Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

OVER FOUR MILLION 

MEDICARE SUMMARY 

NOTICES MAILED TO 

BENEFICIARIES WERE NOT 

DELIVERED IN 2012 

Stuart Wright 

Deputy Inspector General 

for Evaluation and Inspections 

January 2014 

OEI-03-12-00600 
 

EXECUTIVE SUMMARY: OVER FOUR MILLION MEDICARE SUMMARY NOTICES 

MAILED TO BENEFICIARIES WERE NOT DELIVERED IN 2012 

OEI-03-12-00600 

WHY WE DID THIS STUDY 

As part of its efforts to reduce Medicare fraud and abuse, the Centers for Medicare & Medicaid 

Services (CMS) relies on beneficiaries to report suspicious activity identified on their Medicare 

Summary Notices (MSNs). MSNs are paper forms that summarize processed claims. Claims 

processors are responsible for providing MSNs to beneficiaries. If MSNs go undelivered, 

beneficiaries do not have the opportunity to review the services or items billed to Medicare. The 

Department of Health and Human Services’ FY 2011 Agency Financial Report identified CMS’s 

lack of a policy for addressing undelivered MSNs as a weakness in the agency’s financial 

oversight of Medicare contractors. This study provides information on the quantity of undelivered 

MSNs and the procedures that claims processors use to handle undelivered MSNs. 

HOW WE DID THIS STUDY 

We requested from CMS any policies regarding undelivered MSNs. For claims processors in 

operation during 2012, we reviewed their written procedures and survey responses regarding 

tracking and followup procedures for undelivered MSNs. From claims processors’ survey 

responses, we determined the number of undelivered MSNs returned in 2012. In addition, we 

reviewed a purposive sample of 1,445 undelivered MSNs returned to 3 claims processing 

companies during the second full week of January 2013. For each undelivered MSN in our 

sample, we reviewed beneficiary addresses; identified compromised—e.g., stolen or misused— 

beneficiary and provider numbers; and calculated total Medicare-allowed amounts. 

WHAT WE FOUND 

Claims processors reported 4.2 million MSNs as undeliverable to beneficiaries. Without CMS 

guidance on undelivered MSNs, claims processors’ tracking and followup procedures are limited 

and varied. Claims processors identified incorrect or invalid beneficiary addresses as the most 

common reason why MSNs were undeliverable. We found that there continues to be a problem 

with incorrectly populated beneficiary addresses in the data systems that claims processors use to 

process MSNs. Some of the undelivered MSNs reviewed were associated with compromised 

beneficiary or provider identification numbers. 

WHAT WE RECOMMEND 

Undelivered MSNs that are returned to claims processors cannot be reviewed by beneficiaries as 

a defense against fraud. Therefore, CMS should reduce the likelihood that MSNs are 

undeliverable by ensuring that the address information that claims processors use to print 

addresses on MSNs is complete and properly formatted. To help promote consistency and 

efficiency in activities related to undelivered MSNs, CMS should provide guidance to claims 

processors about whether and how to track and follow up on undelivered MSNs. CMS 

concurred with our recommendations. 
TABLE OF CONTENTS 

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

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

Methodology................................................................................................3 

Findings........................................................................................................6 

Claims processors reported 4.2 million MSNs as undeliverable 

to beneficiaries.................................................................................6 

Claims processors’ procedures for tracking and following up on 

undelivered MSNs are limited and varied .......................................7
 

Conclusion and Recommendations ............................................................10 

Agency Comments and Office of Inspector General Response .....12 

Appendixes ................................................................................................13 

A: Number of Undelivered MSNs Reported by 

Claims Processors for 2012 ...........................................................13 

B: Agency Comments ...................................................................14 

Acknowledgments......................................................................................16 
 

 

 

 

OBJECTIVES 

To determine: 

1.	 the number and nature of undelivered Medicare Summary Notices 

(MSN) returned to claims processors; and 

2.	 the extent to which Medicare claims processors track and follow up on 

undelivered MSNs. 

BACKGROUND 

Medicare Summary Notices 

The Centers for Medicare & Medicaid Services (CMS) uses claims 

processors to perform the day-to-day claims administration for the 

Medicare fee-for-service program.1 As part of their responsibilities, claims 

processors must provide MSNs to approximately 37 million Medicare 

beneficiaries.2 

MSNs are the primary vehicle by which beneficiaries are notified of 

decisions on their Medicare claims.3 An MSN is a paper form sent to a 

beneficiary that summarizes the claims that have been processed on his or 

her behalf.4 MSNs list the services billed to Medicare, what Medicare 

paid for the services, and what the beneficiary may owe the provider. 

