Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

EARLY OUTCOMES SHOW 

LIMITED PROGRESS FOR THE 

TRANSFORMED MEDICAID 

STATISTICAL INFORMATION 

SYSTEM 

Daniel R. Levinson 

Inspector General 

September 2013 

OEI-05-12-00610 
 

 

EXECUTIVE SUMMARY: Early Outcomes Show Limited Progress for the 

Transformed Medicaid Statistical Information System 

OEI-05-12-00610 

WHY WE DID THIS STUDY 

In response to a Congressional request, the Office of the Inspector General (OIG) agreed 

to determine the status of national Transformed Medicaid Statistical Information System 

(T-MSIS) implementation and determine whether early outcomes indicate that T-MSIS 

data will be complete, accurate, and timely upon national implementation. T-MSIS is 

designed to be a detailed national database of Medicaid and Children’s Health Insurance 

Program information to cover a broad range of user needs, including program integrity. 

T-MSIS is a continuation of the Centers for Medicare & Medicaid Services’ (CMS) past 

attempts to improve the current nationally available Medicaid data after OIG and others 

found that the current data were not complete, accurate, or timely. 

HOW WE DID THIS STUDY 

To complete this early implementation review, we analyzed project schedules, meeting 

minutes, and milestone achievements from 12 States that volunteered to work with CMS 

on the planning and development of T-MSIS. These States were in a position to be some 

of the first States to implement T-MSIS. We also analyzed CMS’s T-MSIS 

documentation regarding States’ ability to report complete and accurate T-MSIS data. 

Finally, we conducted structured interviews with CMS staff. 

WHAT WE FOUND 

Overall, as of January 2013, CMS and the 12 volunteer States had made some progress in 

implementing T-MSIS. However, most other States had not started implementing 

T-MSIS; and they reported varied timeframes for when they plan to begin. CMS has not 

established a deadline for when national T-MSIS data will be available. 

Further, early T-MSIS implementation outcomes raised questions about the completeness 

and accuracy of T-MSIS data upon national implementation. None of the 12 volunteer 

States can make all T-MSIS data elements available. Further, both CMS and the 

12 States expressed concerns about the accuracy of the data they could provide upon 

implementation. 

WHAT WE RECOMMEND 

Although CMS and 12 volunteer States have made some progress with T-MSIS, it 

remains unclear whether T-MSIS will result in complete, accurate, and timely national 

Medicaid program integrity data upon implementation. We recommend that CMS, to 

help create a fully functional T-MSIS: (1) establish a deadline for when national T-MSIS 

data will be available; (2) ensure that States submit required T-MSIS data; and (3) ensure 
that T-MSIS data are complete, accurate, and timely upon T-MSIS implementation. 

CMS concurred with our recommendations. 
TABLE OF CONTENTS 

Objectives ....................................................................................................1 

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

Methodology................................................................................................8 

Findings......................................................................................................12 

Twelve volunteer States made some progress implementing 

T-MSIS; however, most other States had not started ....................12 

CMS has not established a deadline for when national T-MSIS 

data will be available .....................................................................14 

Volunteer States indicated that their data systems did not have 

all T-MSIS data elements...............................................................14 

CMS and volunteer States reported concerns about the accuracy 

of T-MSIS data ..............................................................................17 

Conclusion and Recommendations ............................................................19 

Agency Comments and Office of Inspector General Response .....22 

Appendixes ................................................................................................24 

A: Implementation Milestones ......................................................24 

B: Description of Documents Reviewed .......................................26 

C: Definitions of Office of Inspector General Completeness 

Categories ......................................................................................27 

D: Progress Toward Milestones ....................................................29 

E: Availability of Transformed Medicaid Statistical Information 

System Data Elements by File for All Volunteer States .................32 

F: Transformed Medicaid Statistical Information System Data
 

Elements Available in All Volunteer States ....................................35 

G: Agency Comments ...................................................................37 

Acknowledgments......................................................................................44 
 

 

 

 

 

OBJECTIVES 

1.	 To determine the status of the Centers for Medicare & Medicaid 

Services’ (CMS) national implementation of the Transformed 

Medicaid Statistical Information System (T-MSIS). 

2.	 To determine the extent to which the early implementation outcomes 

and States’ and CMS’s experiences implementing T-MSIS indicate 

that T-MSIS may result in complete, accurate, and timely national 

Medicaid program integrity data. 

BACKGROUND 

This early implementation review responds to a Congressional request that 

the Office of Inspector General (OIG) review T-MSIS to determine 

whether CMS’s plans, milestones, metrics, goals, and data elements meet 

the needs of entities conducting program integrity activities. In response 

to the request, OIG agreed to determine the status of national T-MSIS 

implementation and determine whether early outcomes indicate that 

T-MSIS data will be complete, accurate, and timely upon national 

implementation. 

Previous OIG work found problems with national Medicaid data and 

recommended that CMS improve the quality of data.1 T-MSIS is CMS’s 

solution to the known problems in the current nationally available 

Medicaid data.2 

Medicaid Data Reporting Requirements 

States are mandated to report fee-for-service claims and individual 

encounter data for managed care enrollees to CMS. The Patient Protection 

and Affordable Care Act (ACA) added a requirement that States report 

elements that the Secretary deems necessary for program integrity, 

oversight, and administration. The Medicaid Statistical Information 

System (MSIS) is the mechanism by which CMS requires States to report 

these data.3

 CMS requires States to report MSIS data quarterly. 4 

1

 OIG, Early Assessment of Audit Medicaid Integrity Contractors, OEI-05-10-00210, 

March 2012; OIG, MSIS Data Usefulness for Detecting Fraud, Waste, and Abuse, 

OEI-04-07-00240, August 2009; and OIG, Medicaid Managed Care Encounter Data: 

Collection and Use, OEI-07-06-00540, May 2009. 2

 OIG, Early Assessment of Audit Medicaid Integrity Contractors. 3

 Social Security Act (SSA) § 1903(r)(1)(F) as added by the Balanced Budget Act of
 

1997, P.L. 105-33 § 4753(a)(1), and amended by the ACA, P.L. 111-148 § 6504, to
 

include data elements the Secretary determines are necessary for program integrity, 

oversight, and administration.
 4

 CMS, State Medicaid Manual, Pub. No. 45, § 2700.2. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 1 
 

 

 

 

 

 

 

CMS’s statutory enforcement mechanisms for data reporting requirements 

vary. CMS may withhold Federal matching payments for the use, 

maintenance, or modification of automated data systems from States that 

fail to report required data.5 For managed care enrollees, CMS may 

withhold Federal matching payments for medical assistance to those 

individuals when States fail to report required data.6 

Medicaid Statistical Information System 

MSIS is an extract of States’ Medicaid Management Information Systems 

(MMIS) and contains claims information from all 50 States and the 

District of Columbia (hereinafter referred to as States).7 

MSIS is composed of 5 data files and approximately 400 data elements. 

There is an eligibility file and there are four claims files (inpatient, 

long-term-care, pharmacy, and other). 

CMS intended MSIS as a detailed national database of Medicaid program 

information to cover a broad range of user needs.8 The database is used 

for analytical research, program integrity, planning, budgeting, and policy 

analyses associated with Medicaid. MSIS is the only nationwide 

Medicaid eligibility and claims database. 

Difficulties Using MSIS for National Medicaid Program Integrity 

In previous reports, OIG identified problems with missing or outdated 

MSIS data that make it an inadequate tool for national Medicaid program 

integrity data analysis strategies. OIG found that MSIS did not have all 

data elements necessary for conducting national Medicaid program 

integrity activities.9 Approximately half of a consolidated set of program 

integrity data elements identified by CMS and other Federal agencies were 

not collected from States for MSIS.10 Also, MSIS data were outdated.11 

OIG found that it took an average of 1.5 years to release MSIS data 

publicly from fiscal year (FY) 2004 to FY 2006; significant time was lost 

because States’ initial MSIS data submissions were late.12 

5 SSA § 1903(r)(1)(F).
 6 SSA § 1903(i)(25), added by the ACA, P.L. 111-148 § 6402 (c).
 7

 Each State has its own unique MMIS. States use MMIS to process claims and monitor 

use of services. 

8

 CMS, MSIS Medicaid Statistical Information System. Accessed at 

http://www.medicaid.gov/Medicaid-CHIP-Program-Information/By-Topics/Data-andSystems/MSIS/Medicaid-Statistical-Information-System.html on April 3, 2013. See 

MSIS Procedures, as well. 9

 OIG, MSIS Data Usefulness for Detecting Fraud, Waste, and Abuse. 10 Ibid. 

