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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

June 2011: 

Fraud Detection Systems: 

Centers for Medicare and Medicaid Services Needs to Ensure More 
Widespread Use: 

GAO-11-475: 

GAO Highlights: 

Highlights of GAO-11-475, a report to congressional requesters. 

Why GAO Did This Study: 

GAO has designated Medicare and Medicaid as high-risk programs, in 
part due to their susceptibility to improper payments—estimated to be 
about $70 billion in fiscal year 2010. Improper payments have many 
causes, such as submissions of duplicate claims or fraud, waste, and 
abuse. As the administrator of these programs, the Centers for 
Medicare and Medicaid Services (CMS) is responsible for safeguarding 
them from loss. To integrate claims information and improve its 
ability to detect fraud, waste, and abuse in these programs, CMS 
initiated two information technology system programs: the Integrated 
Data Repository (IDR) and One Program Integrity (One PI). 

GAO was asked to (1) assess the extent to which IDR and One PI have 
been developed and implemented and (2) determine CMS’s progress toward 
achieving its goals and objectives for using these systems to help 
detect fraud, waste, and abuse. To do so, GAO reviewed system and 
program management plans and other documents and compared them to key 
practices. GAO also interviewed program officials, analyzed system 
data, and reviewed reported costs and benefits. 

What GAO Found: 

CMS has developed and begun using both IDR and One PI, but has not 
incorporated into IDR all data as planned and has not taken steps to 
ensure widespread use of One PI to enhance efforts to detect fraud, 
waste, and abuse. IDR is intended to be the central repository of 
Medicare and Medicaid data needed to help CMS program integrity staff 
and contractors prevent and detect improper payments of Medicare and 
Medicaid claims. Program integrity analysts use these data to identify 
patterns of unusual activities or transactions that may indicate 
fraudulent charges or other types of improper payments. IDR has been 
operational and in use since September 2006. However, it does not 
include all the data that were planned to be incorporated by fiscal 
year 2010. For example, IDR includes most types of Medicare claims 
data, but not the Medicaid data needed to help analysts detect 
improper payments of Medicaid claims. IDR also does not include data 
from other CMS systems that are needed to help analysts prevent 
improper payments, such as information about claims at the time they 
are filed and being processed. According to program officials, these 
data were not incorporated because of obstacles introduced by 
technical issues and delays in funding. Further, the agency has not 
finalized plans or developed reliable schedules for efforts to 
incorporate these data. Until it does so, CMS may face additional 
delays in making available all the data that are needed to support 
enhanced program integrity efforts. 

One PI is a Web-based portal that is to provide CMS staff and 
contractors with a single source of access to data contained in IDR, 
as well as tools for analyzing those data. While One PI has been 
developed and deployed to users, few program integrity analysts were 
trained and using the system. Specifically, One PI program officials 
planned for 639 program integrity analysts to be using the system by 
the end of fiscal year 2010; however, as of October 2010, only 41—less 
than 7 percent—were actively using the portal and tools. According to 
program officials, the agency’s initial training plans were 
insufficient and, as a result, they were not able to train the 
intended community of users. Until program officials finalize plans 
and develop reliable schedules for training users and expanding the 
use of One PI, the agency may continue to experience delays in 
reaching widespread use and determining additional needs for full 
implementation of the system. 

While CMS has made progress toward its goals to provide a single 
repository of data and enhanced analytical capabilities for program 
integrity efforts, the agency is not yet positioned to identify, 
measure, and track benefits realized from its efforts. As a result, it 
is unknown whether IDR and One PI as currently implemented have 
provided financial benefits. According to IDR officials, they do not 
measure benefits realized from increases in the detection rate for 
improper payments because they rely on business owners to do so, and 
One PI officials stated that, because of the limited use of the 
system, there are not enough data to measure and gauge the program’s 
success toward achieving the $21 billion in financial benefits that 
the agency projected. 

What GAO Recommends: 

GAO is recommending that CMS take steps to finalize plans and reliable 
schedules for fully implementing and expanding the use of the systems 
and to define measurable benefits. In its comments, CMS concurred with 
GAO’s recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-11-475] or key 
components. For more information, contact Valerie Melvin at (202) 512-
6304 or melvinv@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

IDR and One PI Have Been Developed and Implemented but Without All 
Planned Data and Widespread Use: 

CMS Is Not Yet Positioned to Fully Meet Goals and Objectives for 
Detecting Fraud, Waste, and Abuse through the Use of IDR and One PI: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Department of Health and Human Services: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Responsibilities of CMS Program Integrity Contractors: 

Table 2: Reported Actual Costs of Developing and Implementing IDR, 
Fiscal Years 2006-2010: 

Table 3: Data Incorporated into IDR as of the End of Fiscal Year 2010: 

Table 4: Reported Actual Costs of Developing and Implementing One PI, 
Fiscal Years 2006-2010: 

Table 5: Planned and Actual Users of One PI as of October 2010: 

Table 6: Reported Estimated and Actual Costs and Benefits of IDR: 

Table 7: Reported Estimated and Actual Costs and Benefits of One PI: 

Figures: 

Figure 1: Initial Plans for Incorporating Data into IDR: 

Figure 2: Initial Plans for One PI: 

Figure 3: Simplified Depiction of the Current IDR and One PI 
Environment: 

Abbreviations: 

CMS: Centers for Medicare and Medicaid Services: 

HHS: Department of Health and Human Services: 

HIPAA: Health Insurance Portability and Accountability Act: 

IDR: Integrated Data Repository: 

IT: information technology: 

MACBIS: Medicaid and Children's Health Insurance Program Business 
Information and Solutions: 

OIG: Office of the Inspector General: 

OMB: Office of Management and Budget: 

One PI: One Program Integrity: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

June 30, 2011: 

The Honorable Thomas R. Carper: 
Chairman: 
Subcommittee on Federal Financial Management, Government Information, 
Federal Services, and International Security: 
Committee on Homeland Security and Governmental: 
Affairs United States Senate: 

The Honorable Scott Brown: 
Ranking Member: 
Subcommittee on Federal Financial Management, Government Information, 
Federal Services, and International Security: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable John McCain: 
United States Senate: 

For more than 20 years, GAO has designated Medicare as a high-risk 
program due to its size and complexity, as well as its susceptibility 
to mismanagement and improper payments. Improper payments are 
overpayments or underpayments that should not have been made or were 
made in an incorrect amount.[Footnote 1] Improper payments may be due 
to errors, such as the inadvertent submission of duplicate claims for 
the same service, or misconduct, such as fraud and abuse. Since 2003, 
we have also designated Medicaid as a high-risk program because of 
concerns about the adequacy of its fiscal oversight, which is 
necessary to prevent inappropriate spending. The Department of Health 
and Human Services (HHS) reported about $70 billion in improper 
payments for the Medicare and Medicaid programs in fiscal year 2010. 