MSNs are sent at least quarterly to beneficiaries for whom claims were 

processed. 

MSNs and Fraud Detection 

MSNs serve as a fraud detection tool that beneficiaries can use to ensure 

that Medicare is paying for services or items that were actually provided to 

them. CMS recommends that beneficiaries check their MSNs carefully 

for suspicious charges, as services or items appearing on an MSN that 

were never provided may be a sign of fraudulent activity. In June 2013, a 

CMS official stated that beneficiaries’ “best defense against fraud is to 

check their MSNs for accuracy and to diligently protect their health 

information for privacy.”5

 An OIG report found that in 2001, almost half 

1

 The fee-for-service program includes items and services covered by Medicare Parts A 

and B. 

2

 CMS, Medicare Claims Processing Manual, Pub. No. 100-04, ch. 21 § 10. 3

 Ibid. 

4

 A beneficiary may submit a claim to Medicare for direct reimbursement using Form
 

CMS 1490S (Patient’s Request for Medical Payment). In these cases, reimbursement 

checks are included with MSNs sent to beneficiaries.
 5

 CMS, Medicare Urges Seniors to Join the Fight Against Fraud. Accessed at 

http://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-Releases/2013-PressReleases-Items/2013-06-06.html on June 10, 2013. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 1 
 

 

 

 

 

of beneficiaries who thought they had experienced Medicare fraud 

reported it and most beneficiaries regularly read their claim statements.6 

In recent years, CMS has worked with beneficiaries to redesign the MSN 

to make it easier to spot and report potential fraud on claims submitted for 

their care. CMS expected to begin mailing the new MSN to beneficiaries 

in summer 2013. 

As part of its efforts to reduce Medicare fraud and abuse, CMS relies on 

beneficiaries to report suspicious activity identified on their MSNs. For 

example, CMS uses beneficiaries’ complaints of suspected fraudulent 

billing on their MSNs to enhance its database of compromised beneficiary 

and provider identification numbers, known as the Compromised Number 

Checklist (CNC).7, 8 CMS sends an updated CNC to each benefit integrity 

contractor monthly and incorporates the CNC into its Fraud Prevention 

System, an initiative to identify aberrant and suspicious billing patterns 

prior to the payment of claims. 

Undelivered MSNs 

MSNs sometimes fail to reach the beneficiaries and are returned to claims 

processors. If MSNs go undelivered, beneficiaries do not have the 

opportunity to review the services or items billed to Medicare on their 

behalf. 

CMS’s Medicare Claims Processing Manual does not address whether or 

how claims processors should track and follow up on undelivered MSNs. 

The Department of Health and Human Services’ (HHS) Agency Financial 

Report for both fiscal years 2010 and 2011 highlighted CMS’s lack of a 

policy regarding undelivered MSNs, identifying it as a weakness in the 

agency’s financial oversight of Medicare contractors.9 These two reports 

stated that when beneficiaries cannot review their MSNs and notify CMS 

of any unusual services or charges, improper payments could go 

undetected. 

6

 OIG, Beneficiary Awareness of Medicare Fraud: A Follow Up, OEI-09-00-00590, 

November 2001. 

7

 Beneficiary Medicare identification numbers are known as Health Insurance Claim 

numbers. Provider Medicare identification numbers are known as National Provider 

Identifiers. In this report, we refer to beneficiary Medicare identification numbers as 

“beneficiary numbers” and provider Medicare identification numbers as “provider 

numbers.” 

8

 The CNC includes compromised provider and beneficiary numbers obtained through 

fraud investigations, reports of security breaches, and complaints from providers or 

beneficiaries. For example, a beneficiary number may be considered compromised if it is 

stolen or misused. 

9

 HHS, FY 2010 Agency Financial Report and FY 2011 Agency Financial Report, 

November 15, 2010, and November 14, 2011, respectively. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 2 
 

 

The Social Security Administration (SSA) maintains the address data that 

CMS provides to claims processors. The SSA address database is updated 

when a beneficiary registers a change of address through SSA or through 

the United States Postal Service (USPS). In addition, MSNs are sent as 

first class mail, which is forwarded if the beneficiary has provided the 

USPS with a forwarding address. 