11 Ibid. 

12 Ibid. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 2 
 

 

 

 

 

 

 

Further, OIG identified MSIS accuracy concerns. In a series of reports, 

OIG found that inaccurate MSIS data hindered the early results of 

Medicaid integrity contractors.13 Specifically, States invalidated more than 

one-third of sampled potential overpayments identified by Medicaid 

integrity contractors mainly because MSIS data were missing or 

inaccurate.14 Additionally, 81 percent of Medicaid integrity contractor 

audits reviewed by OIG either did not, or were unlikely to, identify 

overpayments; in nearly half of these audits, MSIS data were missing or 

inaccurate.15 

In addition, OIG found that the lack of complete, accurate, and timely 

national Medicaid data is also a barrier to CMS’s own program integrity 

data initiatives, such as the Medicare-Medicaid Data Match Program 

(Medi-Medi) and the Integrated Data Repository (IDR).16 Specifically, 

CMS does not use MSIS data for the Medi-Medi program.17 Instead, 

CMS’s contractors work with participating States to collect data directly 

from each State’s Medicaid program. Additionally, CMS intends for the 

IDR to provide a central repository for Medicare and Medicaid data.18 

However, CMS has not integrated MSIS data into the IDR. The OIG 

report notes that according to CMS Medicare program integrity staff, 

MSIS data in their current form are not appropriate to include in the IDR 

because the data are specific to each State and lack many of the 

standardized data elements needed for program integrity work.19 

Finally, in 2012, CMS testified that MSIS was not an effective data source 

for national Medicaid program integrity activities.20 CMS further stated 

13 OIG, Early Assessment of Audit Medicaid Integrity Contractors; OIG, Early
 

Assessment of Review Medicaid Integrity Contractors, OEI-05-10-00200, February 2012. 14 OIG, Early Assessment of Review Medicaid Integrity Contractors. 15 OIG, Early Assessment of Audit Medicaid Integrity Contractors. 16 OIG, The Medicare-Medicaid (Medi-Medi) Data Match Program, OEI-09-08-00370, 

April 2012. 

17 CMS established the Medi-Medi program in 2001 as a way to identify improper billing 

patterns by matching Medicare and Medicaid claims information for providers and 

beneficiaries. Section 6034 of the Deficit Reduction Act added section 1893 of the SSA, 

which permanently established the Medi-Medi program at section 1893(g), P.L. 109-171 

§ 6034. 

18 CMS established the IDR in 2006 as a central repository for Medicare and Medicaid 

data. It is intended to help CMS program integrity staff and contractors (including 

Medi-Medi contractors) prevent and detect improper payments across the Medicare and 

Medicaid programs. Accessed at http://www.cms.gov/Research-Statistics-Data-andSystems/Computer-Data-and-Systems/IDR/index.html on March 5, 2013. 

19 OIG, The Medicare-Medicaid (Medi-Medi) Data Match Program. CMS indicated that 

the IDR would not contain Medicaid claims data until at least 2015. 

20 Peter Budetti, M.D., J.D., Program Integrity Efforts in the Medicare and Medicaid 

Programs, Testimony before the United State House Committee on Oversight and 

Government Reform, Subcommittee on Government Organization, Efficiency, and 

Financial Management, June 7, 2012. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 3 
 

 

 

 

 

that it was taking steps to create a more comprehensive information 

management strategy for Medicaid, the Children’s Health Insurance 

Program (CHIP), and State health systems.21 This included making 

improvements to MSIS. 

Transformed Medicaid Statistical Information System 

CMS’s efforts to improve MSIS will result in a new national Medicaid 

dataset called T-MSIS. Among CMS’s goals for T-MSIS are improving 

the completeness, accuracy, and timeliness of the data. CMS also intends 

for T-MSIS to be a way to limit the number of data requests States receive 

from CMS. To accomplish these goals, CMS is working with contractors 

to implement T-MSIS. 

T-MSIS is a continuation of CMS’s multiple past attempts to improve 

MSIS. In 2009, CMS conducted a pilot project for a national Medicaid 

database entitled MSIS Plus.22 CMS followed this with another pilot 

project for a database entitled MSIS Redesign in 2011.23 CMS’s goals for 

both of these databases were to create a more complete, accurate, and 

timely national Medicaid dataset and to limit data requests to States.24 

T-MSIS pilot project. CMS conducted a pilot project between March 2011 

and June 2012 to inform the development of T-MSIS. The pilot project, 

which incorporated lessons learned from the two previous attempts to 

improve MSIS, had two objectives: (1) identify the data elements required 

by all stakeholders and (2) identify a technical platform and environment 

able to accommodate T-MSIS and run stakeholder analytics. 

At the conclusion of the pilot project, CMS determined that it identified 

appropriate T-MSIS data elements. Internal CMS stakeholders confirmed 

that T-MSIS data elements were those that they need from States to 

conduct business functions and analysis, including national Medicaid 

program integrity activities.25 In addition, many data elements new to 

21 Ibid. 

22 Robb Miller & Yohannes Birre (CMS), MSISPLUS Pilot Project, presentation at 

MMIS Conference, Chicago, IL, August 19, 2009. Accessed at 

http://www.mmisconference.org/MMIS2009_Presentations_PDFs/Wednesday/The%20F 

uture%20of%20MSIS/Wednesday_MSIS_Birre.pdf on March 29, 2013.
 23 Federal IT Dashboard, MSIS Redesign. Accessed at 

http://www.itdashboard.gov/print/investment/project-summary/284 on March 5, 2013. 24 Robb Miller & Yohannes Birre, MSISPLUS Pilot Project; Ibid. 25 Internal stakeholders include multiple divisions within CMS that may use T-MSIS data
 

in the future: Center for Program Integrity, Center for Medicare & Medicaid Innovation, 

Financial Management Group, CHIP, Division of Pharmacy, and Center for Clinical
 

Standards and Quality. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 4 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 5 

 

 

 

T-MSIS address MSIS program integrity gaps identified by external 

stakeholders, such as OIG.26 

CMS also determined how to best construct a data platform to meet the 

data collection and analytic needs of CMS’s internal stakeholders. 

T-MSIS Data. There are approximately 1,000 data elements in T-MSIS, 

an expansion of the approximately 400 data elements collected in MSIS.27 

In general, CMS created T-MSIS data elements that responded to gaps in 

MSIS data identified by OIG and other stakeholders. 

CMS organized T-MSIS into eight files. T-MSIS files include eligibility, 

third-party liability, managed care plan information, provider, and four 

claims files (inpatient, long-term-care, outpatient, and pharmacy). 

CMS plans to make T-MSIS data files available approximately 60 days 

after the month in which the claims were processed.28 States will have 

1 month to submit T-MSIS data files (e.g., States will have until the end of 

February to submit January data). CMS plans to upload files to a data 

platform within 1 month of receiving States’ T-MSIS data files. 

National T-MSIS Implementation 

CMS has taken steps to establish the groundwork for States to begin 

implementing T-MSIS. CMS completed a number of activities to design 

T-MSIS so that States could begin implementing it. These activities 

include clarifying data elements, identifying critical data elements, 

completing some preliminary activities with States, and releasing data 

quality rules to States. See Figure 1 for a timeline of these activities. 

26 OIG, MSIS Data Usefulness for Detecting Fraud, Waste, and Abuse. 27 Jim Gorman (CMS), T-MSIS Pilot Overview, panel presentation at Medicaid Enterprise 

Systems Conference, Boston, MA, August 20, 2012. Accessed at 

http://www.mesconference.org/wpcontent/uploads/2012/08/Monday_TMSIS_Gorman.pdf on June 12, 2013. 28 CMS, T-MSIS Implementation Tool Kit, version 2.0, § 1.4, March 12, 2013. 
 

 

 

 

Figure 1: Timeline of T-MSIS Activities 

Active 

Readiness assessments (39 States) 

Mapping exercise (12 States) 

Status update meetings (12 States) 

Planned implementation phase (all States) 

Kickoff meetings (12 States) 

Pilot project 

Source: OIG analysis of CMS documents and structured interviews, 2013. 

Clarifying data elements and definitions. CMS published the T-MSIS 

data elements and definitions in a data dictionary.29 The data dictionary 

defines the data elements States must submit to CMS for T-MSIS. Along 

with indicating new data elements for T-MSIS, the data dictionary 

changed some of the definitions for data elements that States had been 

submitting as part of MSIS to clarify the information CMS wants States to 

submit. For example, one MSIS data element is “national provider ID.” 