The Centers for Medicare and Medicaid Services (CMS) within HHS is 
responsible for administering the Medicare and Medicaid programs and 
leading efforts to reduce improper payments. As part of these efforts, 
CMS conducts reviews to prevent improper payments before claims are 
paid and reviews of claims potentially paid in error. These activities 
are predominantly carried out by contractors who, along with CMS 
personnel, use various information technology (IT) solutions to 
consolidate and analyze data in support of efforts to detect improper 
payments of claims. For example, these analysts may use software tools 
to access data about claims to identify patterns of unusual activities 
by attempting to match services with patients' diagnoses. 

In 2006, CMS initiated efforts to centralize and make more accessible 
the data needed to conduct these analyses, and to improve the 
analytical tools available to its own and contractor analysts. Among 
these initiatives are the Integrated Data Repository (IDR), which is 
intended to provide a single source of data related to Medicare and 
Medicaid claims, and the One Program Integrity (One PI) system, a Web- 
based portal[Footnote 2] and suite of analytical software tools used 
to extract data from IDR and enable complex analyses of these data. 

You asked us to examine CMS's efforts to develop and implement IDR and 
One PI to improve the agency's ability to detect fraud, waste, and 
abuse in administering these programs. Specifically, our objectives 
were to: 

1. assess the extent to which the IDR and One PI systems have been 
developed and implemented, and: 

2. determine the agency's progress toward achieving defined goals and 
objectives for using the systems to help detect fraud, waste, and 
abuse in the Medicare and Medicaid programs. 

To address these objectives, we reviewed IDR and One PI program 
management and planning documentation and held discussions with agency 
officials and system users. Specifically, to assess the extent to 
which IDR and One PI have been developed and implemented, we compared 
the functionality that has been implemented to date to estimated 
schedule milestones and performance measures. We also reviewed the 
programs' requirements development and management plans and other 
project management artifacts and assessed CMS's documented processes 
against criteria established by the Software Engineering Institute. 
[Footnote 3] To supplement the information we collected from agency 
documents, we met with agency officials to discuss plans for and 
management of the IDR and One PI programs. 

To determine the agency's progress toward achieving goals and 
objectives for improving outcomes of its program integrity 
initiatives, we reviewed agencywide strategic plans and program 
planning documents to identify the goals and objectives, and assessed 
the extent to which IDR and One PI supported efforts to achieve them. 
We also interviewed agency officials about steps the agency had taken 
to achieve the goals and objectives. To determine the extent to which 
the use of IDR and One PI has enabled the agency to meet goals for 
improving its ability to detect fraud, waste, and abuse, we identified 
CMS program integrity personnel and contractors who actively use the 
systems by analyzing training information and system login data. We 
then held discussions with groups of these users to determine the 
extent to which and for what purposes they used the system. We also 
compared reported system costs and financial benefits to those 
projected for both IDR and One PI. 

We assessed the reliability of the agency's data related to project 
management practices; cost, schedule, and financial benefit estimates; 
and system usage through interviews with agency officials 
knowledgeable of the management of the programs, methods for tracking 
and reporting costs of the IDR and One PI programs, the programs' user 
community and training plans, and mechanisms for accessing the 
systems. We determined that the data we collected and assessed were 
sufficiently reliable for the purposes of our study. 

We conducted our work in support of this performance audit primarily 
at CMS's headquarters in Baltimore, Maryland, from June 2010 to June 
2011, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. Detailed 
information about our objectives, scope, and methodology is discussed 
in appendix I. 

Background: 

Medicare is a federal program that provides health insurance coverage 
for individuals aged 65 and older and for certain disabled persons. It 
is funded by general revenues, payroll taxes paid by most employees, 
employers, and individuals who are self-employed, and beneficiary 
premiums. Medicare consists of four parts. Medicare Part A provides 
payment for inpatient hospital, skilled nursing facility, some home 
health, and hospice services, while Part B pays for hospital 
outpatient, physician, some home health, durable medical equipment, 
and preventive services. In addition, Medicare beneficiaries have an 
option to participate in Medicare Advantage, also known as Part C, 
which pays private health plans to provide the services covered by 
Medicare Parts A and B. Further, all Medicare beneficiaries may 
purchase coverage for outpatient prescription drugs under Medicare 
Part D, and some Medicare Advantage plans also include Part D 
coverage. In 2010, Medicare covered 47 million elderly and disabled 
beneficiaries and had estimated outlays of about $509 billion. 

CMS uses contractors to help administer the claims processing and 
payment systems for Medicare. These administrative contractors are 
responsible for processing approximately 4.5 million claims per 
workday. The contractors review the claims submitted by providers to 
ensure payment is made only for medically necessary services covered 
by Medicare for eligible individuals. 

Medicaid is the federal-state program that provides health coverage 
for acute and long-term care services for over 65 million low-income 
people. It consists of more than 50 distinct state-based programs that 
each define eligibility requirements and administer payment for health 
care services for low-income individuals, including children, 
families, the aged, and the disabled. Within broad federal 
requirements, each state operates its Medicaid program according to a 
state plan. Low-income Americans who meet their state's Medicaid 
eligibility criteria are entitled to have payments made on their 
behalf for covered services. States are entitled to federal matching 
funds, which differ from state to state but can be up to three-fourths 
of their costs of this coverage. The amount paid with federal funds is 
determined by a formula established in law.[Footnote 4] 

CMS oversees the Medicaid program at the federal level, while the 
states administer their respective programs' day-to-day operations, 
such as enrolling eligible individuals, establishing payment amounts 
for covered benefits, establishing standards for providers and managed 
care plans, processing and paying for claims and managed care, and 
ensuring that state and federal health care funds are not spent 
improperly or diverted by fraudulent providers. The estimated outlays 
for Medicaid for both the federal and state governments were $408 
billion in 2010. Of this cost, approximately $275 billion was incurred 
by the federal government and $133 billion by the states. 