Undelivered MSNs and Compromised Numbers. Undelivered MSNs may 

contain beneficiary or provider numbers that are compromised and have 

been fraudulently used to bill for services that were never provided. 

Sometimes, beneficiaries’ or providers’ numbers are stolen or used 

without their knowledge. Other times, the beneficiaries or providers are 

complicit in the scheme, receiving payment for the use of their identifiers. 

If claims billed by fraudulent providers appear on undelivered MSNs, 

noncomplicit beneficiaries do not have the opportunity to detect that 

Medicare was billed for services that they never received. 

METHODOLOGY 

Data Collection 

Documentation and Survey Data. We requested from CMS any policies 

regarding undelivered MSNs. From the 19 claims processors in operation 

during 2012, we requested standard written procedures used to track and 

follow up on undelivered MSNs. We requested that claims processors 

provide the total number of undelivered MSNs returned in 2012, as well as 

the total amount paid by Medicare for services listed on these undelivered 

MSNs. In addition, each claims processor completed a survey regarding 

tracking and followup activities for undelivered MSNs. As part of our 

survey, we asked claims processors about CMS’s requirements regarding 

the tracking and review of undelivered MSNs. 

Undelivered MSNs. For 3 companies that have claims processor contracts, 

we requested that each collect and send for our review the first 

500 undelivered MSNs received from January 13 to January 19, 2013. 

Table 1 shows the types of claims processed by these three companies. 

Table 1: Types of Claims Processed by the Companies That Provided Undelivered MSNs 

Types of Claims Processed by Three Selected Companies Number of Undelivered 

MSNs Requested 

Durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) claims 500 

Part A and Part B claims 500 

Part A, Part B, home health, and hospice claims1

 500 

Source: OIG analysis of a purposive sample of undelivered MSNs, 2013. 

1

 This particular company had two claims-processing contracts. A single company may have more than one claims-processing 

contract. We asked that company to provide the first 500 undelivered MSNs collectively received by its two claims processors. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 3 
 

 

Using the claim number(s) appearing on undelivered MSNs, we obtained 

the most recently updated claim record data from the Medicare National 

Claims History (NCH) through the Services Tracking, Analysis, and 

Reporting System (STARS).10 These claim records include the 

Medicare-allowed amount, the type of service, and the beneficiary and 

provider numbers. 

Although we requested 1,500 undelivered MSNs, our purposive sample 

included 1,445 undelivered MSNs. Examples of the 55 undelivered MSNs 

that were unusable for our purposes were those that had missing pages or 

lacked a claim record in the NCH file. Our final sample included 

398 undelivered MSNs for Part A services, 483 undelivered MSNs for 

Part B DMEPOS services, and 564 undelivered MSNs for other Part B 

services. These undelivered MSNs were associated with 5,461 claims 

contained in the NCH file.11 

Analysis 

We reviewed and summarized claims processors’ documentation and 

survey responses regarding their tracking and followup activities for 

undelivered MSNs. From claims processors’ survey responses, we 

determined the number of undelivered MSNs returned to claims 

processors in 2012. 

We compared each of the beneficiary and provider numbers on the 

undelivered MSNs in our sample to the April 2013 CNC to determine 

whether there were any compromised numbers on claims with allowed 

amounts greater than $0.00. For each address on the undelivered MSNs in 

our sample, we determined whether the address had been updated in 

STARS as of April 2013.12 Finally, we calculated the total allowed 

amounts associated with claims that appeared in our sample of undelivered 

MSNs. 

10 STARS extracts claim information from the NCH file. For 98 DMEPOS claims, we 

accessed NCH file claim information from the Integrated Data Repository. 11 We could not locate a claim record on the NCH file for 88 claim numbers that appeared 

on undelivered MSNs in our sample. These 88 claims were excluded from our analysis. 

Other claims that appeared on the same undelivered MSNs as these 88 claims were 

included in our analysis. 

12 STARS extracts beneficiary information from CMS’s Enrollment Database (EDB).
 

The beneficiary’s mailing contact address in the EDB is populated by address data from
 

SSA and the Railroad Retirement Board. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 4 
 

Limitations 

Our purposive sample of undelivered MSNs is not representative of all 

undelivered MSNs. It is also not representative of all undelivered MSNs 

returned to the three companies in our review. Therefore, the results of 

our analysis are limited to the undelivered MSNs we reviewed. 