CMS instructed the State on which provider identification number to 

submit for each claim file in the definition. CMS changed this data 

element in T-MSIS to 10 data elements to reflect the different possible 

provider IDs.30 

Identifying critical data elements. Following the pilot project, CMS 

assessed which T-MSIS data elements would be critical to support 

Medicaid and CHIP business needs, including meetings with internal 

stakeholders. As a result, CMS identified a subset of T-MSIS data 

elements as critical for business needs. Internal stakeholders identified the 

majority of T-MSIS data elements as critical. For example, the Center for 

29 CMS has released three T-MSIS data dictionaries. CMS released the first dictionary in 

February 2012, the second in February 2013, and the third in April 2013. 

30 The 10 T-MSIS data elements are: admitting provider national provider identifier 

(NPI) number, billing provider NPI, dispensing prescription drug provider NPI, health 

home provider NPI, operating provider NPI, prescribing provider NPI, referring provider 

NPI, servicing provider NPI, under direction of provider NPI, and under supervision of 

provider NPI. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 6 
 

 

 

 

Program Integrity identified more than two-thirds of T-MSIS data 

elements as critical.31 

Involving States. CMS partnered with 12 States (hereinafter referred to as 

volunteer States) that volunteered to work with CMS on the planning and 

development of T-MSIS. These States were in a position to be some of 

the first States to implement T-MSIS. CMS plans to phase in the 

remaining States in 2013.32 

CMS outlined 23 milestones to assist States in implementing T-MSIS. 

These milestones fall into four general stages: (1) planning, (2) design, 

(3) development, and (4) testing. CMS estimated that it would take States 

an average of 9 months to complete these milestones and implement 

T-MSIS.33 See Appendix A for a full list of these milestones.34 

Additionally, CMS held a series of meetings with volunteer States 

between April and December 2012. These meetings focused on volunteer 

States’ progress in implementing T-MSIS, including discussion of any 

challenges they may face and possible solutions or strategies to overcome 

them. 

In November and December 2012, CMS’s contractor worked with 

volunteer States to complete a data mapping exercise (hereinafter referred 

to as data matching exercise).35 This exercise consisted of volunteer 

States’ verbally confirming whether they could provide data that matched 

the T-MSIS data elements in the February 2012 T-MSIS data dictionary. 

The purpose of this exercise was to assess the status of the data dictionary 

and to identify any needed clarifications. This exercise informed the 

development of subsequent data dictionaries. 

Lastly, in December 2012, CMS conducted readiness assessments with the 

remaining States. CMS inquired about their readiness to begin 

implementing T-MSIS. 

31 CMS’s Center for Program Integrity, which conducts national Medicaid program 

integrity activities, is one of the internal stakeholders. See footnote 25. 

32 The volunteer States include Arizona, Arkansas, California, Michigan, Minnesota, 

New Jersey, New Mexico, North Carolina, Oregon, Tennessee, Texas, and Washington. 

These States represent approximately 40 percent of the Nation’s Medicaid expenditures. 

Jim Gorman (CMS), T-MSIS Pilot Overview; OIG analysis of data from
 

http://kff.org/state-category/medicaid-chip/, accessed on November 21, 2012. 33 CMS, Guidance for Automated Data Systems Requirements and Data Elements 

Necessary for Program Integrity, Program Oversight, and Administration, Version 

1.0. Provided to OIG on August 15, 2012.
 34 According to CMS staff, States are not required to complete all milestones. 

Additionally, States may not need to complete all milestones in order. See Appendix A 

for more details. 

35 CMS retained a contractor to assist with T-MSIS implementation.
 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 7 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 8 

Releasing data quality rules. CMS released data quality rules that 

addressed formatting T-MSIS data to all States on April 30, 2013. CMS 

expects States to apply these rules prior to submitting their T-MSIS data to 

CMS. These rules address some data standardization concerns that made 

MSIS data unusable for many national data analysis strategies (e.g., some 

States submit five-digit ZIP Codes to MSIS while other States submit 

nine-digit ZIP Codes). 

T-MSIS Guidance. CMS released a State Medicaid Director Letter on 

August 23, 2013.36 This letter provided an update to States on CMS’s 

ongoing effort to improve Medicaid data through T-MSIS.37 

METHODOLOGY 

This early implementation review determines the status of T-MSIS 

implementation as of January 2013. It also assesses the early outcomes 

from 12 States. 

Scope 

Our review focused primarily on the progress CMS and the 12 volunteer 

States had made. 

Our review also used the early outcomes from the 12 volunteer States to 

determine whether T-MSIS will provide complete and accurate national 

Medicaid program integrity data upon national implementation. We did 

not assess the timeliness of T-MSIS data submissions. Because the 

12 volunteer States were not submitting T-MSIS data at the time of our 

review, we could not determine States’ ability to report T-MSIS data a 

month after claims were processed or the ability of CMS to release 

T-MSIS data a month after receiving the data. 

Additionally, we did not assess individual State data elements or States’ 

capacity to modify their data to comply with T-MSIS requirements. 

Further, we did not assess the quality of States’ data or the usefulness of 

those data in conducting State program integrity activities. 

36 CMS, State Medicaid Director Letter, August 23, 2013, (SMD# 13-004). Accessed at
 

http://www.medicaid.gov/Federal-Policy-Guidance/Downloads/SMD-13-004.pdf on
 

September 3, 2013. 

37 Included in this update was a change to CMS’s implementation deadline. In the letter, 

CMS stated its goal is to have all States submitting monthly T-MSIS data by 

July 1, 2014. This change was made after OIG completed its analysis and has no effect 

on the findings of this report. 
 

Data Sources 

Document Request. We requested from CMS all documents related to the 

status of T-MSIS implementation and CMS’s plans for national 

implementation. Primarily, these documents included: 

	 meeting minutes between CMS and volunteer States (occurred 

between April and December 2012), 

	 project schedules and status updates (as of January 2013), 

	 State readiness assessment notes (occurred primarily in 

December 2012), 

	 T-MSIS data dictionaries, and 

	 T-MSIS Implementation Tool Kit. 

See Appendix B for a detailed description of these documents. We 

received documents from CMS through April 2013. 

Data Matching Exercise. CMS’s contractor conducted a data matching 

exercise with each volunteer State. During this exercise, volunteer States 

verbally informed the contractor whether each T-MSIS data element that 

was in CMS’s original February 2012 data dictionary was available in its 

data systems. The contractor entered the results of this exercise into a 

spreadsheet. CMS provided the results spreadsheet to OIG. 

The exercise reviewed 769 data elements. This is fewer than the 

approximately 1,000 data elements that CMS expects T-MSIS to have 

upon completion. At the time of our data collection, CMS was still 

determining the final data elements. For example, during the exercise, 

CMS identified 29 of the 769 data elements for removal. 

Structured Interviews. Between November 2012 and January 2013 we 

conducted multiple structured interviews with CMS officials and CMS’s 

contractor responsible for designing and implementing T-MSIS. We 

asked about the progress toward national T-MSIS implementation and 

CMS’s plans. 

Determining the Status of T-MSIS Implementation 

To determine the status of T-MSIS implementation as of January 2013, we 

analyzed project schedules, meeting minutes, and information gathered 

during structured interviews with CMS and CMS’s contractor. We 

reviewed project schedules and meeting minutes to identify the volunteer 

States’ progress on completing the milestones. We used the milestone 

checklist from the T-MSIS Implementation Tool Kit to identify the 

milestones that CMS laid out for States. We reviewed the meeting 

minutes and information gathered during structured interviews to identify 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 9 
 

 

steps CMS took to implement T-MSIS and move forward with additional 

States. We also reviewed the meeting minutes and information from 

structured interviews for indications of which milestones States had 

completed. 

Determining Early Outcomes From Volunteer States 

We determine early outcomes from volunteer States for two issues: 

completeness and accuracy. 

Completeness. We analyzed 740 data elements in the data matching 

exercise results spreadsheet to determine early outcomes from the 

volunteer States. We excluded the 29 data elements that CMS identified 

for removal. Specifically, we reviewed volunteer States’ responses for 

indications of their ability to make T-MSIS data elements available to 

CMS. 

We calculated the percentage of all data elements in three categories for 

all volunteer States. The three categories we created to reflect volunteer 

State responses to T-MSIS data element availability were: (1) match 

available, (2) match available but data may have gaps, and (3) match not 

available. See Appendix C for a definition of each category. We 

completed this calculation for each T-MSIS file and each volunteer State. 

Further, we calculated how many and what percentage of all T-MSIS data 

elements all volunteer States had available. 