CMS Program Integrity Initiatives: 

The Health Insurance Portability and Accountability Act (HIPAA) of 
1996 established the Medicare Integrity Program to increase and 
stabilize federal funding for health care antifraud activities. 
[Footnote 5] The act appropriated funds for the program as well as 
amounts for HHS and the Department of Justice to carry out the health 
care fraud and abuse control program. Subsequent legislation further 
outlined responsibilities under the Medicare Integrity Program. 

Under the Medicare Integrity Program, CMS staff and several types of 
contractors perform functions to help detect cases of fraud, waste, 
and abuse, and other payment errors, which include reviews of paid 
claims to identify patterns of aberrant billing. Among these program 
integrity contractors are program safeguard contractors, zone program 
integrity contractors, and Medicare drug integrity contractors. 
[Footnote 6] The program safeguard and zone program integrity 
contractors are responsible for ensuring the integrity of benefit 
payments for Medicare Parts A and B (including durable medical 
equipment), as well as the Medi-Medi data match program.[Footnote 7] 
Medicare drug integrity contractors are responsible for monitoring 
fraud, waste, or abuse in the Medicare prescription drug program 
(i.e., Part D). These contractors work with the HHS Office of the 
Inspector General (OIG) and law enforcement organizations, such as the 
Department of Justice, to help law enforcement pursue criminal or 
civil penalties when fraudulent claims are detected. Table 1 
summarizes the origin and responsibilities of the program integrity 
contractors who help CMS to detect fraud, waste, and abuse. 

Table 1: Responsibilities of CMS Program Integrity Contractors: 

Type of contractor: Program safeguard contractors; 
Origin and scope of responsibility: 
Origin: Health Insurance Portability and Accountability Act of 1996, 
section 202, as amended; 
Scope of responsibility: Responsible for detecting and deterring fraud 
and abuse in Medicare Part A and Part B in their 17 jurisdictions. 

Type of contractor: Zone program integrity contractors; 
Origin and scope of responsibility: 
Origin: In response to section 911 of the Medicare Prescription Drug, 
Improvement, and Modernization Act of 2003; 
Scope of responsibility: Responsible for performing a wide range of 
medical review, data analysis, and auditing activities for all 
Medicare programs within seven geographic regions, or zones. 

Type of contractor: Medicare drug integrity contractors; 
Origin and scope of responsibility: 
Origin: In response to the establishment of the Part D prescription 
drug benefit program by the Medicare Prescription Drug, Improvement, 
and Modernization Act of 2003, beginning January 1, 2006; 
Scope of responsibility: Responsible for monitoring the Medicare 
Prescription Drug program to detect and deter cases of fraud and abuse. 

Source: GAO analysis of CMS data. 

[End of table] 

In addition to provisions of HIPAA and other legislation intended to 
strengthen Medicare program integrity functions, in 2006 Congress 
created the Medicaid Integrity Program through the Deficit Reduction 
Act of 2005.[Footnote 8] Its goals are to strengthen the national 
Medicaid audit program and to enhance federal oversight of and support 
and assistance to state Medicaid programs. The program provides states 
with technical assistance and support to enhance the federal-state 
partnership as well as to expand activities that involve data 
analysis, sharing algorithms of known improper billings, and fraud 
awareness through education and outreach. Individual states are 
responsible for ensuring the accuracy of Medicaid payments within 
their state programs, which can involve using their own staff or 
contractors to analyze claims to detect improper payments. In addition 
to the states' efforts, CMS employs Medicaid program integrity 
contractors to perform specific activities as part of its efforts to 
detect fraud, waste, and abuse in the Medicaid program, such as 
reviewing provider claims payments that have been processed by the 
states. 

Generally, each state Medicaid program integrity unit works 
independently, using its own data models, data warehouses, and 
approach to analysis. As a result, Medicaid data are stored in 
multiple disparate systems and databases throughout the country. 
Because of the volumes of work, states often augment their in-house 
capabilities by contracting with companies that specialize in Medicaid 
claims and utilization reviews. State Medicaid program integrity units 
target their activities to those providers that pose the greatest 
financial risk to their Medicaid programs. However, the states have 
limited methods of identifying Medicaid fraud in neighboring 
jurisdictions or by providers who move from state to state. 

As stated in a July 2007 report by the HHS OIG,[Footnote 9] the agency 
intends for program integrity contractors to perform a significant 
amount of self-initiated, exploratory analysis to seek patterns or 
instances of fraud and abuse. One of the specific activities 
undertaken by these contractors is the analysis of claims data to 
identify improper billing that may indicate fraud or abuse. If the 
billing appears to be potentially fraudulent or abusive, the 
contractors take further actions, which can include requesting and 
reviewing medical records associated with the claims and referring the 
case to law enforcement. 

In 2010, CMS created the Center for Program Integrity to serve as its 
focal point for all national Medicare and Medicaid program integrity 
fraud and abuse issues. The new center is responsible for, among other 
things, collaborating with other CMS components to develop and 
implement a comprehensive strategic plan, objectives, and measures to 
carry out the agency's program integrity mission and goals, and ensure 
program vulnerabilities are identified and resolved. According to 
agency documentation describing the program, the center was designed 
to: 

* promote the integrity of the Medicare and Medicaid programs through 
provider and contractor audits and policy reviews, identification and 
monitoring of program vulnerabilities, and support and assistance to 
states; 

* collaborate on the development and advancement of new legislative 
initiatives and improvements to deter, reduce, and eliminate fraud, 
waste and abuse; 

* oversee all CMS interactions and collaboration with key stakeholders 
related to program integrity (e.g., the Department of Justice, HHS 
OIG, and state law enforcement agencies) for the purposes of 
detecting, deterring, monitoring, and combating fraud and abuse; and: 

* take action against those who commit or participate in fraudulent or 
other unlawful activities. 

