Department of Health and Human Services

OFFICE OF 

INSPECTOR GENERAL 

M  P
EDICARE S  ROGRAM 

S C : 

AFEGUARD  ONTRACTORS
P E
ERFORMANCE  VALUATION 

R
EPORTS

Daniel R. Levinson

Inspector General 

March 2006

OEI-03-04-00050
 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 all 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 in order to reduce waste, abuse, and mismanagement and to promote economy and 
efficiency throughout HHS. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts management and program evaluations 
(called inspections) that focus on issues of concern to HHS, Congress, and the public.  The 
findings and recommendations contained in the inspections generate rapid, accurate, and up-to-
date information on the efficiency, vulnerability, and effectiveness of departmental programs.  
OEI also oversees State Medicaid Fraud Control Units which investigate and prosecute fraud and 
patient abuse in the Medicaid program. 
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative 
investigations of allegations of wrongdoing in HHS programs or to HHS 
beneficiaries and of unjust enrichment by providers.  The investigative efforts of OI 
lead to criminal convictions, administrative sanctions, 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 
in OIG's internal operations.  OCIG imposes program exclusions and civil monetary penalties on 
health care providers and litigates those actions within HHS.  OCIG also represents OIG in the 
global settlement of cases arising under the Civil False Claims Act, develops and monitors 
corporate integrity agreements, develops compliance program guidances, renders advisory 
opinions on OIG sanctions to the health care community, and issues fraud alerts and other 
industry guidance.    E X E C U T I V E   S U M M A R Y  

OBJECTIVES 
To determine (1) the extent and type of information provided in 
performance evaluation reports about program safeguard contractors 
(PSC) results related to detecting and deterring fraud and abuse, and 
(2) whether the performance evaluation reports are issued on time. 
BACKGROUND 
The Health Insurance Portability and Accountability Act of 1996 (Public 
Law 104-191), section 202 authorized the Centers for Medicare & 
Medicaid Services (CMS) to contract with entities to fulfill program 
integrity functions for the Medicare program and required a competitive 
process for awarding contracts.  CMS entered into the first contract 
under this authority in 1999.  Entities awarded such contracts are 
called PSCs. Once under contract, PSCs are then awarded task orders 
to carry out specific duties. 
There are two major types of PSC task orders: one for full service 
benefit integrity work and another for specific projects. A benefit 
integrity task order includes the full range of fraud and abuse detection 
and deterrence work (hereinafter fraud and abuse work or activities) 
previously performed by specific carriers and/or fiscal intermediaries.  
As of July 2003, CMS completed the transfer of all fraud and abuse 
work from carriers and fiscal intermediaries to PSCs, with the exception 
of fraud and abuse work performed by three regional medical equipment 
carriers. CMS expects the transition of fraud and abuse work from the 
three medical equipment carriers to be completed by March 1, 2006.  
This report focuses on benefit integrity task orders.  From 
November 1999 to November 2004, CMS allocated $261.4 million for a 
total of 17 benefit integrity task orders.  These task orders were 
awarded to seven PSCs, and each of these task orders has been 
renewed from one to four times. 
Since the first benefit integrity task order was awarded, CMS has 
used four different methods of evaluating PSC performance. 
We requested from CMS its most current performance evaluation report 
for each of the 17 benefit integrity task orders. We reviewed these 
evaluation reports to determine whether they contained information 
about PSC achievements in relation to nine standard activities PSCs 
perform to detect and deter fraud and abuse.  The nine activities are 
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described in three guiding documents for PSCs:  the benefit integrity 
task order, the PSC Umbrella Statement of Work, and the Medicare 
Program Integrity Manual.  We determined whether these nine 
activities were addressed in the evaluation reports in terms of results 
or process and procedures.  The nine activities are: 
1.  Fraud Case Development 
2.  National/Regional Data Analysis 
3.  Law Enforcement Support 
4.  Medical Review to Support Fraud and Abuse Cases 
5.  Civil Monetary Penalties and Other Administrative Actions 
6.  Submit Proposed Fraud Alerts 
7.  Fraud Prevention/Detection Education 
8.  Fraud Complaint Processing 
9.  Incentive Reward Program 
We also requested data from CMS to determine the timeliness of the 
evaluation process for the period November 1999 to November 2004. 
FINDINGS 
Performance evaluation reports provided limited quantitative data 
about program safeguard contractors achievements at detecting and 
deterring fraud and abuse.  Of the 17 performance evaluation reports we 
reviewed, several did not contain results, quantitative or qualitative, for  
1 or more of the 9 fraud and abuse activities.  Eight performance 
evaluation reports did not address results regarding Medical Review to 
Support Fraud and Abuse Cases.  In addition, nine reports did not 
address results regarding Fraud Complaint Processing, and nine reports 
did not address results regarding Fraud Prevention/Detection Education.   
The majority of results-oriented comments did not address outcomes of 
fraud and abuse work, but instead were standardized phrases addressing 
the quality of the work (e.g., case files appear complete, timely, and 
appropriate). 
Fifteen of 118 results-oriented comments (13 percent) were quantitative.  
These 15 comments were spread across 8 of the 17 evaluation reports we 
reviewed.  Thus, evaluation reports provided limited quantitative data 
measuring PSC efforts or achievements related to detecting and deterring 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  ii  E X E C U T I V E   S U M M A R Y  
fraud and abuse.  For example, only one evaluation report contained the 
number of open and pending proactive fraud cases, only one contained the 
amount of money saved as a result of PSC initiatives, and only one 
included the number of requests for support received from law 
enforcement agencies.  Almost half of the quantitative comments 
regarding PSC performance (6 of 15) were negative.  
Sixteen of seventeen reports did not contain information on all required 
fraud and abuse detection and deterrence activities. Only 1 of 17 
evaluation reports contained information on all of the standard fraud 
and abuse activities required by the associated task order. The 
remaining 16 evaluation reports did not contain any information on 2 to 
7 required activities.  Two activities, Submit Proposed Fraud Alerts and 
Incentive Reward Program, were not addressed in any evaluation report 
for task orders requiring these activities.  
Seventy-two percent of evaluation reports were issued on time. Since 
the first benefit integrity task order was awarded in 1999, 72 percent of 
all final evaluation reports (23 of 32) met the reporting timeframes set 
forth in the then governing PSC Umbrella Statement of Work.  
Twenty-eight percent of the final reports (9 of 32) did not.  The PSC 
Umbrella Statement of Work that governed these 32 final reports 
required that final performance evaluation reports would be issued   
2 months after the task order performance period ends.  Of the nine 
final reports that were issued late, seven were from 20 days to 6 months 
late, one was almost 19 months late, and one was 38 months late. 
Only 5 of 32 final reports were issued 3 months before the task order 
ended. It is at this point in time3 months before the performance 
period endsthat CMS is required to notify the PSC whether CMS 
intends to renew the contract.  CMS issued revisions to the PSC 
Umbrella Statement of Work in 2004. The revisions state that CMSs 
final evaluation reports of PSC performance will be issued 3 months 
before the task order performance period ends. 
The unavailability of milestone dates for the production of evaluation 
reports prevented us from identifying where delays occurred in the 
evaluation process.  Once evaluation reports are finalized, the online 
evaluation system used by CMS deletes the dates of earlier milestones, 
such as issuance dates of draft reports.  Based on data CMS provided, it 
appears that CMS does not have a systematic means to track evaluation 
events other than this online system.  Thus CMS is limited in its ability 
to retrospectively determine where delays occurred. 
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RECOMMENDATIONS 
The primary responsibility for detecting and deterring fraud and abuse 
in the Medicare program was transferred from carriers and fiscal 
intermediaries to PSCs.  To determine how well PSCs are performing, 
CMS utilizes the contractor performance evaluation as an important 
tool. 
However, performance evaluation reports contained minimal 
information about PSC efforts to detect and deter fraud and abuse.  
Because these reports are limited in their description of the results 
PSCs may be achieving, they provide limited information on which to 
base task order renewal decisions. 
To improve the evaluation process, we recommend that CMS: 
Address program safeguard contractor results in their performance 
evaluation reports.  CMS should describe PSC results in identifying 
and preventing fraud and abuse in the evaluation reports to 
demonstrate the adequacy of PSC performance. Using quantitative as 
well as qualitative data to describe results would provide a more 
comprehensive picture of PSC performance and provide valuable data 
for making renewal decisions.  If, for example, certain PSC activities are 
saving money for the Medicare program, the activity and the amount of 
money saved should be included in the performance evaluation reports. 
Provide information about required program safeguard contractor 
activities in performance evaluation reports.  The activities CMS 
specifically lists in the benefit integrity task orders and that PSCs are 
required to perform should be evaluated in the performance evaluation 
reports. The primary responsibility of PSCs is to detect and deter fraud 
and abuse; therefore, the performance evaluation reports should include 
information on whether fraud and abuse detection and deterrence 
activities were performed and how effectively they were performed.  
Take steps to ensure that all draft and final performance evaluation 
reports are issued in accordance with the current timetable. CMS 
should aim to issue 100 percent of the performance evaluation 
reports on time.  Moreover, by following the timetable in the current 
revised PSC Umbrella Statement of Work, evaluation reports 
would be available for CMS when the task order renewal notice is 
due.  This would allow CMS to make more informed decisions when 
renewing a task order with a contractor.  
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  iv  E X E C U T I V E   S U M M A R Y  
Establish a means to track and save evaluation milestone dates. 
The online system CMS uses for PSC evaluations only holds 
evaluation milestone dates temporarily.  A system that tracks and 
saves all milestone dates would help CMS identify where delays 
occur so that improvements can be made to the performance 
evaluation process.    
AGENCY COMMENTS 
CMS concurred with Office of Inspector General (OIG) 
recommendations to:  (1) ensure that all draft and final performance 
evaluation reports are issued in accordance with the current timetable; 
and (2) establish a means to track and save evaluation milestone dates. 
CMS concurred only in part with the OIG recommendation to address 
results in PSC performance evaluation reports.  CMS believes that 
quantifying PSC output could create perverse incentives and undermine 
the value of a PSCs work.  CMS stated that it has been cautioned by 
prosecutors that cases could be jeopardized if the entity assessing the 
facts of the investigation were rewarded for sheer volume of case 
referrals or required to meet a quota of case referrals.  CMS, therefore, 
looks to the timeliness of PSC performance, the thoroughness of PSC 
work, and PSC responsiveness to law enforcement agencies to 
determine PSC effectiveness in fraud fighting.  However, CMS stated 
that the current OIG study underscored the benefits that could be 
gained by capturing units of work that PSCs perform.  CMS stated that 
it has already begun moving forward on the OIG recommendation by 
improving the means by which it gathers information about the outcome 
of PSC activities and will collect an array of quantitative and 
qualitative measurements. 
CMS concurred in part with OIGs recommendation to provide 
information about required PSC activities in performance evaluation 
reports.  CMS stated that every aspect of PSC performance should be 
scrupulously reviewed and evaluated. However, it stated that resources 
limit the level and intensity of scrutiny that can reasonably be applied 
to PSCs and it will focus performance evaluations on the primary PSC 
activities. Furthermore, CMS will reevaluate the listing of activities 
required in the PSC Statement of Work in order to emphasize the most 
crucial activities.   
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  v  E X E C U T I V E   S U M M A R Y

