We then used the 2017 encounter data to stratify MAOs based on their submission of ordering 
provider NPIs on 2017 encounter records.    
13 We did not include MAOs that offer cost plans, demonstration plans, or program of all-inclusive care for the elderly (PACE) 
organizations, as these may have different compliance program requirements. 
 
 
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430                              Endnotes | 15   
 
14 For encounter records with dates of service in 2017, we identified DMEPOS records as records with claim type code 4800; 
laboratory records as records with claim type code 4700 and at least one service line with BETOS codes T1A through T1H; 
imaging records as records with claim type code 4700 and at least one service line with BETOS codes I1A through I4B; and 
home health records as records with claim type codes 4032, 4033, or 4034.    
15 Of the 33 MAOs that did not submit any ordering provider NPIs on 2017 encounter records, 26 did not submit any ordering 
provider NPIs on 2018 encounter records for the 4 items and services.    
Issue Brief: CMSs Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability To Collect 
OEI-03-19-00430                              Endnotes | 16