CMS's Use of IT to Help Detect Fraud, Waste, and Abuse: 

Like financial institutions, credit card companies, telecommunications 
firms, and other private sector companies that take steps to protect 
customers' accounts, CMS uses automated software tools to help predict 
or detect cases of improper claims and payments. For more than a 
decade, CMS and its contractors have applied such tools to access data 
from various sources to analyze patterns of unusual activities or 
financial transactions that may indicate fraudulent charges or other 
types of improper payments. For example, to identify unusual billing 
patterns and to support referrals for prosecution or other action, CMS 
and program integrity contractor analysts and investigators need, 
among other things, access to information about key actions taken to 
process claims as they are filed and specific details about claims 
already paid. This includes information on claims as they are billed, 
adjusted, and paid or denied; check numbers on payments of claims; and 
other specific information that could help establish provider intent. 
These data, along with data on regional or national trends on claims 
billing and payment, support the investigation and potential 
prosecution of fraud cases. Upon completing investigations, the 
contractors determine whether to refer the investigations as cases to 
law enforcement officials. 

CMS and its program integrity contractors currently use many different 
means to store and manipulate data and, since the establishment of the 
agency's program integrity initiatives in the 1990s, have built 
multiple databases and developed analytical software tools to meet 
their individual and unique needs. However, according to CMS, these 
geographically distributed, regional approaches to data analysis 
result in duplicate data and limit the agency's ability to conduct 
analyses of data on a nationwide basis. Additionally, data on Medicaid 
claims are scattered among the states in multiple disparate systems 
and data stores, and are not readily available to CMS. Thus, CMS has 
been working for most of the past decade to consolidate program 
integrity data and analytical tools for detecting fraud, waste, and 
abuse. The agency's efforts led to the initiation of the IDR program 
and, subsequently, the One PI program, which are intended to provide 
CMS and its program integrity contractors with a centralized source 
that consolidates Medicare and Medicaid data from the many disparate 
and dispersed legacy systems and databases and a Web-based portal and 
set of analytical tools by which these data can be accessed and 
analyzed to help detect cases of fraud, waste, and abuse. 

CMS's Initiative to Develop a Centralized Source of Medicare and 
Medicaid Data: 

The CMS Office of Information Services is responsible for agencywide 
IT management. Its initiative to develop a centralized data warehouse 
began in 2003 as an element of the agency's Enterprise Data 
Modernization strategy. According to agency documentation, the 
strategy was designed to meet the increasing demand for higher quality 
and more timely data to support decision making throughout the agency, 
including identifying trends and discovering patterns of fraud, waste, 
and abuse. As part of the strategy, the agency established the Data 
Warehouse Modernization project to develop and implement the 
technology needed to store long-term data for analytical purposes, 
such as summary reports and statistical analyses. CMS initially 
planned for the data warehouse project to be complete by September 30, 
2008. 

However, in 2006 CMS expanded the scope of the project to not only 
modernize data storage technology but also to integrate Medicare and 
Medicaid data into a centralized repository. At that time, program 
officials also changed the name to IDR, which reflected the expanded 
scope. The Office of Information Services' Enterprise Data Group 
manages the IDR program and is responsible for the design and 
implementation of the system. The program's overall goal is to 
integrate Medicare and Medicaid data so that CMS and its partners may 
access the data from a single source. Specific goals for the program 
are to: 

* transition from stove-piped, disparate sets of databases to a highly 
integrated data environment for the enterprise; 

* transition from a claim-centric orientation to a multi-view 
orientation that includes beneficiaries, providers, health plans, 
claims, drug code data, [Footnote 10] clinical data, and other data as 
needed; 

* provide uniform privacy and security controls; 

* provide database scalability to meet current and expanding volumes 
of CMS data; and: 

* provide users the capability to analyze the data in place instead of 
relying on data extracts. 

According to IDR program officials, CMS envisioned that IDR would 
become the single repository for the agency's data and enable data 
analysis within and across programs. Specifically, IDR was to 
establish the infrastructure for storing data for Medicare Parts A, B, 
and D,[Footnote 11] as well as a variety of other CMS functions, such 
as program management, research, analytics, and business intelligence. 
CMS envisioned an incremental approach to incorporating data into IDR. 
Specifically, program plans provided to the Office of Management and 
Budget (OMB) by the Office of Information Services in 2006 stated that 
all Medicare Part D data would be incorporated into IDR by the end of 
that fiscal year. CMS's 2007 plans added the incorporation of Medicare 
Parts A and B data by the end of fiscal year 2007, and Medicaid data 
for 5 states by the end of fiscal year 2009, 20 states by 2010, 35 by 
2011, and all 50 states by the end of fiscal year 2012. 

Initial program plans and schedules also included the incorporation of 
additional data from legacy CMS claims-processing systems that store 
and process data related to the entry, correction, and adjustment of 
claims as they are being processed, along with detailed financial data 
related to paid claims. According to program officials, these data, 
called "shared systems" data, are needed to support the agency's plans 
to incorporate tools to conduct predictive analysis of claims as they 
are being processed, helping to prevent improper payments.[Footnote 
12] Shared systems data, such as check numbers and amounts related to 
claims that have been paid, are also needed by law enforcement 
agencies to help with fraud investigations.[Footnote 13] CMS initially 
planned to include all the shared systems data in IDR by July 2008. 
Figure 1 shows a timeline of initial plans for incorporating data into 
IDR. 

Figure 1: Initial Plans for Incorporating Data into IDR: 

[Refer to PDF for image: timeline] 

2006: 
Incorporation of Part D data. 

2007: 
Incorporation of Parts A and B data. 

2008: 
Incorporation of shared systems data. 

2009: 
Incorporation of Medicaid data for 5 states. 

2010: 
Incorporation of Medicaid data for 20 states. 