OFFICE OF INSPECTOR GENERAL RESPONSE 
OIG is pleased that our review helped underscore the benefits that 
could be gained by a more complete review of PSC performance, and we 
appreciate that CMS is already moving forward on our 
recommendations.  While OIG understands CMSs concerns about 
creating perverse incentives, we are not advocating that a system of 
numeric quotas be implemented. Rather, OIG is recommending that 
evaluation reports include the level of activity and results that PSCs 
have achieved in combating fraud in the Medicare program. OIG 
continues to believe that these types of measures are necessary to 
accurately assess the effectiveness of the PSCs fraud-fighting efforts.   
CMS commented that resources sometimes limit the level and intensity 
of scrutiny CMS can give to all PSC activities.  While this is 
understandable, OIG believes that activities listed in PSC task orders 
should be addressed in performance evaluation reports. 
OIG looks forward to working with CMS in its continuing efforts to 
improve the PSC review process. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  vi    T A B L E   O F   C O N T E N T S  

EXECUTIVE SUMMARY ......................................... i

INTRODUCTION ................................................ 1 

FINDINGS ....................................................... 8 

Reports provided few results regarding fraud and abuse  

detection and deterrence activities. . . . . . . . . . . . . . . . . . . . . . . . . .  8

Most reports did not contain information on all fraud 

   and abuse detection and deterrence activities. . . . . . . . . . . . . . . . .  9

Not all reports were issued on time . . . . . . . . . . . . . . . . . . . . . . . .  10

RECOMMENDATIONS ......................................... 12 

Agency Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  13

Office of Inspector General Response. . . . . . . . . . . . . . . . . . . . . . .  14

APPENDIXES .................................................. 15 

Appendix A:  Related Officeo f Inspector GeneralR  eports  . . . . . .  15

Appendix B:  Performance Evaluation Reports Reviewed. . . . . . .  16

Appendix C:  Evaluation CommentsA  ddressing Results  . . . . . . .  17

Appendix D:  Evaluation Comments Addressing Process and

  Procedures  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  19

Appendix E:  Task Order Performance Period Versus  

  Evaluation Period, 19992004 . . . . . . . . . . . . . . . .  21

Appendix F:   	Fraud and Abuse Detection/Deterrence 

  Activities Addressed in Evaluation Reports  . . . . . .  23

Appendix G:  	Timeliness of Performance Evaluation Reports,

  19992004. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  24

Appendix H:	  Agency Comments  . . . . . . . . . . . . . . . . . . . . . . . . . .  26