We repeated these calculations for two subsets of T-MSIS data elements: 

(1) data elements deemed critical by CMS entities conducting program 

integrity work and (2) data elements that were included in MSIS. 

Accuracy. We analyzed the data matching exercise results spreadsheet 

and information from interviews with CMS to determine whether 

volunteer States’ early outcomes indicated potential accuracy concerns. 

We analyzed the spreadsheet and information from interviews with CMS 

to determine the extent to which early outcomes indicated that: (1) data 

will reflect T-MSIS data dictionary definitions and (2) source data may be 

inaccurate. 

We analyzed notes in the spreadsheet in which CMS, CMS’s contractor, 

or volunteer States indicated potential accuracy concerns. When possible, 

we counted instances in which such notes indicated accuracy concerns and 

calculated the percentage of data elements with accuracy concerns. 

Limitations 

This study reports on CMS’s plans for national implementation of 

T-MSIS, as well as the status and outcomes of national implementation as 

of January 2013. OIG recognizes that the status of implementation and 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 10 
 

even CMS’s plans may have changed by the time OIG releases this report. 

Further, given the early nature of national implementation, we were unable 

to assess the States’ ability to submit complete, accurate, and timely data. 

Rather, we used the volunteer States’ early implementation outcomes as 

indicators for what CMS and the remaining States might encounter during 

implementation. 

At the time of our data collection, the data matching exercise was the best 

available proxy for the data that volunteer States had available. Because 

the exercise covered 740 of the 1,000 data elements in T-MSIS, it is a 

strong indicator of States’ ability to provide the T-MSIS data elements. 

However, the data elements in the exercise were not the final version of 

T-MSIS data elements that CMS will ask States to submit. Subsequent to 

this exercise, CMS made definitional changes and refined record layouts 

in an updated data dictionary. This means that States’ ability to submit the 

final data elements may differ from our results. In addition, the data from 

the exercise are self-reported State data. We did not verify whether States 

could actually provide the data that they reported they could. 

We could not calculate a percentage for all types of accuracy concerns 

mentioned by CMS and States. When we could confidently interpret a 

comment on the data matching exercise results spreadsheet as a potential 

accuracy concern, we counted it and calculated a percentage. In other 

instances, when we could not confidently interpret a comment as a 

potential accuracy concern, we relayed the nature of the concern. 

Standards 

This study was conducted in accordance with the Quality Standards for 

Inspection and Evaluation issued by the Council of the Inspectors General 

on Integrity and Efficiency. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 11 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 12 

FINDINGS 

Twelve Volunteer States Made Some Progress 

Implementing T-MSIS; However, Most Other States 

Had Not Started 

As of January 2013, the 12 volunteer States had made progress toward 

T-MSIS implementation, but most of the remaining States had not started. 

The volunteer States completed, on average, 7 of the 23 T-MSIS 

milestones in the 6 months from when implementation began in July 2012. 

Seventeen additional States indicated that they were ready to start 

implementation in 2013. The remaining 22 States did not have a 

timeframe for starting implementation. 

While volunteer States made some progress, they may exceed 

the estimated implementation time 

As of January 2013, all volunteer States had completed some of the 

T-MSIS implementation milestones but no volunteer State had completed 

all of them. 

Volunteer States made the most progress in the first stage, planning. All 

volunteer States completed or partially completed the seven milestones 

associated with this stage. However, only five volunteer States completed 

all of the milestones associated with this stage. 

No volunteer States completed the other three stages—design, 

development, and testing. Further, four volunteer States have not started 

working on milestones associated with development and testing. Table 1 

is a broad overview of the progress that volunteer States made in the 

four stages. For a complete breakdown of volunteer States’ progress by 

individual implementation milestone, see Appendix D. 

Table 1: Volunteer States’ Progress Toward T-MSIS Implementation 

Milestones 

Milestone Stages Completed Partially Completed Not Started 

1. Planning (7 milestones) 5 7 0 

2. Design (6 milestones) 0 12 0 

3. Development (3 milestones) 0 8 4 

4. Testing (7 milestones) 0 7 5 

Source: OIG analysis of T-MSIS project schedules and volunteer State status updates, 2013. 

Volunteer States experienced some delays that may have hindered their 

progress, including delays finalizing contracts to assist with T-MSIS 

implementation. Securing contracts is part of identifying T-MSIS project 

resources, which is a stage 1 milestone, but delays in contracts also affect 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 13 

 

 

States’ ability to complete other milestones, such as mapping their data 

elements to the T-MSIS data elements. Five volunteer States indicated 

that they faced delays of this nature. 

Volunteer States also faced delays because CMS did not release needed 

information when it initially expected. For instance, CMS initially 

expected that it would release the revised T-MSIS data dictionary in 

September or October 2012. In fact, CMS did not release the revision 

until February 2013, delaying volunteer States’ ability to re-map their data 

elements to T-MSIS data elements. Further, CMS did not release the data 

quality rules until April 2013. Volunteer States need these rules to 

develop and test data verification/business rules and to validate 

successfully the eight T-MSIS data files. 

Possibly because of these delays volunteer States completed fewer 

milestones, on average, than would be expected at this point in CMS’s 

estimated 9-month completion timeframe. Volunteer States worked on 

milestones for at least 6 months by the time of our data collection, but 

were able to complete only between 3 and 13 of them, mainly in the 

planning phase. To stay on schedule to complete the milestones within the 

estimated 9-month completion time, States would have to complete the 

design, development, and testing of T-MSIS in 3 months. 

The remaining 39 States may not face the same challenges that volunteer 

States faced. CMS’s experiences with the volunteer States may enable it 

to work with the remaining States to avoid similar challenges and thus 

have fewer delays. In addition, CMS has released the data quality rules, 

so the remaining States will not have to wait for those as they begin 

implementing T-MSIS. However, the remaining States may still 

experience delays, such as those related to finalizing contracts or 

challenges unique to their States. 

The remaining 39 States reported varied timeframes for when 

they can begin implementing T-MSIS 

As of the December 2012 readiness assessments, 17 of the remaining 

39 States indicated to CMS that they anticipate being ready to begin 

implementing T-MSIS in 2013. The final 22 States did not indicate when 

they could begin implementing T-MSIS.38 These States listed various 

reasons for their hesitation, including lack of information about T-MSIS 

and competing demands for State resources. 

38 Included in the group of 22 States that did not have a timeline for T-MSIS 

implementation are 4 States for which OIG did not receive records of their readiness 

assessments. These States are Iowa, Missouri, New Hampshire, and Wyoming. 
 

 

CMS Has Not Established a Deadline for When 

National T-MSIS Data Will Be Available 

CMS does not have a specific timeframe for when it will begin to rely on 

T-MSIS as the sole national Medicaid dataset. Further, CMS does not 

have a timeline for switching completely from the use of MSIS data to 

T-MSIS data. Instead, the switch from MSIS to T-MSIS will happen over 

time on a State-by-State basis. CMS staff indicated that each State will 

switch from MSIS to T-MSIS only after it demonstrates operational 

readiness to implement T-MSIS and successfully transmits T-MSIS data. 

Additionally, CMS has not clearly defined when it expects all States to 

complete T-MSIS implementation. In August 2012, CMS staff stated that 

the goal was for all States to submit T-MSIS data as of January 1, 2014. 

In anticipation of that goal, CMS indicated that its goal was to be ready to 

accept data from States by that date. However, later, in 2013, CMS staff 

indicated that CMS modified its expectation for States by saying that all 

States should be either working on T-MSIS or committed to working on 

T-MSIS by January 1, 2014. CMS added terms and conditions on funding 

secured through an APD to reflect this shift. CMS staff indicated that 

States that are not submitting T-MSIS data by January 1, 2014 must 

develop a work plan to submit T-MSIS data as soon as possible. 

What steps CMS might take to enforce any deadline is unclear. When 

States asked whether there was flexibility in meeting the January 2014 

deadline or whether there were penalties for not doing so, CMS staff 

informed States that they were uncertain whether CMS would impose any 

penalties and what those penalties might be. CMS’s ability to enforce a 

deadline is a concern because 8 of the 39 remaining States asked CMS 

about the January 2014 deadline during the readiness assessments; 3 States 

asked specifically about potential penalties for not meeting the deadline. 

Volunteer States Indicated That Their Data Systems 

Did Not Have All T-MSIS Data Elements 

Upon implementation, T-MSIS will likely not contain all data elements 

across all volunteer States for two primary reasons. First, volunteer States 

indicated that they do not have data available for all T-MSIS data elements 

in their State data systems. Second, CMS’s T-MSIS processes allow 

States to submit a subset of T-MSIS data elements. 