2011: 
Incorporation of Medicaid data for 35 states. 

2012: 
Incorporation of Medicaid data for 50 states. 

Source: GAO based on CMS data. 

[End of figure] 

CMS's Initiative to Develop and Implement Analytical Tools for 
Detecting Fraud, Waste, and Abuse: 

In 2006, CMS's Office of Financial Management initiated the One PI 
program with the intention of developing and implementing a portal and 
software tools that would enable access to and analysis of claims, 
provider, and beneficiary data from a centralized source. CMS's goal 
for One PI was to support the needs of a broad program integrity user 
community, including agency program integrity personnel and 
contractors who analyze Medicare claims data, along with state 
agencies that monitor Medicaid claims. To achieve its goal, agency 
officials planned to implement a tool set that would provide a single 
source of information to enable consistent, reliable, and timely 
analyses and improve the agency's ability to detect fraud, waste, and 
abuse. These tools were to be used to gather data about beneficiaries, 
providers, and procedures and, combined with other data, find billing 
aberrancies or outliers. For example, as envisioned, an analyst could 
use software tools to identify potentially fraudulent trends in 
ambulance services. He or she could gather data about claims for 
ambulance services and medical treatments, and then use other software 
to determine associations between the two types of services. If the 
analyst found claims for ambulance travel costs but no corresponding 
claims for medical treatment, the analyst may conclude that the 
billings for those services were possibly fraudulent. 

According to agency program planning documentation, the One PI system 
was to be developed incrementally to provide access to data, 
analytical tools, and portal functionality in three phases after an 
initial proof of concept phase. The proof of concept phase was 
reportedly begun in early 2007 and focused on integrating Medicare and 
Medicaid data into the portal environment. After its completion, the 
first development phase focused on establishing a development 
environment in CMS's Baltimore, Maryland, data center and, according 
to program officials, was completed in April 2009. The second and 
third phases of development were planned in January 2009 to run 
concurrently and to focus on the technical and analytical aspects of 
the project, such as building the environment to integrate the 
analytical tools using data retrieved from IDR, sourcing claims data 
from the shared systems, conducting data analyses in production, and 
training analysts who were intended users of the system. CMS planned 
to complete these two phases and implement the One PI portal and two 
analytical tools for use by program integrity analysts on a widespread 
basis by the end of fiscal year 2009. 

CMS's Office of Financial Management engaged contractors to develop 
the system. Responsibility for and management of the One PI program 
moved from the Office of Financial Management to the Center for 
Program Integrity in 2010. Figure 2 illustrates initial plans for One 
PI. 

Figure 2: Initial Plans for One PI: 

[Refer to PDF for image: timeline] 

2006: 
One PI program initiated by CMS’s Office of Financial Management. 

2007: 
One PI Proof of Concept phase completed. 

2009: 
Second phase begun. 

Planned date for implementation and widespread use of One PI with 2 
tools. 

2010: 
Responsibility moved to the Center for Program Integrity. 

Source: GAO based on CMS data. 

[End of figure] 

Prior GAO Reports on Fraud, Waste, and Abuse in the Medicare and 
Medicaid Programs: 

In our prior work, we have reported on CMS's efforts to detect and 
prevent fraudulent and improper payments in the Medicare and Medicaid 
programs and on its management of IT to support its mission. For 
example, as early as 1995, we reviewed IT systems used in the Medicare 
program to detect and prevent fraud and discussed the availability of 
other technologies to assist in combating fraudulent billing.[Footnote 
14] We found it was too early to fully document the cost-effectiveness 
of such systems, although several potential fraud cases were detected 
by this technology, indicating that these types of systems could 
provide net benefits in combating fraud. We observed that such 
technology could ultimately be utilized in the claims-processing 
environment to delay or even prevent the payment of questionable 
claims submitted by suspect providers. 

We have also reported on weaknesses in CMS's processes for managing IT 
investments based upon key practices established in our Information 
Technology Investment Management framework.[Footnote 15] Specifically, 
in 2005, we evaluated CMS's capabilities for managing its internal 
investments, described plans the agency had for improving these 
capabilities, and examined the agency's process for approving and 
monitoring state Medicaid Management Information Systems.[Footnote 16] 
We found that CMS had not established certain key practices for 
managing individual IT investments and recommended that the CMS 
Administrator develop and implement a plan to address the IT 
investment management weaknesses identified in the report. We also 
recommended that at a minimum, the agency should update its investment 
management guide to reflect current investment management processes. 
CMS subsequently took actions to implement each of our recommendations. 

Additionally, our 2007 study of the Medicare durable medical 
equipment, prosthetics, orthotics, and supplies benefit found that it 
was vulnerable to fraud and improper payments.[Footnote 17] We 
recommended that CMS direct its contractors to develop automated 
prepayment controls to identify potentially improper claims and 
consider adopting the most cost-effective controls of other 
contractors. CMS concurred with the recommendation, but has not yet 
implemented the prepayment controls that we recommended. 

In 2009, we examined the administration of the Medicare home health 
benefit, which we found to leave the benefit vulnerable to fraud and 
improper payments.[Footnote 18] We made several recommendations to the 
Administrator of CMS, including directing contractors to conduct post- 
payment medical reviews on claims submitted by home health agencies 
with high rates of improper billing identified through prepayment 
review. CMS stated it would consider two of our four recommendations-- 
to amend regulations to expand the types of improper billing practices 
that are grounds for revocation of billing privileges, and to provide 
physicians who certify or recertify plans of care with a statement of 
services received by beneficiaries. CMS neither agreed nor disagreed 
with our other two recommendations. 

Finally, in testifying on Medicare and Medicaid fraud, waste, and 
abuse in March 2011, we described steps that CMS could take to reduce 
improper payments and the agency's recent solicitation for proposals 
of contracts for the development and implementation of automated tools 
that support reviews of claims before they are paid.[Footnote 19] 
These predictive modeling tools are intended to provide new 
capabilities to help prevent improper payments of Medicare claims. 