ACKNOWLEDGMENTS ......................................... 31
   I N T R O D U C T I O N  

OBJECTIVES 
To determine (1) the extent and type of information provided in 
performance evaluation reports about program safeguard contractors 
(PSC) results related to detecting and deterring fraud and abuse, and 
(2) whether the performance evaluation reports are issued on time. 
BACKGROUND 
The first PSC was established in 1999.  As of November 2004, the 
Centers for Medicare & Medicaid Services (CMS) had allocated   
$261.4 million for a total of 17 benefit integrity task orders. These task 
orders were awarded to seven PSCs.  To date, the Office of Inspector 
General (OIG) has not reviewed the performance of PSCs in general nor 
PSC performance of benefit integrity task orders in particular.  In this 
report, we focus on PSC performance evaluation reports of benefit 
integrity task orders. 
Establishment of Program Safeguard Contractors 
The Health Insurance Portability and Accountability Act of 1996 (Public 
Law 104-191), section 202, authorized CMS to contract with entities to 
fulfill program integrity functions for the Medicare program and 
required a competitive process for awarding contracts.  CMS entered 
into the first contract under this authority in 1999.  Entities awarded 
such contracts are called PSCs.  Once under an umbrella contract, PSCs 
are then awarded task orders to carry out specific duties. 
Task Orders and Transfer of Fraud and Abuse Detection/Deterrence Work 
There are two major types of PSC task orders: one for full service 
benefit integrity work and another for specific projects.1  A benefit 
integrity task order includes the full range of fraud and abuse detection 
and deterrence work (hereinafter fraud and abuse work or activities) 
previously performed by specific carriers and/or fiscal intermediaries.  
As of July 2003, CMS had completed the transfer of all fraud and abuse 
work from carriers and fiscal intermediaries to PSCs, with the exception 
of fraud and abuse work performed by three regional medical equipment 
carriers. CMS expects the transition of fraud and abuse work from the 
three medical equipment carriers to be completed by March 1, 2006.    
1 An example of a specific project is generate program safeguard edits.  There are also 
specialty PSC task orders, which address specialized work such as the Comprehensive 
Error Rate Testing Program. 
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In addition to the work transferred from carriers and fiscal 
intermediaries, benefit integrity task orders may also include the 
requirement to match Medicare and Medicaid data to identify potential 
fraud and abuse.  
Benefit integrity task orders are renewable, and as of November 2004, 
each of these task orders had been renewed from one to four times. 
Documents Outlining Program Safeguard Activities 
Three documents govern PSC operations and describe various fraud and 
abuse activities required of PSCs. These documents are the individual 
benefit integrity task orders, the PSC Umbrella Statement of Work, 
and the Medicare Program Integrity Manual.  
Purpose of Performance Evaluation 
The Federal Acquisition Regulation establishes policies for all 
competitively bid Federal contracts including program safeguard 
contracts.  Pursuant to 48 CFR 42.1502(a), CMS is required to evaluate 
PSC performance. 
Moreover, the PSC Umbrella Statement of Work states that CMS 
conducts performance evaluations of PSCs to assess the contractors 
overall performance, determine whether to renew the task orders, 
and/or determine whether to renew the umbrella contract. 
According to CMS staff, in the absence of a final report, the decision to 
renew a task order can be made when the performance evaluation 
report is in draft form because at that point there is no additional 
information to be gathered. 
Evaluation Methods 
Since November 1999, when the first benefit integrity task order was 
awarded to a PSC, CMS has used four methods of evaluating PSC 
performance.  
For the first performance evaluation method, CMS utilized a 
Government task leader to evaluate the task order performance period 
based on their oversight of the PSC and the PSCs periodic deliverables. 
A Government task leader is a CMS employee responsible for overseeing 
the implementation of the task order once it is awarded. 
The second method of evaluating PSC performance utilized a team 
approach whereby CMS Government task leaders and subject matter 
experts (e.g., a benefit integrity, medical review) conducted the 
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evaluation using a review and rating instrument called the Balanced 
Scorecard. 
With the third evaluation method, used in 2004, CMS had outside 
auditors conducting the performance evaluations using an auditing tool 
known as Statement on Auditing Standards (SAS) No. 70, or SAS 70.  
The auditors reported their findings to CMS.  Then CMS staff used a 
review and rating tool called the Record of Evaluation to combine the 
SAS 70 findings with additional findings of CMS staff based on their 
oversight of PSCs. 
In 2005, CMS used a fourth performance evaluation method and had 
CMS staff from central office and regional offices conducting these 
evaluations. According to a CMS representative, the 2005 evaluation 
protocol was designed to review and measure PSC effectiveness, 
efficiency, outcomes, and innovation.  
National Institutes of Health Contractor Performance System 
Regardless of the evaluation method used to assess PCS performance, 
CMS has always used the online National Institutes of Health (NIH) 
Contractor Performance System to report out PSC evaluation findings.  
The NIH Contractor Performance System is used by various Federal 
agencies for evaluating contractors. PSC evaluation data are entered into 
the system by CMS staff in the Program Integrity Group and the Office of 
Acquisitions and Grants Management (formerly Acquisitions and Grants 
Group).  PSCs may enter comments on the draft evaluation report in the 
Contractor Comments section of the system.  
Related Office of Inspector General Reports 
OIG has long been concerned about contractor performance related to 
the detection and deterrence of fraud and abuse in the Medicare 
program. Our previous studies have found that medical equipment 
carriers did not provide data needed to determine the effectiveness of 
their fraud units; that some fiscal intermediary fraud units produced 
few, if any, significant results; and that few carrier fraud units were 
successful in meeting all outcome criteria.  Brief summaries of our 
reports on contractor performance are provided in Appendix A. 
Government Accountability Office Report 
In May 2001, Government Accountability Office (GAO) issued a report, 
Medicare:  Opportunities and Challenges in Contracting for Program 
Safeguards (GAO-01-616), in response to a congressional request. GAO 
was asked to (1) describe CMSs progress in implementing its PSC 
contracting authority and (2) assess whether CMS could improve its 
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management of PSCs to ensure their most effective use. GAO found 
that CMS lacked a long term strategy for incorporating PSCs into the 
Medicare program. In addition, CMS had not established clear, 
measurable performance criteria to assess the PSCs performance on 
individual task orders. 
METHODOLOGY 
We spoke with CMS central office staff about the establishment of PSCs 
and the performance evaluation process for benefit integrity task 
orders. CMS provided us with the original PSC Umbrella Statement of 
Work (effective May 1999) and its two revisions (effective March 2004 
and May 2004). They also provided the April 2004 revision of the 
Medicare Program Integrity Manual, which became effective for all 
PSCs in July 2004, and copies of benefit integrity task orders. 
Evaluation Reports Collected 
To determine how evaluation reports address fraud and abuse activities, 
we collected the most current evaluation reports from CMSs central 
office, as of November 5, 2004, for each benefit integrity task order. 
These 17 reports are the official reports in the NIH Contractor 
Performance System. A list of these reports is provided in Appendix B. 
Analysis of Evaluation Reports 
Identifying a Standard Set of Fraud and Abuse Activities.  We looked for a 
standard set of fraud and abuse activities, i.e., activities that were 
common to current benefit integrity task orders and that would also be 
relevant for future benefit integrity task orders. We reviewed all 
benefit integrity task orders, all versions of the PSC Umbrella 
Statement of Work, and the Medicare Program Integrity Manual. 
A table of 9 activities PSCs should perform to detect and deter fraud 
and abuse was included in 12 of 17 benefit integrity task orders. These 
nine activities became our analysis criteria. They are: 
1.  Fraud Case Development 
2.  National/Regional Data Analysis 
3.  Law Enforcement Support 
4.  Medical Review to Support Fraud and Abuse Cases 
5.  Civil Monetary Penalties and Other Administrative Actions 
6.  Submit Proposed Fraud Alerts 
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7.  Fraud Prevention/Detection Education  
8.  Fraud Complaint Processing 
9.  Incentive Reward Program 
The five task orders that did not contain a table of these nine activities 
did, however, require most of them.  The task orders either referred to 
the activity in the text or referenced the PSC Umbrella Statement of 
Work, which required the activity. These five task orders did not 
mention the Incentive Reward Program, but this activity is described as 
a PSC responsibility in revisions of the PSC Umbrella Statement of 
Work and in the Medicare Program Integrity Manual.  We 
determined that a task order did not require an activity if the task order 
explicitly stated it was not required, or if the activity was not addressed 
as a PSC activity in both the task order and applicable version of the  
PSC Umbrella Statement of Work. 
Prior to conducting this study, we presented CMS our rationale for 
using this set of activities as analysis criteria. CMS explained that 
while the table of nine activities lists Civil Monetary Penalties, PSCs 
are responsible for Civil Monetary Penalties and Other Administrative 
Actions.  Based on this, when we identified three task orders that 
excluded responsibility for civil monetary penalties but required other 
administrative actions, we counted these task orders as requiring the 
activity, Civil Monetary Penalties and Other Administrative Actions. 
Analyzing Text in Evaluation Reports.  We categorized text in the 
evaluation reports to quantify and describe the types of comments that 
addressed the nine fraud and abuse activities.  The evaluation reports 
that addressed activities did so in the following ways:  positive, 
negative, brief mention, extensive comments, results information, 
and/or process and procedures information.  We did not categorize text 
that was unrelated to the fraud and abuse activities. 
In accordance with the analysis plan we shared with CMS, we assigned 
evaluation report comments to two categories, and further divided the 
first category as follows: 
1.  Results 
a.  Qualitative comments 
b.  Quantitative comments 
2.  Process and procedures  
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By results, we mean accomplishments in detecting and deterring fraud 
and abuse. By qualitative comment, we mean the comment consisted of 
words only, e.g., PSCs data analysis resulted in case referrals to law 
enforcement.  By quantitative comment, we mean the comment 
included numeric information, e.g., Of the 12 cases referred to law 
enforcement, 7 were opened via proactive data analysis.  The table in 
Appendix C shows the types of comments that we counted as results in 
the 17 evaluation reports we reviewed.  These 17 reports contained from 
0 to 16 results comments, for a total of 119 results comments.  
By process and procedures, we mean the day-to-day operations, tools, 
and methods of conducting fraud and abuse detection and deterrence 
work.  The table in Appendix D shows the types of comments that we 
counted as process and procedures in the 17 evaluation reports we 
reviewed.  These 17 reports contained from 0 to 15 comments related to 
process and procedures, for a total of 94 process and procedures 
comments. 
Limitation of Evaluation Report Analysis. We did not request information 
from CMS that would (1) corroborate information in the performance 
evaluation reports, or (2) provide additional information about PSC 
achievements. 
Task Order and Evaluation Report Data Collected   
We also requested data from CMSs central office that would enable us 
to determine: 
o 	 the funds allocated to benefit integrity task orders,  
o 	 the number of task orders renewed, 
o 	 the number of task order performance periods that were 
evaluated, 
o 	 the evaluation method used for each task order, 
o 	 the timeliness of the evaluation reports, and  
o 	 where delays in the evaluation process occurred (if any).   
The data we reviewed covered the period November 22, 1999, (start date 
of the oldest benefit integrity task order awarded to a PSC) to 
November 5, 2004. This time period included renewals for the 17 task 
orders, resulting in a total of 44 task order performance periods.   
While we asked CMS to clarify and verify some of the data they 
provided, we did not perform an independent validation of all the data. 
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Task order performance period or simply performance period are the 
terms we use to represent a discrete task order performance period. A 
task order may have more than one performance period depending on 
how many times it was renewed. 
Evaluation period is the term we use to represent the time period of 
PSC performance that was evaluated by CMS. Evaluation periods 
rarely match performance periods, as shown in the table, Task Order 
Performance Period Versus Evaluation Period, in Appendix E. One 
reason for this is that CMS must provide the PSC advance notice of the 
Governments intention to renew or not renew the task order. 
Therefore, the evaluation is performed far enough in advance of the end 
of the performance period. In some cases, an evaluation may cover all 
or part of the previous performance period and part of the current 
performance period. In one unusual case, an 18-month performance 
period was divided into three evaluation periods. 
Basis of Timeliness Calculation for Evaluation Reports 
PSC Umbrella Statement of Work. Of the 40 report-issuance dates CMS 
provided, 32 were for final reports and 8 were for draft reports. To 
determine whether reports were issued on time, we calculated the 
difference between the report issue dates and the deadlines set forth in 
the applicable PSC Umbrella Statement of Work. Of the 40 report-
issuance dates CMS provided, 39 were for task orders under the original 
PSC Umbrella Statement of Work, and 1 was for a task order under 
the May 2004 revision. 
Three-Month Renewal Notice. As a secondary measure of report 
timeliness, we determined whether reports were issued by the time the 
renewal notice was due. CMS is required to notify the PSC 3 months 
before the end of the performance period as to whether CMS intends to 
renew the task order. We performed this calculation for the 32 final 
report dates and 8 draft report dates we received from CMS. 
Inspection Standards 
This inspection was conducted in accordance with the Quality 
Standards for Inspections issued by the Presidents Council on 
Integrity and Efficiency and the Executive Council on Integrity and 
Efficiency. 
OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  7    F I N D I N G S