Volunteer States do not have complete T-MSIS data available 

Results from the data matching exercise indicated that no volunteer State 

could make all of the 740 data elements available for T-MSIS. In other 

words, States indicated that their data systems do not capture data that 

could match every T-MSIS data element. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 14 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 15 

 

Volunteer States’ reported mixed abilities to make data available for 

T-MSIS data elements. Data availability ranged from 9 percent of data 

elements to 81 percent; 11 of the 12 volunteer States reported data 

available for more than 50 percent of the data elements. Data for the 

remaining data elements were either not currently available or available 

with indications of gaps in the data.39 T-MSIS data element availability by 

volunteer State is represented in Figure 2. To see each volunteer States’ 

data element availability by file, see Appendix E. 

Figure 2: T-MSIS Data Availability by Volunteer State 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

CA TX MI AR NM MN AZ TN WA OR NC NJ 

Match not 

available 

Match available 

but data may 

have gaps 

Match available 

Source: OIG analysis of data matching exercise results spreadsheet, 2013. 

CMS faces similar challenges with data availability for T-MSIS data 

elements deemed critical for program integrity activities by the Center for 

Program Integrity as it does for T-MSIS data elements as a whole. The 

percentage of data elements that were critical for program integrity was 

similar to the overall percentage of available T-MSIS data elements. 

Specifically, States’ individual abilities to make data available for critical 

program integrity data elements ranged from 9 percent to 84 percent; 11 of 

the volunteer States reported at least 50 percent of these critical T-MSIS 

elements as available. This similarity is unsurprising because the Center 

for Program Integrity deemed two-thirds of the data elements as critical 

for conducting national Medicaid program integrity activities. 

States also indicated that data for T-MSIS data elements that were also 

required as part of MSIS may not be available. Data for T-MSIS data 

elements that were also in MSIS (28 percent of T-MSIS data elements) 

39 Examples of gaps in data include: notes saying that a volunteer State had certain data 

available only for fee-for-service claims or notes indicating that a volunteer State had 

only a subset of the values that CMS requested for T-MSIS data elements. Data that are 

not available are composed of all data elements for which volunteer States did not clearly 

have matches available. 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 16 

 

 

were slightly more available than T-MSIS data elements overall. 

Availability of these elements ranged from 13 percent to 87 percent; 11 

volunteer States reported at least 50 percent availability. 

A small percentage of the same T-MSIS data elements are available across 

all volunteer States. Approximately 4 percent (27 data elements) of 

T-MSIS data elements are available from all volunteer States. The 

percentage of data elements available from volunteer States increased to 

25 percent when we excluded California from our analysis. The results of 

California’s data matching exercise indicated an unusually high 

percentage of T-MSIS data elements for which matches were not 

available.40 For a list of the 27 data elements that all volunteer States can 

provide, see Appendix F. 

Upon implementation, CMS will accept, as complete, the data 

volunteer States have available 

CMS will create an individualized control file for each volunteer State. 

These files will specify the T-MSIS data elements that each volunteer 

State reports it is able to provide upon implementation. These files will be 

created after States submit formal mapping documents to CMS and CMS 

reviews the results for completeness.41 States will need to justify their 

reasons for not providing specific data elements and provide an action 

plan to obtain the missing data elements. CMS will use each volunteer 

States’ individualized files to determine whether their data submissions 

are complete. 

Modifications to volunteer States’ initial individualized control files after 

implementation depend on the State. In some cases, the initial 

individualized files will represent a subset of T-MSIS that encompasses all 

of the data elements a State will be required to submit. For example, 

Arkansas does not use managed care plans for its managed care program, 

so it does not have the data elements requested in the T-MSIS managed 

care plan information file, nor would CMS expect Arkansas to submit 

those data. In other cases, CMS will alter States’ initial individualized 

control file to include additional data elements as the States expand the 

number of data elements they are able to provide. 

40 Specifically, California indicated that 81 percent of elements were “TBD” (i.e., to be 

determined). California indicated that mapping its data to the T-MSIS data elements 

would involve reviewing 24 internal data sources. 

41 States’ mapping documents indicate, in writing, which data elements available in their 

State systems map to the T-MSIS data elements in the April 2013 data dictionary. 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 17 

CMS and Volunteer States Reported Concerns About 

the Accuracy of T-MSIS Data 

CMS and volunteer States raised concerns about States’ ability to submit 

accurate T-MSIS data. CMS, CMS’s contractor, and volunteer States 

raised two types of concerns during the T-MSIS data matching exercise 

about whether the T-MSIS data submitted by States will be accurate. The 

first concern is that data from States may not reflect the definition of the 

T-MSIS data element in question. For example, while CMS requests that 

States report the data element for birth weight in grams, some States 

indicated that they would report birth weight in pounds. The second 

concern is that State source data may be inaccurate. For example, in some 

cases, State agencies other than the States’ Medicaid agencies collect and 

store the data necessary for T-MSIS. Some volunteer States indicated 

concerns that they cannot guarantee the accuracy of data collected and 

stored by these other State agencies. 

CMS and its contractor described three reasons why T-MSIS data may not 

reflect the data element definitions: (1) different derivation methods may 

cause inconsistent data reporting, (2) T-MSIS data element definitions 

may be unclear, and (3) States may submit data that do not match the data 

element definitions. 

CMS questioned whether volunteer States’ derivation methods when 

pulling or deriving T-MSIS data elements from sources outside MMIS 

would lead to inconsistent data reporting across volunteer States. For 

example, CMS expressed concerns over whether the data elements 

indicating an individual’s disability status were derived consistently across 

States because States may use and store disability codes in different ways. 

CMS had this concern for 19 percent of T-MSIS data elements. 

Additionally, CMS’s contractor expressed concerns about whether CMS 

clearly defined some data elements. Some data element definitions lacked 

specificity that could lead to the submission of inaccurate data. For 

example, CMS’s contractor noted that the definition for “billing location” 

needed clarification. CMS’s contractor explained that volunteer States 

were unsure whether this data element asks for the location of where a 

service was performed or where the physician’s main business office is 

located.42 

CMS’s contractor also raised concerns that States may submit data that do 

not match CMS data element definitions. CMS’s contractor noted that 

many volunteer States collect data concerning beneficiary ethnicity and 

42 Not all medical services are provided at the physician’s main business address; many 

physicians perform services in both an office setting and a hospital setting. 
 

 

 

financial assistance through State agencies other than the State Medicaid 

agencies. These other State agencies may not code the data according to 

T-MSIS data element definitions. 

Volunteer States also expressed potential accuracy concerns for a small 

percentage of data elements. Volunteer States’ comments indicated 

potential accuracy concerns related to their ability to submit data that 

reflected the data element definitions and the accuracy of their source data. 

Potential accuracy concerns ranged by State between 2 percent and 

9 percent of data elements for which they had matches available. For a 

breakdown of available data elements with potential accuracy concerns by 

State, see Table 2. 

Table 2: Available T-MSIS Data Elements with Potential Accuracy 

Concerns Identified by Volunteer State 

States Number 

Available 

Number of Accuracy 

Concerns 

Percentage With 

Accuracy Concerns 

AR 470 18 4% 

AZ 491 15 3% 

CA 69 5 7% 

MI 432 18 4% 

MN 479 43 9% 

NC 598 33 6% 

NJ 598 13 2% 

NM 479 15 3% 

OR 597 11 2% 

TN 547 27 5% 

TX 409 24 6% 

WA 575 42 7% 

Source: OIG analysis of data matching exercise results spreadsheet, 2013. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 18 
 

CONCLUSION AND RECOMMENDATIONS 

Although CMS and 12 volunteer States have made some progress with 

T-MSIS, early T-MSIS implementation outcomes raised questions about 

the completeness and accuracy of T-MSIS data upon national 

implementation. Creating and obtaining a national Medicaid dataset is a 

complex endeavor given the structure of the Medicaid program. To that 

end, CMS has planned and designed a dataset that appears to addresses 

various stakeholder data needs and concerns, including the planned 

collection of data elements important for national Medicaid program 

integrity strategies. However, early evidence raises concerns about 

volunteer States’ abilities to submit complete and accurate T-MSIS data; 

only 25 percent of T-MSIS data elements from the February 2012 data 

dictionary were available from all volunteer States.43 Additionally, limited 

implementation progress has delayed CMS’s and States’ abilities to test 

monthly submission requirements. 