IDR and One PI Have Been Developed and Implemented but Without All 
Planned Data and Widespread Use: 

CMS has developed and implemented IDR and One PI for use by its 
program integrity analysts, but IDR does not include all the data the 
agency planned to have incorporated by the end of 2010, and One PI is 
being used by a limited number of analysts. While CMS has developed 
and begun using IDR, the repository does not include all the planned 
data, such as Medicaid and shared systems data. Program officials 
attribute this lack of data to insufficient planning, which did not 
consider unexpected obstacles or allow time for contingencies. In 
addition, the agency has developed and deployed One PI, but the system 
is being used by less than 7 percent of the intended user community 
and does not yet provide as many tools as planned. According to agency 
officials, plans to train and deploy the system to a broad community 
of users were disrupted when resources dedicated to these activities 
were redirected to address a need to improve the user training 
program. Further, plans and schedules for completing the remaining 
work have not been finalized, and CMS has not identified risks and 
obstacles to project schedules that may affect its ability to ensure 
broad use and full implementation of the systems. Until program 
officials finalize plans and develop reliable schedules for providing 
all planned data and capabilities and ensuring that One PI gains 
broader use throughout the program integrity community, CMS will 
remain at risk of experiencing additional delays in reaching 
widespread use and full implementation of the systems. Consequently, 
the agency may miss an opportunity to effectively use these IT 
solutions to enhance its ability to detect fraud, waste, and abuse in 
the Medicare and Medicaid programs. 

IDR Has Been Developed and Is in Use, but Does Not Yet Include All 
Data Needed to Enhance Program Integrity Efforts: 

IDR has been in use by CMS and contractor program integrity analysts 
since September 2006 and currently incorporates data related to claims 
for reimbursement of services under Medicare Parts A, B, and D. 
Specifically, CMS incorporated Part D data into IDR in September 2006, 
as planned, and incorporated Parts A and B data by the end of fiscal 
year 2008. The primary source of these data is CMS's National Claims 
History database, from which data are extracted on a weekly basis. 
Other supplemental data were incorporated into IDR that are used to 
conduct program integrity analyses, including drug code data that are 
obtained from daily and weekly updates of data from CMS's Drug Data 
Processing System, and claims-related data about physicians that are 
retrieved from National Provider Index databases on a daily basis. 
Additionally, IDR contains data about beneficiaries that are extracted 
daily from the Medicare Beneficiary Database and health plan contract 
and benefit data that are obtained on a weekly basis from CMS's Health 
Plan Management Systems. According to IDR program officials with the 
Office of Information Services, the integration of these data into IDR 
established a centralized source of data previously accessed from 
multiple disparate system files. 

CMS reported to OMB in 2010 that the agency had spent almost $48 
million to establish IDR and incorporate the existing data since the 
program was initiated. Table 2 provides the actual costs of developing 
and implementing IDR for each year since fiscal year 2006, as reported 
to us by CMS officials. 

Table 2: Reported Actual Costs of Developing and Implementing IDR, 
Fiscal Years 2006-2010: 

2006: $4.7 million; 
2007: $6.5 million; 
2008: $10.9 million; 
2009: $9.9 million; 
2010: $15.6 million; 
Total: $47.6 million. 

Source: CMS data. 

[End of table] 

Although the agency has been incorporating data from various data 
sources since 2006, IDR does not yet include all the data that were 
planned to be incorporated by the end of 2010 and that are needed to 
support enhanced program integrity initiatives. Specifically, the 
shared systems data that are needed to allow predictive analyses of 
claims are not incorporated. Without this capability, program 
integrity analysts are not able to access data from IDR that would 
help them identify and prevent payment of fraudulent claims. 
Additionally, IDR does not yet include the Medicaid data that are 
critical to analysts' ability to detect fraud, waste, and abuse in the 
Medicaid program. 

According to IDR program officials, the shared systems data were not 
incorporated into IDR because, although initial program integrity 
requirements included the incorporation of these data by July 2008, 
funding for the development of the software and acquisition of the 
hardware needed to meet this requirement was not approved until the 
summer of 2010. Since then, IDR program officials have developed 
project plans and identified users' requirements, and plan to 
incorporate shared systems data by November 2011. 

With respect to Medicaid data, program officials stated that the 
agency has not incorporated these data into IDR because the original 
plans and schedules for obtaining Medicaid data did not account for 
the lack of a mandate or funding for states to provide Medicaid data 
to CMS, or the variations in the types and formats of data stored in 
disparate state Medicaid systems. In this regard, program officials 
did not consider risks to the program's ability to collect the data 
and did not include additional time to allow for contingencies. 
Consequently, the IDR program officials were not able to collect the 
data from the states as easily as they expected and, therefore, did 
not complete this activity as originally planned. 

In addition to the IDR program, in December 2009, CMS initiated 
another agencywide program intended to, among other things, identify 
ways to collect Medicaid data from the many disparate state systems 
and incorporate the data into a single data store. As envisioned by 
CMS, this program, the Medicaid and Children's Health Insurance 
Program Business Information and Solutions program, or MACBIS, is to 
include activities in addition to providing expedited access to 
current data from state Medicaid programs. For example, the MACBIS 
initiative is also intended to result in the development of a national 
system to address the needs of federal and state Medicaid partners, 
along with technical assistance and training for states on the use of 
the system. Once established, the MACBIS system data would then be 
incorporated into IDR and made accessible to program integrity 
analysts. According to program planning documentation, this 
enterprisewide initiative is expected to cost about $400 million 
through fiscal year 2016. However, plans for this program are not 
final, and funds for integrating Medicaid data into IDR have not yet 
been requested. 

According to agency planning documentation, as a result of efforts to 
be initiated under the MACBIS program, CMS intends to incorporate 
Medicaid data for all 50 states into IDR by the end of fiscal year 
2014. Program integrity officials stated that they plan to work with 
three states during 2011 to test the transfer and use of Medicaid data 
to help CMS determine the data that are available in those states' 
systems. The Center for Program Integrity is also working with 
Medicaid officials to establish a test environment to begin 
integrating state Medicaid data into IDR. Despite establishing these 
high-level milestones, the agency has not finalized detailed plans for 
incorporating the Medicaid data that include reliable schedules that 
identify all the necessary activities and resources for completing 
these efforts or the risks associated with efforts to collect and 
standardize data from 50 independent systems that differ in design, 
technology, and other characteristics dictated by state policies. 