Of the 17 evaluation reports we 
Performance evaluation reports provided 
reviewed, several did not contain 
limited quantitative data about program 
results, quantitative or 
safeguard contractors achievements related to  qualitative, for 1 or more of the 9 
detecting and deterring fraud and abuse  fraud and abuse activities. Eight 
performance evaluation reports 
did not address results regarding 
Medical Review to Support Fraud and Abuse Cases.  In addition, nine 
reports did not address results regarding Fraud Complaint Processing, 
and nine reports did not address results regarding Fraud 
Prevention/Detection Education.   
The majority of results-oriented comments (62 of 119) did not address 
outcomes of fraud and abuse work, but instead were standardized 
phrases addressing the quality of the work (e.g., case files appear 
complete, timely, and appropriate). 
Fifteen of 119 results-oriented comments (12 percent) were quantitative. 
These 15 quantitative comments were spread across 8 evaluation reports. 
Thus, the evaluation reports provided limited quantitative data 
measuring PSC efforts or achievements related to detecting and deterring 
fraud and abuse. For example, only one evaluation report mentioned 
the number of open and pending proactive fraud cases, only one 
mentioned the amount of money saved as a result of PSC initiatives and 
the matching of Medicare and Medicaid data, and only one mentioned 
the number of requests received from law enforcement agencies. 
Almost half of the quantitative comments regarding PSC performance 
(6 of 15) were negative. Five of six negative comments pointed out a 
lack of detection and deterrence activity, such as no PSC-initiated 
referrals to law enforcement in a jurisdiction that has a history of fraud 
and abuse. The remaining comment described failures to respond to 
law enforcement requests for support in a timely manner. 
Table 1 identifies the number of evaluation reports that addressed PSC 
results quantitatively for each standard fraud and abuse activity. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  8  F I N D I N G S  