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. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 5 
 

 

 

 

 

FINDINGS 

Claims processors reported 4.2 million MSNs as 

undeliverable to beneficiaries 

CMS did not monitor how many MSNs failed to reach Medicare 

beneficiaries during 2012. CMS did not require claims processors to 

report the number of undeliverable MSNs that were returned to them 

during calendar year 2012 and none of the claims processors reported to 

CMS the number of undeliverable MSNs returned that year. 

In 2012, claims processors mailed 194 million MSNs to beneficiaries. 

According to claims processors, approximately 4.2 million MSNs were 

returned as undeliverable in 2012. However, the volume of undelivered 

MSNs returned in 2012 is likely to be greater than 4.2 million, as 1 of the 

19 claims processors did not report the number of undelivered MSNs and 

7 claims processors provided data that did not cover the full calendar year. 

In addition, two claims processors reported the number of undelivered 

MSN envelopes—which may each contain multiple MSNs—rather than 

the number of undelivered MSNs.13 The remaining claims processors 

reported either counts or estimates that covered the full calendar year. 

Claims processors’ reports for the number of undelivered MSNs returned 

in 2012 are shown in Appendix A. 

Claims processors could not provide the total Medicare payment amounts 

associated with these undelivered MSNs. The allowed amounts associated 

with a sample of 1,445 undelivered MSNs returned in January 2013 

totaled $2.7 million.14 

Some undelivered MSNs were associated with compromised 

numbers 

Of 1,445 undelivered MSNs, 51 included paid claims that were associated 

with compromised beneficiary or provider numbers. Forty-seven 

undelivered MSNs were associated with compromised beneficiary 

numbers, and four undelivered MSNs were associated with compromised 

provider numbers. The allowed amounts on these undelivered MSNs 

ranged from $0.11 to $41,546 and totaled $165,983. 

13 According to CMS’s Medicare Claims Processing Manual (Section 10.3.2), if a claims 

processor’s system allows it to do so, and multiple MSNs are available for mailing, the 

claims processor may enclose all MSNs in the same envelope. 

14 Our sample included 398 undelivered MSNs for Part A services, 483 undelivered 

MSNs for Part B DMEPOS services, and 564 undelivered MSNs for other Part B 

services. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 6 
 

Claims processors’ procedures for tracking and 

following up on undelivered MSNs are limited and 

varied 

CMS requires claims processors to provide MSNs to Medicare 

beneficiaries, but it has not issued guidance regarding whether or how to 

track and follow up on undelivered MSNs. In practice, not all claims 

processors track or follow up on undelivered MSNs, and those that do 

utilize a variety of methods. According to CMS staff, when claims 

processors have requested guidance on the storage of undelivered MSNs, 

CMS has allowed claims processors to destroy the undelivered MSNs. 

However, CMS has not issued a written directive to all claims processors 

on the storage and/or destruction of undelivered MSNs. 

Although many claims processors track some information 

regarding undelivered MSNs, activities are inconsistent across 

claims processors 

Despite a lack of CMS guidance, 16 of 19 claims processors track some 

information regarding undelivered MSNs that are returned to them. These 

activities include tracking the quantity of undelivered MSNs, recording 

information about undelivered MSNs, and storing undelivered MSNs. 

Tracking the Number of Undelivered MSNs. Twelve of nineteen claims 

processors tracked undelivered MSNs to some extent. These claims 

processors reported using various techniques, including spreadsheets, 

machines that count the number of returned envelopes containing MSNs, 

and electronic filing systems that store scanned images of returned MSNs. 

Seven of these twelve claims processors could provide exact counts of the 

number of undelivered MSNs returned in 2012.15 Two additional claims 

processors could provide exact counts for only the returned MSNs that 

included checks for beneficiaries. Five of these twelve claims processors 

have written procedures outlining how they track undelivered MSNs. 