Table 3 shows the original planned dates for incorporating the various 
types of data and the data that were incorporated into IDR as of the 
end of fiscal year 2010. 

Table 3: Data Incorporated into IDR as of the End of Fiscal Year 2010: 

Type of data: Medicare Part D; 
Original planned date: January 2006; 
Actual date: January 2006. 

Type of data: Medicare Part B; 
Original planned date: September 2007; 
Actual date: May 2008. 

Type of data: Medicare Part A; 
Original planned date: September 2008; 
Actual date: May 2008. 

Type of data: Shared systems; 
Original planned date: July 2008; 
Actual date: Not incorporated (planned for November 2011). 

Type of data: Medicaid for 5 states; 
Original planned date: September 2009; 
Actual date: Not incorporated (planned for September 2014). 

Type of data: Medicaid for 20 states; 
Original planned date: September 2010; 
Actual date: Not incorporated (planned for September 2014). 

Type of data: Medicaid for 35 states; 
Original planned date: September 2011; 
Actual date: Not incorporated (planned for September 2014). 

Type of data: Medicaid for 50 states; 
Original planned date: September 2012; 
Actual date: Not incorporated (planned for September 2014). 

Source: GAO analysis of CMS data. 

[End of table] 

While CMS has identified target dates for incorporating the remaining 
data, best practices, such as those described in our cost estimation 
guide,[Footnote 20] emphasize the importance of establishing reliable 
program schedules that include all activities to be performed, assign 
resources (labor, materials, etc.) to those activities, and identify 
risks and their probability and build appropriate reserve time into 
the schedule. However, the IDR schedule we reviewed did not identify 
all activities and necessary resources or include a schedule risk 
analysis. Such an analysis could have helped CMS identify and prepare 
for obstacles, such as those previously encountered in trying to 
incorporate Medicaid data into IDR and expected to be encountered as 
CMS initiates efforts to collect and standardize data from 50 state 
systems. Without establishing a reliable schedule for future efforts 
to incorporate new data sources, the agency will be at greater risk of 
schedule slippages, which could result in additional delays in CMS's 
efforts to incorporate all the data sources into IDR that are needed 
to support enhanced program integrity efforts. 

One PI Has Been Developed but Deployed to Few Users and With Less 
Functionality Than Planned: 

According to program officials, user acceptance testing of the One PI 
system was completed in February 2009, and the system was deployed in 
September 2009 as originally planned. This initial deployment of One 
PI consisted of a portal that provided Web-based access to analytical 
tools used by program integrity analysts to retrieve and analyze data 
stored in IDR. 

CMS reported to OMB that the agency had spent almost $114 million to 
develop the existing features and functionality of the One PI system 
by the end of fiscal year 2010. Table 4 provides information on the 
actual costs of developing One PI since fiscal year 2006, as reported 
to us by CMS officials. 

Table 4: Reported Actual Costs of Developing and Implementing One PI, 
Fiscal Years 2006-2010: 

2006: $0.65 million; 
2007: $15.3 million; 
2008: $20.9 million; 
2009: $32.9 million; 
2010: $43.8 million; 
Total: $113.5 million. 

Source: GAO analysis of CMS data. 

[End of table] 

As currently implemented, the system provides access to two analytical 
tools--Advantage Suite and Business Objects. Documented specifications 
of the One PI system described Advantage Suite as a commercial, off- 
the-shelf decision support tool that is used to perform data analysis 
to, for example, detect patterns of activities that may identify or 
confirm suspected cases of fraud, waste, or abuse. According to 
program officials and the One PI users to whom we spoke, program 
integrity analysts use Advantage Suite to analyze claims data 
retrieved from IDR and create standard and custom reports that combine 
data about costs and quality of services, providers, and 
beneficiaries. The results of this level of analysis may be used to 
generate leads for further analysis with Business Objects, which 
provides users extended capabilities to perform more complex analyses 
of data by allowing customized queries of claims data across the three 
Medicare plan types. It also allows the user to create ad hoc queries 
and reports for nonroutine analysis. 

For example, an analyst could use Advantage Suite to identify 
potentially fraudulent trends in ambulance services. He or she could 
use the tool to gather data about claims for ambulance services and 
medical treatments, and then use Business Objects to conduct further 
analysis to determine associations between the two types of services. 
If the analyst found claims for ambulance travel costs but no 
corresponding claims for medical treatment, the analyst may conclude 
that the billings for those services were possibly fraudulent. 

Figure 3 provides a simplified view of the IDR and One PI environment 
as currently implemented. 

Figure 3: Simplified Depiction of the Current IDR and One PI 
Environment: 

[Refer to PDF for image: illustration] 

One PI users conducting fraud, waste, and abuse analyses: 

Data sources: 
Health plans; 
Providers; 
Medicare Parts A, B, and D; 
Beneficiaries; 
National drug codes. 

All data sources feed IDR. 

From IDR: 

Business Objects and Advantage Suite tools: 
One PI portal: 
Program safeguard contractors; 
Zone program integrity contractors; 
Medicare drug integrity contractors; 
CMS analysts. 

Source: GAO based on CMS data. 

[End of figure] 

While program officials deployed the One PI portal and two analytical 
tools to CMS and contractor program integrity analysts, the system was 
not being used as widely as planned. Program planning documentation 
from August 2009 indicated that One PI program officials planned for 
639 program integrity staff and analysts to be trained and using the 
system by the end of fiscal year 2010; however, CMS confirmed that by 
the end of October 2010 only 42 of those intended users were trained 
to use One PI, and 41 were actively using the portal and tools. These 
users represent less than 7 percent of the original intended users. Of 
these, 31 were contractors and 10 were CMS staff who performed 
analyses of claims to detect potential cases of fraud, waste, and 
abuse. Table 5 describes the analysts planned to be and actually using 
One PI at the end of fiscal year 2010.[Footnote 21] 

Table 5: Planned and Actual Users of One PI as of October 2010: 

Type of user: CMS program integrity staff; 
Planned by end of FY 2010: 100; 
Actual: 10. 