Table 1:  Evaluation Reports Addressing Results Quantitatively 
Fraud and Abuse Detection and  Number of Evaluation Reports with 
Deterrence Activity  Quantitative Results Per Activity1 
Fraud Case Development  3 
Civil Monetary Penalties and Other 
2 
Administrative Actions 
Law Enforcement Support  2 
Fraud Prevention/Detection Education  1 
National/Regional Data Analysis  1 
Fraud Complaint Processing  1 
Medical Review to Support Fraud and 
0 
Abuse Cases 
Submit Proposed Fraud Alerts  0 
Incentive Reward Program  0 
1The quantitative results were in eight reports.  The numbers in this column are not mutually 
exclusive.  
Source:  OIG analysis of comments in evaluation reports of benefit integrity task orders, 2005. 
Sixteen of seventeen reports did not contain  Only one evaluation report 
information on all required fraud and abuse  contained information on 
all of the standard fraud 
detection and deterrence activities 
and abuse activities 
required by the associated task order.  The remaining 16 evaluation 
reports did not contain any information on 2 to 7 required activities.  
These 16 reports had neither results nor process and procedure 
information for these activities.  Two activities, Submit Proposed Fraud 
Alerts and Incentive Reward Program, were not addressed in any 
evaluation report for task orders requiring these activities. Six of 
seventeen evaluation reports did not address Fraud Complaint 
Processing, and 7 of 15 evaluation reports did not address Medical 
Review to Support Fraud and Abuse Cases.  The activity that was 
addressed in most evaluation reports was National/Regional Data 
Analysis (16 of 17), followed by Fraud Case Development (15 of 17).   
Based on our review of all 17 benefit integrity task orders, we found 
that they require PSCs to perform from 7 to 9 of the 9 standard fraud 
and abuse activities. Table 2 shows the number of standard fraud and 
abuse activities required by each task order and the number of these 
activities addressed in each evaluation report. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  9  N G
For a list of the specifc fraud and abuse activities required in each task
order and addressed in each evaluation report that we reviewed, see
Appendix F.
Table 2: Fraud and Abuse DetectionlDeterrence Activities Addressed in
Evaluation Reports
Task Order Number of Number of
Identifier Activities Required Activities Evaluated
This evaluation covered only 2 weeks that the PSC was fully operational and 5 months that the PSC
was in transition.
Source: OIG analysis of comments in evaluation report of benefi integrity task orders. 2005.
Seventy-two percent of evaluation  Since the first benefit integrity
report were
task order was awarded in
time
issued on 
1999, 72 percent of all final
evaluation reports (23 of 32) have been issued on time. Twenty-eight
percent (9 of 32) were issued late. The "PSC Umbrella Statement of
Work" that governed these 32 final reports stated that final
performance evaluation reports would be issued 2 months  afterthe end
of the task order performance period. Of the nine final reports that
were issued late, seven were from 20 days to 6 months late, one was
almost 19 months late, and one was 38 months late. Appendix G
contains information on the timeliness of each evaluation report for
which CMS provided issue dates. It also lists the benefit integrity task
OEI.03.04.00050 MEDICARE S PROGRAM SAFEGUARD CONTRACTORS: PERFORMANCE EVALUATION REPORTS F I N D I N G S  
order performance periods for which the report issue dates were not 
available.   
While almost three-quarters of evaluation reports were issued on time, 
only 5 of these 32 reports were issued at least 3 months before the task 
order performance period ended.  It is at this time3 months before the 
performance period endsthat CMS is required to notify the PSC 
whether CMS intends to renew the contract.  
CMS staff members stated that they can use draft evaluation reports to 
make task order renewal decisions. However, CMS was only able to 
provide us with draft report dates for eight draft reports.  Of these eight 
draft reports, two were issued at least 3 months before the end of the 
task order performance period.   
CMS issued revisions to the PSC Umbrella Statement of Work in 
2004. The revisions state that CMSs final evaluation reports of PSC 
performance will be issued 3 months before the task order performance 
period ends.  This new time schedule for issuing final reports coincides 
with the time schedule for sending a renewal notice to the PSC.   
The unavailability of milestone dates in the evaluation process prevented 
us from identifying where reporting delays occur 
Few performance evaluation milestone dates, other than most final 
report dates, were available from CMS.  Once evaluation reports are 
finalized, the online evaluation system used by CMS deletes the dates of 
earlier events.  Examples of earlier events include the issuance of draft 
reports to PSCs and the receipt of comments on draft reports from 
PSCs. Based on data CMS provided, it appears CMS does not have a 
systematic means to track evaluation events other than the online 
system. Thus, CMS is limited in its ability to retrospectively determine 
where delays in the evaluation report process occur. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  11    RR EE CC OO MM MM EE NN DD AA TT II OO NN SS   

The primary responsibility for detecting and deterring fraud and abuse 
in the Medicare program was transferred from carriers and fiscal 
intermediaries to PSCs.  To determine how well PSCs are performing, 
CMS utilizes the contractor performance evaluation as an important 
tool. 
However, performance evaluation reports contained minimal 
information about PSC efforts to detect and deter fraud and abuse.  
Because these reports are limited in their description of the results 
PSCs may be achieving, they provide limited information on which to 
base task order renewal decisions. 
To improve the evaluation process, we recommend that CMS: 
Address program safeguard contractor results in their performance 
evaluation reports.  CMS should describe PSC results in identifying 
and preventing fraud and abuse in the evaluation reports to 
demonstrate the adequacy of PSC performance. Using quantitative as 
well as qualitative data to describe results would provide a more 
comprehensive picture of PSC performance and provide valuable data 
for making renewal decisions.  If, for example, certain PSC activities are 
saving money for the Medicare program, the activity and the amount of 
money saved should be included in the performance evaluation reports. 
Provide information about required program safeguard contractor 
activities in performance evaluation reports.  The activities CMS 
specifically lists in the benefit integrity task orders and that PSCs are 
required to perform should be evaluated in the performance evaluation 
reports. The primary responsibility of PSCs is to detect and deter fraud 
and abuse; therefore, the performance evaluation reports should include 
information on whether fraud and abuse detection and deterrence 
activities were performed and how effectively they were performed. 
Take steps to ensure that all draft and final performance evaluation 
reports are issued in accordance with the current timetable. CMS 
should aim to issue 100 percent of the performance evaluation 
reports on time.  Moreover, by following the timetable in the current 
revised PSC Umbrella Statement of Work, evaluation reports 
would be available for CMS when the task order renewal notice is 
due.  This would allow CMS to make more informed decisions when 
renewing a task order with a contractor.  
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  12  R E C O M M E N D A T I O N S  
Establish a means to track and save evaluation milestone dates. 
The online system CMS uses for PSC evaluations only holds 
evaluation milestone dates temporarily.  A system that tracks and 
saves all milestone dates would help CMS identify where delays 
occur so that improvements can be made to the performance 
evaluation process.    
AGENCY COMMENTS 
CMS concurred with OIG recommendations to: (1) ensure that all draft 
and final performance evaluation reports are issued in accordance with 
the current timetable; and (2) establish a means to track and save 
evaluation milestone dates. 
CMS concurred only in part with the OIG recommendation to address 
results in PSC performance evaluation reports.  CMS believes that 
quantifying PSC output could create perverse incentives and undermine 
the value of a PSCs work.  CMS stated that it has been cautioned by 
prosecutors that cases could be jeopardized if the entity assessing the 
facts of the investigation were rewarded for sheer volume of case 
referrals or required to meet a quota of case referrals.  CMS, therefore, 
looks to the timeliness of PSC performance, the thoroughness of PSC 
work, and PSC responsiveness to law enforcement agencies to 
determine PSC effectiveness in fraud fighting.  However, CMS stated 
that the current OIG study underscored the benefits that could be 
gained by capturing units of work that PSCs perform.  CMS stated that 
it has already begun moving forward on the OIG recommendation by 
improving the means by which it gathers information about the outcome 
of PSC activities and will collect an array of quantitative and 
qualitative measurements. 
CMS concurred in part with OIGs recommendation to provide 
information about required PSC activities in performance evaluation 
reports.  CMS stated that every aspect of PSC performance should be 
scrupulously reviewed and evaluated. However, it stated that resources 
limit the level and intensity of scrutiny that can reasonably be applied 
to PSCs and it will focus performance evaluations on the primary PSC 
activities. Furthermore, CMS will reevaluate the listing of activities 
required in the PSC Statement of Work in order to emphasize the most 
crucial activities.  The full text of CMSs comments are in Appendix H. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  13  R E C O M M E N D A T I O N S  