Recording Information About Undelivered MSNs. Six of nineteen claims 

processors record information about undelivered MSNs, including 

information listed on undelivered MSNs and information listed on 

beneficiary checks returned with undelivered MSNs. Among the six claims 

processors that record any information about undelivered MSNs, the most 

common pieces of information tracked were the beneficiary number, the 

beneficiary name, the claims processor contract number, the date the MSN 

was returned, and—for beneficiary checks returned with undelivered 

15 Three of these seven claims processors were affiliated with one company, which 

reported an exact count for the collective undelivered MSNs returned to its three claims 

processors. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 7 
 

MSNs—the check number. All of these six claims processors have written 

procedures for tracking information regarding undelivered MSNs. 

No claims processors track the allowed amounts associated with 

undelivered MSNs. However, two claims processors track the dollar 

amounts on beneficiary checks returned with undelivered MSNs. For 

these claims processors, $3.9 million in checks to beneficiaries were 

returned with 26,266 undelivered MSNs in 2012. 

Storing Undelivered MSNs. All but 1 of the 19 claims processors 

eventually destroy some or all of the undelivered MSNs that are returned 

to them. Eleven of nineteen store undelivered MSNs by keeping the 

originals, electronic copies, or both the originals and electronic copies. 

Four of the nineteen claims processors keep indefinitely only the returned 

MSNs that include checks for beneficiaries. One claims processor keeps 

all undelivered MSNs and reported spending $34,282 per year on storage. 

Eight of the eleven claims processors that store undelivered MSNs have 

written procedures regarding their storage practices. 

Half of claims processors attempt to verify addresses on 

undelivered MSNs, but few conduct any further followup 

Ten of nineteen claims processors attempt to determine a new or correct 

beneficiary address for any undelivered MSNs returned to them. All 

10 of these claims processors have written procedures. As part of their 

efforts, they compare the address for the undelivered MSN to addresses 

listed in the EDB, the Health Insurance Master Record (HIMR), the 

Common Working File (CWF), and/or the Shared Systems that claims 

processors use to process Medicare claims.16 In 2012, 5 of the 10 claims 

processors that verify addresses did so for all of their undelivered MSNs. 

Two of these claims processors report that they suppress future MSN 

mailings to undeliverable addresses until those addresses have been 

updated in their system. The remaining five claims processors verified 

addresses only for undelivered MSNs that were returned with beneficiary 

checks, lacked postage, or were not inserted into the envelope properly, 

which accounted for less than 3 percent of their undelivered MSNs in 

2012. 

Despite these efforts to identify new or correct beneficiary addresses, 

claims processors must use the addresses in their data systems for MSNs. 

These addresses come directly from SSA. Only beneficiaries can update 

16 SSA maintains the beneficiary address data that populate the HIMR, EDB, CWF, and 

Shared Systems. SSA maintains the Master Beneficiary Record (MBR) from which the 

HIMR is established, and beneficiary address data are transmitted electronically from the 

MBR to the EDB, from the EDB to the CWF, and from the CWF to the Shared Systems. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 8 
 

 

their SSA address information. When claims processors identify a new or 

corrected address, they may direct beneficiaries to contact SSA to register 

a change of address. 

Among the sample of undelivered MSNs we reviewed, there were no 

changes made to 71 percent of the corresponding beneficiary addresses 

(1,033 of 1,445) in CMS’s system 3 months after the MSNs were returned 

to claims processors. 

Five claims processors attempt to determine the reasons MSNs are 

undeliverable. Two of these five claims processors attempt to determine 

whether the services on undelivered MSNs are associated with a higher 

incidence of fraud, waste, and abuse. No claims processors refer 

information on undelivered MSNs to program integrity contractors. 

Claims processors identified incorrect or invalid addresses as 

the most common reason MSNs were undeliverable 

Among the five claims processors that attempt to determine the reason(s) 

MSNs were undelivered, the most common reason identified was incorrect 

or invalid addresses. Such addresses may result from formatting errors in 

the data systems used by claims processors to print addresses on MSNs. 

In 2006, CMS recognized that beneficiary address data from the CWF 

were not populating correctly into the Shared Systems because the address 

fields in the two had different line length and character configurations.17 

CMS instructed system maintainers to modify the Shared Systems to 

accept the complete CWF address.18 However, one claims processor 

continued to report that MSNs are returned in part because beneficiary 

address data from the CWF are populated incorrectly into the Shared 

Systems. In addition, our review of sampled undelivered MSNs identified 

incomplete beneficiary addresses that appeared to result from incorrectly 

populated data. For example, a street address on an undelivered MSN 

might appear as “WHERE BLVD,” when the street address data in STARS 

was “100 ANY WHERE BLVD.” 