The early outcomes of volunteer States’ efforts to implement T-MSIS may 

also provide insight into the remaining 39 States’ abilities to implement 

T-MSIS. Specifically, the remaining States may also not have all T-MSIS 

data elements available in their data systems. Further, many of the 

potential accuracy issues identified by CMS and volunteer States may also 

exist in the remaining States’ T-MSIS data. 

Complete, accurate, and timely national Medicaid data are essential to 

help protect the integrity of Medicaid. CMS has multiple program 

integrity projects underway that require T-MSIS data to be fully 

functional. Additionally, OIG and other external stakeholders could more 

effectively protect Medicaid with complete, accurate, and timely national 

Medicaid data. 

The earlier T-MSIS is fully functional, the earlier CMS and others can 

support States by using advanced data analytics nationally to monitor 

Medicaid to prevent fraud, waste, and abuse. To help create a fully 

functional T-MSIS, we make the following recommendations to CMS. 

CMS Should Establish a Deadline for When National T-MSIS 

Data Will Be Available 

CMS should provide a deadline so that stakeholders know when to expect 

data that is of sufficient completeness and quality that it can be effectively 

used for program integrity activities. CMS should provide a deadline by 

which all States need to be submitting complete T-MSIS data. As part of 

its effort to establish a deadline, CMS should provide a clear and 

43 Excluding California. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 19 
 

 

transparent timeline for the rest of the implementation process so that 

States know what is expected of them. The timeline should clearly 

identify when the remaining States must begin working on T-MSIS. 

To communicate a deadline and timeline to States and stakeholders, CMS 

could issue a State Medicaid Director letter or other policy guidance. This 

letter or guidance could document what the deadline is for State 

implementation and what is required of States as they implement T-MSIS, 

as well as communicate to stakeholders when T-MSIS will be complete 

and usable for national Medicaid activities, including program integrity. 

To be more transparent about the status of T-MSIS implementation, CMS 

could provide periodic updates to stakeholders. This could be 

accomplished in numerous ways, such as a regularly updated Web site or 

regular status updates sent to stakeholders. Updates should include a 

status of each State’s T-MSIS implementation. 

CMS Should Ensure That States Submit Required T-MSIS Data 

CMS should clearly state that T-MSIS is required. If States fail to begin 

submitting T-MSIS data by the implementation deadline, CMS should use 

its enforcement mechanisms to compel States to begin submitting required 

T-MSIS data. CMS has two statutory enforcement mechanisms (i.e., 

withhold matching payments for data systems or withhold matching 

payments for medical assistance for managed care enrollees) that could be 

used if States do not begin submitting T-MSIS data by the deadline. 

CMS may also want to seek legislative authority to employ alternative 

tools to compel State participation, such as interim sanctions for States 

that do not implement T-MSIS by the deadline. Alternatively, CMS could 

seek legislative authority to encourage State participation through an 

incentive program. 

This recommendation builds on a past OIG recommendation that CMS 

enforce the Federal requirements that States submit managed care 

encounter data.44 CMS responded that it intended to review statutory and 

regulatory authorities to determine areas in which it could strengthen the 

reporting of managed care encounter data. 

CMS Should Ensure That T-MSIS Data Are Complete, Accurate, 

and Timely Upon T-MSIS Implementation 

CMS should ensure that the submitted T-MSIS data are complete, 

accurate, and timely. The lack of complete, accurate, and timely MSIS 

data prevented it from being used effectively to protect the integrity of 

44 OIG, Medicaid Managed Care Encounter Data: Collection and Use. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 20 
 

Medicaid. CMS should work to ensure that these problems are not 

repeated in T-MSIS. 

CMS could establish standards for the completeness, accuracy, and 

timeliness of T-MSIS data that States should meet once they have 

implemented T-MSIS. These standards should establish specific 

expectations for the completeness, accuracy, and timeliness of the data. 

Establishing specific standards would allow CMS and other oversight 

bodies to hold States accountable for the quality and timeliness of their 

T-MSIS data. 

To enforce these standards, CMS could use existing accountability tools. 

Or CMS could seek legislative action for new tools that would compel 

States to submit data that are complete, accurate, and timely. 

CMS could work with States to ensure the submission of complete, 

accurate, and timely data. For example, to improve the completeness of 

T-MSIS data, CMS could work with States to identify ways that States 

could collect information that they currently do not collect that is needed 

to meet T-MSIS data requirements. To improve the accuracy of T-MSIS 

data, CMS could create standard derivation methods for States to use to 

ensure uniformly derived data elements. 

OIG has previously made a recommendation to CMS to improve the 

quality of nationally available Medicaid data so that better data are 

available for program integrity efforts. Specifically, OIG recommended 

that CMS improve the quality of data that program integrity contractors 

can access for conducting data analysis.45 CMS responded that it intended 

to develop improved data systems for Medicaid program integrity and that 

T-MSIS was the chosen system. 

45 OIG, Early Assessment of Review Medicaid Integrity Contractors. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 21 
 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

CMS concurred with our recommendations and provided details about 

ongoing activities in support of our recommendations. OIG acknowledges 

CMS’s already planned activities and encourages CMS to take the 

additional steps necessary to fulfill our recommendations and to ensure 

that T-MSIS is successful. 

For the first recommendation, CMS indicated that it is engaged in 

informing key internal stakeholders of when to expect data in the T-MSIS 

format. CMS also stated that it is working to issue a State Medicaid 

Director Letter that it believes will reinforce the importance of meeting the 

T-MSIS compliance date. One week after providing comments to this 

report, CMS issued this letter and provided a deadline for when “all States 

are expected to demonstrate operational readiness to submit T-MSIS files, 

transition to T-MSIS, and submit timely T-MSIS data.”46 OIG reiterates 

that our recommendation is that CMS should establish a deadline for when 

T-MSIS data that is complete, accurate, and timely will be available. This 

deadline may be different than a compliance deadline when States are 

capable of sending data to CMS in T-MSIS format. In addition, OIG 

encourages CMS to think broadly about T-MSIS stakeholders. A number 

of external stakeholders who conduct program integrity work could 

benefit from better quality national Medicaid data. They should also be 

updated as to the progress of T-MSIS and informed as to when T-MSIS 

data will be available. 

For the second recommendation, CMS believes that using the existing 

statutory enforcement mechanisms is an effective way to ensure timely 

T-MSIS data. OIG encourages CMS to include information about its 

intent to use the statutory enforcement mechanisms to enforce T-MSIS 

deadlines in any T-MSIS guidance provided to States. The State Medicaid 

Director Letter did not address T-MSIS enforcement mechanisms. 

For the third recommendation, CMS stated that it is working to create a set 

of data quality rules to govern T-MSIS data submission. CMS also plans 

to monitor States’ progress to ensure improved data reporting when 

T-MSIS data are not available at implementation. OIG encourages CMS 

to hold States accountable to the data quality rules. 

Having access to complete, accurate, and timely national Medicaid 

program integrity data is critically important. OIG will continue to 

46 CMS, State Medicaid Director Letter. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 22 
 

monitor T-MSIS beyond the early implementation phase to determine 

whether the identified vulnerabilities have been addressed. 

We did not make any changes to the report based on CMS’s comments. 

For the full text of CMS’s comments, see Appendix G. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 23 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 24 

 

APPENDIX A 

Implementation Milestones 

The Centers for Medicare & Medicaid Services (CMS) created the 

implementation milestones for States as a “high-level list of major 

milestones that States should consider within their schedule for successful 

implementation.”47 

States may not have to complete all of the milestones. In fact, States may 

not need to complete at least 2 of the 23 milestones. Specifically, not all 

States will need to complete milestones 5 and 6 (stage 1). Some States 

may not have to complete milestone 5—submitting an advanced planning 

document (APD) to CMS—because they may not require financial 

assistance to implement the Transformed Medicaid Statistical Information 

System (T-MSIS.)48 Some States may not need to complete milestone 6— 

hardware and software procurement completed—if they plan to use 

existing hardware and software. 

Additionally, CMS staff explained that States might not need to complete 

the milestones in order. For example, States may test their ability to send 

a sample of data to CMS (milestone 19) prior to completely mapping their 

State data elements to T-MSIS data elements (milestone 9). 

Planning 

1.	 T-MSIS on-boarding/orientations completed 

2.	 T-MSIS State-level project approvals obtained 

3.	 T-MSIS detailed project schedule developed 

4.	 T-MSIS project team identified 

5.	 APD submitted to CMS 

6.	 Hardware and software procurement completed 

7. T-MSIS project planning activities completed 

Design 

8.	 Data dictionary/data file/business rules review completed 

9.	 Data mapping for all eight files completed and base lined with 

CMS 

47 CMS, T-MSIS Implementation Tool Kit, version 2.0, § 3.4, March 12, 2013. 48 CMS requires States to submit APDs when they request financial assistance to make 

changes to their Medicaid Management Information Systems. See 42 CFR § 433.112. 