OFFICE OF INSPECTOR GENERAL RESPONSE 
OIG is pleased that our review helped underscore the benefits that 
could be gained by a more complete review of PSC performance, and we 
appreciate that CMS is already moving forward on our 
recommendations.  While OIG understands CMSs concerns about 
creating perverse incentives, we are not advocating that a system of 
numeric quotas be implemented. Rather, OIG is recommending that 
evaluation reports include the level of activity and results that PSCs 
have achieved in combating fraud in the Medicare program. OIG 
continues to believe that these types of measures are necessary to 
accurately assess the effectiveness of the PSCs fraud-fighting efforts.   
CMS commented that resources sometimes limit the level and intensity 
of scrutiny CMS can give to all PSC activities.  While this is 
understandable, OIG believes that activities listed in PSC task orders 
should be addressed in performance evaluation reports. 
OIG looks forward to working with CMS in its continuing efforts to 
improve the PSC review process. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  14    A P P E N D I X   ~   A  

Related Office of Inspector General Reports 
The following is a brief description of OIG reports about contractors 
responsible for detecting and deterring fraud and abuse in the Medicare 
program: 
February 2000, Durable Medical Equipment Regional Carriers:  Meeting 
HCFAs Objectives (OEI-04-97-00330). We found that durable medical 
equipment regional carriers (DMERC) were addressing fraud in 
individual cases, but a lack of information precluded us from 
determining the overall effectiveness of their fraud units.  DMERCs did 
not provide needed data to document the quality and results of their 
efforts. 
November 1998, Fiscal Intermediary Fraud Units (OEI-03-97-00350).  We 
found that fiscal intermediary fraud units differed substantially in the 
number of complaints and cases handled.  Some units produced few, if 
any, significant results. 
November 1996, Carrier Fraud Units (OEI-05-94-00470).  We compared 
carrier performance in five outcome areas:  accuracy of complaint 
disposition; case documentation; assessing financial damage; internal 
proactive safeguards; and external proactive safeguards.  We found that 
few carriers were successful in meeting all outcome criteria. 
August 1995, Monitoring Medicare Contractor Performance:  A New Approach 
(OEI-01-93-00160). We found that the new monitoring approach 
(instituted in 1994), which used qualitative assessment, gathered useful 
information.  In addition, the use of teams from outside the local 
regional office to conduct the reviews enhanced the reviews. We also 
found that CMS had not yet made full use of information gathered in 
the reviews to further contractors ability to safeguard Medicare 
payments. 
August 1988, Medicare Carriers Performance of Program Integrity Functions 
(OAI-04-88-00710). We found that certain CMS policies and/or 
procedures regarding program integrity were outdated, that allocation 
of carrier resources away from traditional program integrity processes 
was a concern, that carriers were properly accounting for costs and 
savings for program integrity functions, and that improvements were 
needed in OIG systems for providing feedback on status and disposition 
of fraud cases referred by the carriers. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  15    A P P E N D I X   ~   B  
This table contains the 17 performance evaluation reports we reviewed.  The information in this 
table appears in descending order by final report issue date. 
Performance Evaluation Reports Reviewed (n=17) 
Additional 
Task Order  Allocation for 
Task Order  Performance  Funds  Medi-Medi  Final Report 
Identifier  Period  Allocated  Project1  Issue Date2 
J  11/01/03 - 10/31/04  $4,408,499  11/05/04 
E  01/01/04 - 12/31/04  $5,386,795  $2,170,312  10/21/04 
A  01/01/04 -12/31/04  $6,892,628  10/20/04 
L  03/05/04 - 10/31/04  $1,278,635  $1,067,232  10/15/04 
B  01/01/04 - 12/31/04  $2,960,903  $1,090,280  10/15/04 
C  01/01/04 - 12/31/04  $2,092,031  10/15/04 
K  12/01/03 - 11/30/04  $7,643,157  10/15/04 
F  01/01/04 - 12/31/04  $4,707,594  10/14/04 
H  12/01/03 - 11/30/04  $8,238,693  10/13/04 
P  01/01/04 - 06/30/04  $2,557,795  09/18/04 
M  11/01/03 - 10/31/04  $6,812,554  $1,182,466  09/16/04 
D  11/01/03 - 10/31/04  $3,705,267  $1,251,969  09/16/04 
I  11/01/03 - 10/31/04  $9,766,300  $1,250,000  09/08/04 
O  11/07/02 - 11/30/03  $6,083,042  01/26/04 
Q  08/01/02 - 11/30/03  $7,733,315  $1,244,435  10/29/03 
G  06/01/02 - 12/31/03  $11,751,340  $1,244,435  06/10/03 
N  08/03/01 - 08/02/02  $6,192,838  10/30/02 
Totals  $98,211,386  $10,501,129 
1Medi-Medi is a project that matches Medicare and Medicaid data, and it is required of certain PSCs. 
2These were the most current final reports as of November 5, 2004. 
Source:  Centers for Medicare & Medicaid Services, Program Integrity Group and Office of Acquisitions and Grants Management. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  16  This table shows the types of comments that we counted as "results" in the 17 performance
evaluation reports we reviewed. Comments could be positive or negative and are organized
under the nine standard fraud and abuse detection and deterrence activities. The check marks
indicate whether the comments in the reports we reviewed were qualitative or quantitative.
QUALITATIVE QUANTITATIVE
1. FRAUD CASE DEVELOPMENT
roduction
2. NATIONAUREGIONAL DATA ANALYSIS
3. LAW ENFORCEMENT SUPPORT
4. MEDICAL REVIEW TO SUPPORT FRAUD AND ABUSE CASES
Medical review determinations - ualit
Medical review determinations - timeliness
5. CIVIL MONETARY PENALTIES AND OTHER ADMINISTRATIVE ACTIONS
enalties
6. SUBMIT PROPOSED FRAUD ALERTS
OEI.03.04.00050 MEDICARE S PROGRAM SAFEGUARD CONTRACTORS: PERFORMANCE EVALUATION REPORTS Evaluation Comments Addressing Results
7.  FRAUD PREVENTION/DETECTION EDUCATION
Affliated contractor education
eMS education
Law enforcement education
Provider education
PSC education
Training
8.  FRAUD COMPLAINT PROCESSING
Complaint acknowledoments
Complaint processino - Qualitv
Complaint processinQ - timeliness
Complaint referrals
Reduction of pending beneficiary complaints
Reduction of pending complaints (source of complaints not
specified)
9. INCENTIVE REWARD PROGRAM
No comments on this activity in any report we reviewed
Source: Offce of Inspector General analysis of comments in evaluation reports of benefit integrity task orders. 2005.
OEI.03.04.00050 MEDICARE S PROGRAM SAFEGUARD CONTRACTORS: PERFORMANCE EVALUATION REPORTS I X
This table shows the types of comments that we counted as "process and procedures" in the
17 performance evaluation reports we reviewed. Comments could be positive or negative and
are organized under the nine standard fraud and abuse detection and deterrence activities-
Evaluation Comments Addressing Process and Procedures
1.  FRAUD CASE DEVELOPMENT
Case documentation
Case audit trail
Case Drocedures
Case referral packages to law enforcement aQencies
Case trackinQ system
Cost control
Cost report
Feedback from law enforcement reoardino cases
Fraud Investioation Database - cases unassioned
Fraud Inyestioation Database - uDdates (oualitv and timeliness)
Fraud Investioation Database - traininG
Followino UP referrals timelv
Interaction with eMS reaardino cases
Interaction with law enforcement recrdinocases
Performance problem
Qualitv control
2.  NATIONAUREGIONAL DATA ANALYSIS
Analysis methods
Analysis tools
Data obtained. uploaded. maintained
Development of data matchino methodoloov for Medicare-Medicaid proiect
Interaction with affliated contractor reoardino data analysis
Manaoement performance reoardino data analysis
Performance problem
SUQQestions for PSC Analysis. Reportino, and Trackino System
3.  LAW ENFORCEMENT SUPPORT
Audit trail of law enforcement reouests for SUDDort
Cost control
Cost report
Feedback from law enforcement
Interaction with eMS reQardino law enforcement support
Interaction with law enforcement reaardinosuDDort reQuests
Procedures for respondino to support reQuests
4.  MEDICAL REVIEW TO SUPPORT FRAUD AND ABUSE CASES
Follows ouidelines/reoulations reoardino medical review
Interaction with affilated contractor reoardino medical review
5.  CIVIL MONETARY PENALTIES AND OTHER ADMINISTRATIVE ACTIONS
Coordination with affliated contractor reaardino administrative action
Coordination with eMS reoardino administrative action
Procedures reQardino administrative action
6.  SUBMIT PROPOSED FRAUD ALERTS
No comments on this activitv in any report we reviewed
7.  FRAUD PREVENTION/DETECTION EDUCATION
No comments on this activitv in anv reDort we reviewed
OEI-03.04.00050 MEDICARE S PROGRAM SAFEGUARD CONTRACTORS: PERFORMANCE EVALUATION REPORTS Evaluation Comments Addressing Process and Procedures
8. FRAUD COMPLAINT PROCESSING
Complaint audit trail
Complaint procedures
Complaint trackino system
Cost control
Interaction with affliated contractor reQardinQ complaints
Interaction with eMS regarding complaints
9. INCENTIVE REWARD PROGRAM
No comments on this activity in any report we reviewed
Source: Offce of Inspector General analysis of comments in evaluation reports of benefit integrity task orders. 2005.
OEI.03-04-00050 MEDICARE S PROGRAM SAFEGUARD CONTRACTORS: PERFORMANCE EVALUATION REPORTS   A P P E N D I X   ~   E  
This table contains all task order performance periods for the period 1999-2004.  The 
information appears in ascending order by performance period end date.  It compares the task 
order performance period with the evaluation period.  The 17 performance evaluation reports we 
reviewed are associated with task order identifiers A  Q. 
Task Order Performance Period Versus Evaluation Period, 1999-2004 
Task Order Identifier  Performance Period  Evaluation Period 
R  11/22/99 - 11/21/00  11/24/99 - 11/23/00 
S  07/14/00 - 07/13/01  07/14/00 - 07/13/01 
T  11/07/00 - 11/06/01  Not Applicable1 
U  11/22/00 - 11/21/01  No Evaluation 
V  07/14/01 - 07/13/02  07/14/01 - 03/31/02 
N  08/03/01 - 08/02/02  08/03/01 - 06/24/02 
W  11/07/01 - 11/06/02  11/07/00 - 07/16/02 
X  11/22/01 - 11/21/02  11/01/01 - 05/30/02 
Y  12/21/01 - 12/20/02  12/21/01 - 09/23/02 
Z  07/14/02 - 10/31/03  01/01/02 - 12/31/02 
AA  10/17/02 - 10/31/03  10/17/02 - 03/31/03 
BB  04/01/03 - 10/31/03  Not Applicable1 
CC  09/27/02 - 10/31/03  09/27/02 - 03/31/03 
DD  08/01/02 - 11/30/03  08/01/02 - 01/31/03 
O  11/07/02 - 11/30/03  07/17/02 - 04/30/03 
Q  08/01/02 - 11/30/03  08/01/02 - 02/01/03 
EE2  05/16/02 - 11/30/03  5/15/02 - 12/16/02 
EE2  05/16/02 - 11/30/03  12/17/02 - 02/28/03 
EE2  05/16/02 - 11/30/03  03/01/03 - 11/17/03 
FF  12/21/02 - 12/31/03  09/24/02 - 06/30/03 
GG  6/25/02 - 12/31/03  6/25/02 - 12/31/02 
HH  12/20/02 - 12/31/03  12/20/02 - 05/31/03 
II  11/22/02 - 12/31/03  05/31/02 - 05/31/03 
JJ  05/16/02 - 12/31/03  05/16/02 - 10/31/02 
KK  12/20/02 - 12/31/03  Not Applicable1 
G  06/01/02 - 12/31/03  06/01/02 - 01/15/03 
1This task order performance period was evaluated with a subsequent performance period.
2This task order had three evaluations conducted during the performance period.  Consequently, this table has 46 lines of data for 44 individual task 
  order performance periods. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  21  A P P E N D I X   ~   E  