According to claims processors, other reasons MSNs were undelivered 

include that the beneficiary was temporarily away, the address’s 

forwarding order had expired, the MSN had been inserted into the 

envelope improperly, and the envelope did not have sufficient postage. 

Among the undelivered MSNs reviewed, two envelopes were returned 

with handwritten notes indicating that the envelope had insufficient 

postage for a foreign address. 

17 CMS, Transmittal 205, Change Request 4224. CMS Manual System, Pub. No. 100-20, 

“Beneficiary Change of Address.”
 18 Effective July 1, 2006. 

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CONCLUSION AND RECOMMENDATIONS 

As part of its efforts to reduce Medicare fraud and abuse, CMS relies on 

beneficiaries to report suspicious activity identified on their MSNs. In 

fact, a CMS official stated in June 2013 that beneficiaries’ best defense 

against fraud includes checking their MSNs for accuracy. However, we 

found that at least 4.2 million MSNs did not reach some of these 

beneficiaries. Therefore, CMS is missing the opportunity to solicit these 

beneficiaries’ help in the fight against fraud. 

Claims processors are responsible for providing MSNs to Medicare 

beneficiaries, but CMS does not provide claims processors with guidance 

on whether or how to track or follow up on MSNs that are returned as 

undeliverable. In addition, the HHS FY 2011 Agency Financial Report 

identified CMS’s lack of a policy for addressing undelivered MSNs as a 

weakness in CMS’s financial oversight of Medicare contractors. While 

we do not know the amount paid by Medicare for services associated with 

undelivered MSNs, it may total hundreds of millions of dollars. 

Without guidance for handling undelivered MSNs, claims processors have 

developed their own approaches. However, these approaches are not 

consistent across the Medicare program because not all claims processors 

track or follow up on undelivered MSNs and those that do use a variety of 

methods. 

Among claims processors that attempt to determine reasons MSNs are 

returned as undeliverable, the most common reason identified was 

incorrect or invalid addresses. We found that that there continues to be a 

problem with incorrectly populated beneficiary addresses in the data 

systems that claims processors use to process MSNs. 

We recommend that CMS: 

Provide guidance to claims processors about handling MSNs 

that are returned as undeliverable 

To help promote consistency and efficiency in activities related to 

undelivered MSNs, CMS should provide guidance to claims processors 

about whether and how to track and follow up on undelivered MSNs. This 

guidance should include instructions to claims processors about whether 

or when and how to: 

 destroy or store undelivered MSNs, 

 keep a record of the number of undelivered MSNs, 

 record information about undelivered MSNs, 

 verify beneficiary addresses for undelivered MSNs, 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 10 
 

	 ensure that claims processors encourage beneficiaries to register a 

change of address with SSA when the claims processor is made aware 

of a new or corrected address, 

	 analyze information on undelivered MSNs to identify patterns 

indicative of potential fraud and abuse, and 

	 refer information on undelivered MSNs to program integrity 

contractors. 

Ensure that the address information used by claims 

processors to print addresses on MSNs is complete and 

properly formatted 

CMS should reduce the likelihood that MSNs are returned as 

undeliverable by ensuring that claims processors have access to the 

complete beneficiary address information maintained by SSA. Since 

July 2006, CMS has instructed system maintainers to ensure that the 

Shared Systems used by claims processors accept the complete beneficiary 

address from the CWF. CMS should ensure that the Shared Systems 

contain beneficiary addresses that match the addresses on file in the CWF. 

Given that we saw examples of incomplete addresses on our review of 

undelivered MSNs, CMS should also ensure that claims processors are 

formatting addresses correctly for printing on MSNs. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 11 
 

 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

CMS concurred with both of our recommendations. Regarding the first 

recommendation, CMS stated that its Office of Communication will work 

with the Center for Medicare and with claims processors’ Contracting 

Office Representatives to develop instructions as to what claims 

processors should do with undelivered MSNs that are returned to them. In 

addition, CMS stated that it will also explore with claims processors the 

possible actions that can be taken, within reasonable costs, to reduce the 

number of returned MSNs. 