States use the APD to outline any changes they are making, the rationale for them, and 

their expected costs. 
 

10. Software development life cycle (SDLC) T-MSIS requirements 

phase completed 

11. Operational structure of data files defined 

12. Extract validation and format design defined 

13. SDLC T-MSIS design phase completed 

Development 

14. Data extraction process developed and tested (if applicable) 

15. Data verification/business rules developed and tested 

16. SDLC T-MSIS development phase completed 

Testing 

17. End-to-end data verification test planning complete – at State level 

18. SDLC end-to-end integration testing complete – at State level 

19. Successful transmission of test data to CMS 

20. Successful transmission of data file (all four claims files, 

eligibility, provider, managed care, third-party liability)
 

21. Successful validation of all data files (all four claims files, 

eligibility, provider, managed care, third-party liability) per 

business rules 

22. Production readiness approved by CMS (email to State) 

23. Submission of first set of monthly production file 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 25 
 

 

APPENDIX B 

Description of Documents Reviewed 

Meeting minutes: Records of status update meetings 

that occurred between the Centers 

for Medicare & Medicaid Services 

(CMS), its contractor, and the 

volunteer States. 

Project schedules and status updates: CMS records of initial schedules for 

the Transformed Medicaid Statistical 

Information System (T-MSIS) 

implementation and the status of 

implementation activities in the 

volunteer States. 

State Readiness Assessment Notes:	 Records of CMS’s readiness 

assessment calls with the remaining 

39 States to determine their ability to 

implement T-MSIS. 

T-MSIS Data Dictionaries: Documents containing the names, 

definitions, and format for T-MSIS 

data elements. 

T-MSIS Implementation Tool Kit: Roadmap for States to follow as they 

continue, or begin, implementing 

T-MSIS. Developed from CMS’s 

experience with the volunteer States, 

it contains milestones, guidance, and 

best practices. CMS expected to 

release this to all States in May 2013. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 26 
 

APPENDIX C 

Definitions of Office of Inspector General Completeness 

Categories 

Match Available: 

Available: Volunteer State indicated that it has this data 

element. 

Derivable: Volunteer State indicated that it could obtain the 

data element by performing a calculation, pulling 

from another file, or creating a crosswalk between 

existing data. For example, if a volunteer State 

indicated that a data element was stored in a 

different data system and required a crosswalk to 

fulfill the Transformed Medicaid Statistical 

Information System (T-MSIS) definition and 

format, we considered the data element derived. 

Match Available But Data May Have Gaps: 

Partially available: Volunteer State indicated that it may not have all of 

the information requested in the T-MSIS data 

dictionary definition. For example, if a volunteer 

State indicated that it could provide a certain data 

element for only fee-for-service claims, we 

considered the data element to be partially 

available. 

Match Not Available: 

Not available: Volunteer State indicated that it did not have the 

requested data element. 

To be determined: Volunteer State indicated that the requested data 

element was “TBD” or that it was still working to 

determine whether the requested data element was 

available. 

Unknown: We could not determine the availability of the data 

element using information from the data matching 

exercise results spreadsheet, or the volunteer State 

did not provide a response to the requested data 

element. 

Not applicable: Volunteer State indicated that a data element does 

not apply to it. For example, Arkansas has a limited 

managed care program and indicated that almost all 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 27 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 28 

 

 

of the data elements in the managed care file were 

not applicable.49 

49 Arkansas operates its Medicaid program through a primary care case management 

program. This means that providers are reimbursed on a fee-for-service basis for 

treatment and that the State does not have managed care plan information. Very few of 

the managed care plan information file data elements apply to Arkansas’s managed care 

program. 
APPENDIX D 

Progress Toward Milestones 

Table D-1: Individual States' Progress Toward T-MSIS* Milestones 

IV 

.E >. 0 Cll t: Ill IV IV t: Cll u Cll 0 IV IV ·c: IV 0 0 Ill ">( t: Ill Ill c, Ill t: ... - ... ... 01 Ill Cll 0 Ill IV t: 0 IV Cll 01 t: Milestone Cll .., Cll IV N g :E (.J >< t: ::!! t: Cll :E .Ill: ·;: u f!! ... (ij t: ..c: ~ ~ t: 1­ Ill < 0 :e t::: Cll Ql Ql < (.J :e 0 z z 1­ ~ z 

1. T-MSIS 

onboarding/orientations 

completed 

2. T-MSIS State-Level 

project approvals 

obtained 

3. T-MSIS detailed 

project schedule 

developed 

4 . T-MSIS project team 

identified 

5. Advanced planning 

document submitted to 

CMS** 

6. Hardware and 

software procurement 

completed 

7. T-MSIS project 


planning activities 


completed 


8. Data dictionary/data 


file/business rules 


review completed 


9. Data mapping for all 


eight fi les completed 


and base lined with 


CMS 


*T-MSIS =Transformed Medicaid Statistical Information System; **CMS =Centers for Medicare & Medicaid Services 

Note: Y = Completed milestone; P = Milestone in progress; X = Milestone not necessary; U = Progress unknown by Office of 

Inspector General (OIG); N = Milestone not complete. 

continued on next page 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12 -0061 0) 29 
Table D-1: Individual States' Progress Toward T-MSIS Milestones, 

continued 

ns 

s::: >­ 0 Q) s::: til ns ns s::: Q) (,) Q) ns ns £ '2 ns 0 0 ·;c s::: til til til s::: C) ... C) ... !!! til Q) 0 til ns s::: 0 Q) Q) ns C) s::: Milestone .., Q) )( ns N g :2 s::: 0 ::!1: s::: Q) :2 .ll:: ·;: (,) ~ ... iii s::: ..r::: ~ ~ s::: 1­ til < 0 i 1: Q) Q) Q) < 0 i 0 z z 1­ ~ z 

10. Software 

Development Life 

Cycle (SDLC) T-MSIS N p p p N N p p p p N p 

requirements phase 

completed 

11 . Operational 

structure of data files N p p p N N p p p p N p 

defined 

12. Extract validation 

and format design N N N p N N p p p p N p 

defined 

13. SDLC T-MSIS 

design phase N p p N N p p 

completed 

N I I I I 

14. Data extraction 

process developed and N p p p N N p p p 

tested (If applicable) 

N I I 

15. Data 

verification/business N p N N p p p p N p rules developed and 

tested 

development 

16. SDLC T-MSIS 

phase N 

•

p p p N N p p p p N p 

completed 

17. End-to-end data 

verification test N N N p N N p p p p p planning complete - at 

State level 

18. SDLC end-to-end 

integration testing N N N p N N p p p p p complete - at State 

level 

Note: Y = Completed milestone; P = Milestone in progress; X = Milestone not necessary; U = Progress unknown by Office of 

Inspector General (OIG); N =Milestone not complete. 

continued on next page 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-0061 0) 30 
Table D-1 : Individual States' Progress Toward T-MSIS Milestones, 

continued 

Milestone 

19. Successful 

1/) 

Cll 

1/) 

c 

Cll 

.II: 

.... 

< 

Cll 

c 

0 

N 

·;:: 

< 

Cll 

"2 

.... 

g 

iii 

u 

Cll 

c 0 c Cll >­ Q) 

c Q) 0 Q) 0 Cll - 0 ·;:c c 0 .... I!! 1/) 1/) Cl Cl 1/) 0 Q) Cll ., 

Q) Q) Cl 1/) 

Q) Cll -

c :2 >< c u :::!: Q) 0 ~ c :c c .s::. c 1­ 1/)

~ 0 t:: Q) Q) Q) 

~ == 0 z == z 1­ 3 z 

transmission of test data 

toCMS 

20. Successful 

transmission of data file 

(all four claims files, 

eligibility, provider, 

managed care, thirdparty liability) 

21. Successful 

validation of all data files 

(all four claims files, 

eligibility, provider, 

managed care, thirdparty liability) per 

business rules 

22. Production 

readiness approved by 

CMS (email to State) 

23 . Submission of first 

set of monthly 

production file 

Source: OIG analysis of T-MSIS project schedules and volunteer State updates, 2013 . 