Task Order Performance Period Versus Evaluation Period, 1999-2004 
Task Order Identifier  Performance Period  Evaluation Period 
LL  08/03/02 - 01/09/04  02/01/02 - 01/31/03 
MM  03/05/03 - 03/04/04  03/05/03 - 12/31/03 
P  01/01/04 - 06/30/04  07/01/03 - 01/31/04 
L  03/05/04 - 10/31/04  01/01/04 - 06/30/04 
I  11/01/03 - 10/31/04  01/01/03 - 04/30/04 
M  11/01/03 - 10/31/04  04/01/03 - 04/30/04 
D  11/01/03 - 10/31/04  04/01/03 - 04/30/04 
J  11/01/03 - 10/31/04  04/01/03 - 04/30/04 
K  12/01/03 - 11/30/04  02/01/03 - 05/31/04 
NN  12/01/03 - 11/30/04  05/01/03 - 05/31/04 
OO  12/01/03 - 11/30/04  02/02/03 - 05/31/04 
H  12/01/03 - 11/30/04  11/18/03 - 05/31/04 
PP  07/01/04 - 12/31/04  02/01/04 - 06/30/04 
B  01/01/04 - 12/31/04  01/01/03 - 06/30/04 
C  01/01/04 - 12/31/04  06/01/03 - 06/30/04 
QQ  01/10/04 - 12/31/04  02/01/03 - 06/30/04 
A  01/01/04 -12/31/04  06/01/03 - 06/30/04 
E  01/01/04 - 12/31/04  11/1/02 - 6/30/04 
F  01/01/04 - 12/31/04  03/15/03 - 06/30/04 
RR  01/01/04 - 12/31/04  01/16/03 - 06/30/04 
 Source:  Centers for Medicare & Medicaid, Program Integrity Group and Office of Acquisitions and Grants Management. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  22    A P P E N D I X   ~   F  