In response to our second recommendation, CMS stated that it will work 

with SSA to determine if addresses are being altered between when SSA 

provides them to CMS and when the claims processors retrieve them from 

the CWF. CMS reported that if it finds that the addresses are being altered 

in any manner, it will work with appropriate parties to rectify the situation. 

OIG agrees that this is an appropriate step to take to ensure that 

beneficiaries are receiving their MSNs. 

OIG agrees that reducing the number of returned MSNs is an important 

step in protecting the integrity of Medicare. Ensuring that more 

beneficiaries receive their MSNs increases the opportunity for 

beneficiaries to participate in the fight against Medicare fraud and 

improper payments. 

The full text of CMS’s comments is provided in Appendix B. 

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APPENDIX A 

Number of Undelivered MSNs Reported by Claims Processors for 2012 

Table A-1 provides the number of undelivered MSNs reported by each of the 19 claims 

processors in operation during calendar year 2012. 

Table A-1: Number of Undelivered MSNs Reported By Claims Processors for 2012 

Claims Processor1 Number of Months for Which 

Claims Processors Reported Data 

Number of 

Undelivered MSNs 

Claims Processor 1 12 260,000 

Claims Processor 2 12 245,000 

Claims Processor 3 12 214,000 

Claims Processor 4 12 454,739 

Claims Processors 5, 6, and 7 combined2

 11 624,527 

Claims Processor 8 12 180,000 

Claims Processor 9 11 65,000 

Claims Processors 10 and 11 combined3

 12 1,057,266 

Claims Processor 12 11 178,835 

Claims Processor 13 4 146,319 

Claims Processor 14 12 181,889 

Claims Processor 15 12 233,997 

Claims Processor 16 Not provided Not provided 

Claims Processor 17 12 126,000 

Claims Processor 18 12 203,000 

Claims Processor 19 4 64,000

 Total 4,234,572 

Source: OIG analysis of claims processor surveys, 2013. 

1 We assigned a unique identifier to each of the 19 claims processors in operation in 2012. 2

 Claims processors 5, 6, and 7 are affiliated with the same company, which reported the collective number of undelivered MSNs returned 

to the three claims processors. 

3 Claims processors 10 and 11 are affiliated with the same company, which reported the collective number of undelivered MSNs returned to 

the two claims processors. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 13 
APPENDIX 8 

Agency Comments 

_..f>~"lC~ 

~~- li-t,
 (::f- DEPARIMENT OF HEALTii & HUMAN SERVICES Centers for Medicare & Medicaid Services 

Administrator 

Washington, DC 20201 

DATE: 

TO: 

FROM: 

SUBJECT: 

JAN -6 2014 

Daniel R. Levinson 

Inspector General 

Marilyn Tavenner 

Administrator 

Office oflnspector General (OIG) Draft Report: Over Four Million Medicare 

Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03­

12-00600) 

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

comment on the above referenced OIG draft report. The objectives of the report were to 

determine: (1) the number and nature of undelivered Medicare Summary Notices (MSN) 

returned to claims processors; and (2) the extent to which Medicare claims processors track and 

follow up on undelivered MSNs. 

The CMS response to each of the OIG recommendations follows: 

OIG Recommendation: 

The OIG recommend that CMS provide guidance to claims processors about handling Medicare 

Summary Notices (MSNs) that are returned as undeliverable. 

CMS Response: 

The CMS concurs with this recommendation. The Office ofCommunication will work with the 

Center for Medicare and the Medicare Administrative Contractor's (MAC) Contracting Officer 

Representative (CORs) to draft a continuing resolution that will provide instructions to the 

claims processors on what they should do with undelivered MSNs that are returned to them. 

CMS will also explore possible actions with the MACs that might reduce the number of returned 

MSNs that can be performed within reasonable costs. 

OIG Recommendation: 

The OIG recommend that CMS ensure that the address information used by claims processors to 

print addresses on MSNs is complete and properly formatted. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 14 
 

 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 15 
 

ACKNOWLEDGMENTS 

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. 

Tanaz Dutia served as the team leader for this study. Other Office of 

Evaluation and Inspections staff from the Philadelphia regional office who 

conducted the study include Joanna Bisgaier, Nancy J. Molyneaux, and 

Russell Tisinger. Central office staff who provided support include 

Scott Manley and Christine Moritz. 

Over Four Million Medicare Summary Notices Mailed to Beneficiaries Were Not Delivered in 2012 (OEI-03-12-00600) 16 
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.