Note: Y =Completed milestone; P =Milestone in progress; X = Milestone not necessary; U =Progress unknown by Office of 

Inspector General (OIG); N =Milestone not complete . 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12 -0061 0) 31 
 

 

APPENDIX E 

Availability of Transformed Medicaid Statistical Information 

System Data Elements by File for All Volunteer States 

Table E-1: Availability of Inpatient Claim File, by State 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

CA TX MI AR NM MN AZ TN WA OR NC NJ 

Match not available 

Match available but data may have 

gaps 

Match available 

Source: Office of Inspector General (OIG) analysis of data matching exercise results spreadsheet, 2013. 

Table E-2: Availability of Long-Term-Care Claim File, by State 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

CA TX MI AR NM MN AZ TN WA OR NC NJ 

Match not available 

Match available but data may have 

gaps 

Match available 

Source: OIG analysis of data matching exercise results spreadsheet, 2013. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 32 
 

Table E-3: Availability of Outpatient Claim File, by State 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

CA TX MI AR NM MN AZ TN WA OR NC NJ 

Match not available 

Match available but data may have 

gaps 

Match available 

Source: OIG analysis of data matching exercise results spreadsheet, 2013. 

Table E-4: Availability of Pharmacy Claim File, by State 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

CA TX MI AR NM MN AZ TN WA OR NC NJ 

Match not available 

Match available but data may have 

gaps 

Match available 

Source: OIG analysis of data matching exercise results spreadsheet, 2013. 

Table E-5: Availability of Eligibility File, by State 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

CA TX MI AR NM MN AZ TN WA OR NC NJ 

Match not available 

Match available but data may have 

gaps 

Match available 

Source: OIG analysis of data matching exercise results spreadsheet, 2013. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 33 
 

 

Table E-6: Availability of Managed Care File, by State 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

CA TX MI AR NM MN AZ TN WA OR NC NJ 

Match not available 

Match available but data may have 

gaps 

Match available 

Source: OIG analysis of data matching exercise results spreadsheet, 2013. 

Table E-7: Availability of Provider File, by State 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

CA TX MI AR NM MN AZ TN WA OR NC NJ 

Match not available 

Match available but data may have 

gaps 

Match available 

Source: OIG analysis of data matching exercise results spreadsheet, 2013. 

Table E-8: Availability of Third-Party Liability File, by State 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

CA TX MI AR NM MN AZ TN WA OR NC NJ 

Match not available 

Match available but data may have 

gaps 

Match available 

Source: OIG analysis of data matching exercise results spreadsheet, 2013. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 34 
 

 

APPENDIX F 

Transformed Medicaid Statistical Information System (T-MSIS) 

Data Elements Available in All Volunteer States 

Table F-1: T-MSIS Data Elements That All Volunteer States Reported as 

Match Available 

T-MSIS File Data element 

Claim: Inpatient Revenue units 

Claim: Pharmacy Medicaid Statistical Information System (MSIS) identification number 

Claim: Pharmacy Prescription fill date 

Claim: Pharmacy Prescription number 

Eligibility Basis of eligibility code 

Eligibility Children’s Health Insurance Program code 

Eligibility County code 

Eligibility County name 

Eligibility Date of birth 

Eligibility Days of eligibility 

Eligibility Eligible ZIP Code 

Eligibility Eligibility status end date 

Eligibility Eligibility status start date 

Eligibility Federal fiscal year month 

Eligibility First name 

Eligibility Health insurance coverage 

Eligibility Last name 

Eligibility Maintenance assistance status 

Eligibility Managed care plan enrollment end dates 

Eligibility Managed care plan enrollment start dates 

Eligibility Middle initial 

Eligibility MSIS case number 

Eligibility Restricted benefits code 

Eligibility Sex 

Eligibility Social Security Number 

Eligibility State 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 35 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 36 

 

 

Table F-1: T-MSIS Data Elements That All Volunteer States Reported as 

Match Available, continued 

T-MSIS File Data element 

Eligibility ZIP Code50 

Source: Office of Inspector General analysis of data matching exercise results spreadsheet, 2013. 

50 In the data matching exercise results spreadsheet, this data element was indicated as 

duplicative. Notes in the spreadsheet indicate that it was to be removed from the 

February 2013 data dictionary. 
APPENDIXG 

Agency Comments 

/"'''<q«t. \....4-	 DEPARTMENT OF HEALTH &'HUMAN SERVICES Centern for Medicare & Medicaid Services 

Administrator 

Washington, DC 20201 

DATE: AUG 1 5 2013 

TO: 	 Daniel R. Levinson 


!~spector General 


FROM: 	 Nlari~ T~e; 

Adminislratm: 


SUBJECT: 	 Office oflnspector General (OIG) Draft Report: "Early Outcomes Show Limited 

Progress for the Transformed Medicaid Statistical Information System" (OEI-05­

12-00610) 

The Centers for Medicare & Medicaid Services (CMS) appreciates the opportunity to review and 

comment on the above-referenced draft report. CMS concurs with all recommendations and is 

actively engaged in tasks to address these recommendations as part of the normal course of 

project activities. Please review additional details below relating to the recommendations, which 

have been broken out by topic area to more succinctly address the recommendation areas. 

OIG Recommendation 1 

The OIG recommends that CMS Should Establish a Deadline for When National T-MSIS Data 

Will Be Available. 

CMS should provide a deadline so that stakeholders know when to expect data that is of 

sufficient completeness and quality that it can be effectively used for program integrity activities. 

CMS should provide a deadline by which all States need to be submitting complete T-MSIS data. 

As part ofits effort to establish a deadline, CMS should provide a clear and transparent timeline 

for the rest ofthe implementation process so that States know what is expected ofthem. The 

time line should clearly identify when the remaining States must begin working on T-MSIS. 

CMS Response 

We concur. CMS is actively engaged in informing key stakeholders via CMS senior leadership 

data councils ofwhen to expect Medicaid and Children's Health Insurance Program (CHIP) 

operational data in the Transformed Medicaid Statistical Information System (T-MSIS) format. 

Standardized reports reflecting critical milestones in T-MSIS implementation activities are 

distributed and reviewed by said councils. In addition, all ofthe states have been instructed to 

add a series of critical milestones that are to be integrated into their internal project work plans . 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-0061 0) 37 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 38 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 39 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 40 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 41 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 42 
Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 43 
 

ACKNOWLEDGMENTS 

This report was prepared under the direction of Ann Maxwell, Regional 

Inspector General for Evaluation and Inspections in the Chicago regional 

office, and Thomas Komaniecki, Deputy Regional Inspector General. 

Nicole Hrycyk served as the team leader for this study, and Carolyn 

Pichert served as the lead analyst. Other Office of Evaluation and 

Inspections staff from the Chicago regional office who conducted the 

study include Emily Rowe and Cassie Yarbrough. Central office staff who 

provided support include Kevin Farber and Kevin Manley. 

Early Outcomes Show Limited Progress for T-MSIS (OEI-05-12-00610) 44 
Office of Inspector General

http://oig.hhs.gov 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as 

amended, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of beneficiaries served by those 

programs. This statutory mission is carried out through a nationwide network of audits, 

investigations, and inspections conducted by the following operating components: 

Office of Audit Services 

The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting 

audits with its own audit resources or by overseeing audit work done by others. Audits 

examine the performance of HHS programs and/or its grantees and contractors in carrying 

out their respective responsibilities and are intended to provide independent assessments of 

HHS programs and operations. These assessments help reduce waste, abuse, and 

mismanagement and promote economy and efficiency throughout HHS. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 

HHS, Congress, and the public with timely, useful, and reliable information on significant 

issues. These evaluations focus on preventing fraud, waste, or abuse and promoting 

economy, efficiency, and effectiveness of departmental programs. To promote impact, OEI 

reports also present practical recommendations for improving program operations. 

Office of Investigations 

The Office of Investigations (OI) conducts criminal, civil, and administrative investigations 

of fraud and misconduct related to HHS programs, operations, and beneficiaries. With 

investigators working in all 50 States and the District of Columbia, OI utilizes its resources 

by actively coordinating with the Department of Justice and other Federal, State, and local 

law enforcement authorities. The investigative efforts of OI often lead to criminal 

convictions, administrative sanctions, and/or civil monetary penalties. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to 

OIG, rendering advice and opinions on HHS programs and operations and providing all 

legal support for OIG’s internal operations. OCIG represents OIG in all civil and 

administrative fraud and abuse cases involving HHS programs, including False Claims Act, 

program exclusion, and civil monetary penalty cases. In connection with these cases, OCIG 

also negotiates and monitors corporate integrity agreements. OCIG renders advisory 

opinions, issues compliance program guidance, publishes fraud alerts, and provides other 

guidance to the health care industry concerning the anti-kickback statute and other OIG 

enforcement authorities.