This table quantifies the specific fraud and abuse activities required in benefit integrity task 
orders and addressed in the 17 performance evaluation reports we reviewed. 
Fraud and Abuse Detection/Deterrence Activities Addressed in Evaluation Reports 
r 
sis Othe aud  s 
TIadsekn Otifrideer r  National/Regional Data Analy Fraud Case Development    Law Enforcement Support  Civil Monetary Penalties and Administrative Actions  Fraud Complaint Processing  Medical Review to Support Frand Abuse Cases Fraud Prevention/Detection Education  Submit Proposed Fraud Alert   Incentive Reward Program ReTNqAauuscimkrtie vbOdietr iUrde eonsrfd 2 e r  EvAalNduAduacrmtteiiovsbniset ierRe dose f ip no rt EvPAaelduArdcacretteiinovstnisat iegRedese   iponof  rt 
A  T  T  T  T  T  T  T  N/A  N/A  7  7  100% 
B  T  T  T  T  T  T  T  9  7  78% 
C  T  T  T  T  T  T  T  9  7  78% 
D  T  T  T  T  T  T  T  9  7  78% 
E  T  T  T  T  T  T  9  6  67% 
F  T  T  T  T  T  T  9  6  67% 
G  T  T  T  T  T  T  9  6  67% 
H  T  T  T  T  T  T  9  6  67% 
I  T  T  T  T  T   N/A  8  5  63% 
J  T  T  T  T  T  9  5  56% 
K  T  T  T  T  9  4  44% 
L  T  T  T  T  9  4  44% 
M  T  T  T  T  9  4  44% 
N  T  T  N/A  T   N/A  7  3  43% 
O  T  T  N/A  T   N/A  7  3  43% 
P  T  T  N/A  8  2  25% 
Q1  T  T  9  2  22% 
Totals  16  15  14  12  11  8  8  0  0 
1This evaluation covered only 2 weeks that the PSC was fully operational and 5 months that the PSC was in transition. 
2We determined that a task order did not require an activity if the task order stated that it was not required, or if the activity was not addressed as
  a PSC activity anywhere in the task order and PSC Umbrella Statement of Work. 
 Source:  Office of Inspector General analysis of comments in evaluation reports of benefit integrity task orders, 2005. 
  OEI-03-04-00050  MEDICARES PROGRAM SAFEGUARD CONTRACTORS:  PERFORMANCE EVALUATION REPORTS  23    A P P E N D I X   ~   G  

This table contains information on the timeliness of each performance evaluation report for 
which the Centers for Medicare & Medicaid Services provided issue dates.  It also lists the 
benefit integrity task orders for which report issue dates were not applicable or not available. 
Timeliness of Performance Evaluation Reports, 1999-2004 
Performance 
Task Order  Period End  Draft Report  Timeliness1 of  Final Report  Timeliness1 of Final 
Identifier  Date  Issue Date  Draft Report  Issue Date  Report  
R  11/21/2000  Not Available  03/10/2004  38.17 months late 
Y  12/20/2002  Not Available  09/02/2004  18.73 months late 
EE3  11/30/2003  Not Available  07/20/2004  5.77 months late 
X  11/21/2002  Not Available  07/02/2003  5.43 months late 
S  07/13/2001  Not Available  01/08/2002  3.97 months late 
W  11/06/2002  Not Available  02/24/2003  1.67 months late 
N  08/02/2002  Not Available  10/30/2002  0.97 months late 
CC  10/31/2003  Not Available  01/23/2004  0.80 months late 
P  06/30/2004  Not Available  09/18/2004  0.67 months late 
O  11/30/2003  Not Available  01/26/2004  0.10 months early 
J  10/31/2004  07/01/2004  5.07 months early  11/05/2004  1.83 months early 
L  10/31/2004  Not Available  10/15/2004  2.53 months early 
II  12/31/2003  Not Available  12/04/2003  2.90 months early 
Q  11/30/2003  Not Available  10/29/2003  3.07 months early 
D  10/31/2004  Not Available  09/16/2004  3.50 months early 
M  10/31/2004  Not Available  09/16/2004  3.50 months early 
K  11/30/2004  Not Available  10/15/2004  3.53 months early 
H  11/30/2004  Not Available  10/13/2004  3.60 months early 
I  10/31/2004  Not Available  09/08/2004  3.77 months early 
HH  12/31/2003  Not Available  10/22/2003  4.33 months early 
FF  12/31/2003  Not Available  10/22/2003  4.33 months early 
E  12/31/2004  09/09/2004  4.77 months early  10/21/2004  4.37 months early 
A  12/31/2004  Not Available  10/20/2004  4.40 months early 
B  12/31/2004  Not Available  10/15/2004  4.57 months early 
C  12/31/2004  Not Available  10/15/2004  4.57 months early 
F  12/31/2004  Not Available  10/14/2004  4.60 months early 
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Timeliness of Performance Evaluation Reports, 1999-2004 
Performance 
Task Order  Period End  Draft Report  Timeliness1 of  Final Report  Timeliness1 of Final 
Identifier  Date  Issue Date  Draft Report  Issue Date  Report  
AA  10/31/2003  Not Available  08/07/2003  4.83 months early 
Z  10/31/2003  Not Available  07/29/2003  5.13 months early 
G  12/31/2003  Not Available  06/10/2003  8.80 months early 
JJ  12/31/2003  Not Available  05/19/2003  9.53 months early 
EE3  11/30/2003  Not Available  04/07/2003  9.90 months early 
GG  12/31/2003  Not Available  03/21/2003  11.50 months early 
T  11/06/2001  Not Applicable2    Not Applicable2 
U  11/21/2001  No Evaluation    No Evaluation 
V  07/13/2002  Not Available  Not Available 
BB  10/31/2003  Not Applicable2    Not Applicable2 
EE3  11/30/2003  03/11/2004  2.40 months late  Not Available 
DD  11/30/2003  Not Available  Not Available 
KK  12/31/2003  Not Applicable2    Not Applicable2 
LL  01/09/2004  Not Available  Not Available 
MM  03/04/2004  01/14/2004  2.67 months early  Not Available 
OO  11/30/2004  10/19/2004  2.40 months early  Not Available 
NN  11/30/2004  09/09/2004  3.73 months early  Not Available 
PP  12/31/2004  10/21/2004  2.13 months late  Not Available 
QQ  12/31/2004  10/05/2004  3.90 months early  Not Available 
RR  12/31/2004  Not Available  Not Available 
1Timeliness calculation is based on timeframes set forth in the applicable Program Safeguard Contractor Umbrella Statement of Work.
2This task order performance period was evaluated with a subsequent performance period.
3This task order had three evaluations conducted during the performance period.  Consequently, this table has 46 lines of data for 44 individual  
task order performance periods. 
Source:  Office of Inspector General analysis of dates that evaluation reports were issued, 2005. 
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This report was prepared under the direction of Robert A. Vito, Regional 
Inspector General for Evaluation and Inspections in the Philadelphia 
regional office, and Linda M. Ragone, Deputy Regional Inspector 
General. Other principal Office of Evaluation and Inspections staff who 
contributed include: 
Isabelle Buonocore, Team Leader 
Cynthia Hansford, Program Assistant 
Linda Frisch, Program Specialist 
Scott Manley, Program Specialist 
Tricia Davis, Director, Medicare and Medicaid Branch 
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