Type of user: CMS program integrity contractors; 
Planned by end of FY 2010: 159; 
Actual: 31. 

Type of user: Medicaid states and Medi-Medi program staff; 
Planned by end of FY 2010: 130; 
Actual: 0. 

Type of user: HHS OIG staff and law enforcement; 
Planned by end of FY 2010: 250; 
Actual: 0. 

Type of user: Total; 
Planned by end of FY 2010: 639; 
Actual: 41. 

Source: GAO analysis of CMS information. 

[End of table] 

According to One PI program officials, the system was not being used 
by the intended number of program integrity analysts because the 
office had not trained a sufficient number of analysts to use the 
system. Similarly, although CMS contractually requires Medicare 
program integrity contractors to use the system, officials stated that 
they could not enforce this requirement because they also had not 
trained enough of their program integrity contractors. 

Although One PI program plans emphasized the importance of effective 
training and communications, program officials responsible for 
implementing the system acknowledged that their initial training plans 
and efforts were insufficient. According to the officials, they 
initially provided training for the all the components of the system-- 
the portal, tools, and use of IDR data--in a 3-and-a-half-day course. 
However, they realized that the trainees did not effectively use One 
PI after completing the training. Consequently, program officials 
initiated activities and redirected resources to redesign the One PI 
training plan in April 2010, and began to implement the new training 
program in July of that year. The redesigned program includes courses 
on each of the system components and allows trainees to use the 
components to reinforce learning before taking additional courses. For 
example, the redesigned plan includes a One PI portal overview and 
data training webinars that users must complete before attending 
instructor-led training on Advantage Suite and Business Objects. The 
new plans also incorporate the use of "data coaches" who provide hands-
on help to analysts, such as assistance with designing queries. 
Additionally, the plans require users to complete surveys to evaluate 
the quality of the training and their ability to use the tools after 
they complete each course. 

As program officials took the initiative and time to redesign the 
training program, this effort caused delays in CMS's plans to train 
the intended number of users. Since the new training program was 
implemented, the number of users has not yet significantly increased, 
but the number of contractor analysts requesting training has 
increased. Specifically, One PI officials told us that 62 individuals 
had signed up to be trained in 2011, and that the number of training 
classes for One PI was increased from two to four per month. The 
officials also stated that they planned to reach out to and train more 
contractors and staff from the HHS OIG and the Department of Justice 
to promote One PI. They anticipated that 12 inspectors general and 12 
law enforcement officials would be trained and using One PI by the end 
of May 2011. 

Nonetheless, while these activities indicate some progress toward 
increasing the number of One PI users, the number of users expected to 
be trained and to begin using the system represents a small fraction 
of the population of 639 intended users. Additionally, One PI program 
officials had not yet made detailed plans and developed schedules for 
completing training of all the intended users. Further, although 
program officials had scheduled more training classes, they have not 
established deadlines for contractor analysts to attend training so 
that they are able to fulfill the contractual requirement to use One 
PI. Unless the agency takes more aggressive steps to ensure that its 
program integrity community is trained, it will not be able to require 
the use of the system by its contractors, and the use of One PI may 
remain limited to a much smaller group of users than the agency 
intended. As a result, CMS will continue to face obstacles in its 
efforts to deploy One PI to the intended number of program integrity 
users as the agency continues to develop and implement additional 
features and functionalities in the system. 

Additionally, although efforts to develop and implement One PI were 
initiated in 2006 and the Advantage Suite and Business Objects tools 
are fully developed, implemented, and in use, the One PI system does 
not yet include additional analytical functionality that CMS initially 
planned to implement by the end of 2010. Program documentation for the 
system includes plans for future phases of One PI development to 
incrementally add new analytical tools, additional sources of data, 
and expanded portal functionality, such as enhanced communications 
support, and specifically included the integration of a third tool by 
the end of fiscal year 2010. However, program officials have not yet 
identified users' needs for functionality that could be provided by 
another tool, such as the capability to access and analyze more data 
from IDR than the current implementation of the system provides. 
According to program officials, they intend to determine users' needs 
for additional functionality when the system becomes more widely used 
by agency and contractor analysts who are able to identify 
deficiencies and define additional features and functionality needed 
to improve its effectiveness. 

Additionally, as with IDR, in developing the One PI schedule estimate 
that was provided to OMB in 2010, program officials did not complete a 
risk assessment for the schedule that identified potential obstacles 
to the program. As a result, they lacked information needed to plan 
for additional time to address contingencies when obstacles arose. As 
the program office makes plans for deploying the system to the wide 
community of program integrity analysts and implementing additional 
tools, it is crucial that officials identify potential obstacles to 
the schedules and the risks they may introduce to the completion of 
related activities. For example, an analysis that identified the risk 
that resources would need to be redirected to other elevated 
priorities, such as user training, could have informed managers of the 
need to include additional time and resources in the schedule to help 
keep the development and deployment of One PI on track. Unless program 
officials complete a risk assessment of schedules for ongoing and 
future activities, CMS faces risks of perpetuating delays in 
establishing widespread use of One PI and achieving full 
implementation of the system for increased rates of fraud, waste, and 
abuse detection. 

CMS Is Not Yet Positioned to Fully Meet Goals and Objectives for 
Detecting Fraud, Waste, and Abuse through the Use of IDR and One PI: 

Our prior work emphasized agencies' need to ensure that IT investments 
actually produce improvements in mission performance.[Footnote 22] As 
we have reported, agencies should forecast expected benefits and then 
measure actual financial benefits accrued through the implementation 
of IT programs. Further, OMB requires agencies to report progress 
against performance measures and targets for meeting them that reflect 
the goals and objectives of the programs. To do this, performance 
measures should be outcome-based, developed with stakeholder input, 
and monitored and compared to planned results.[Footnote 23] 
Additionally, industry experts describe the need for performance 
measures to be developed with stakeholders' input early in a project's 
planning process to provide a central management and planning tool and 
to monitor the performance of the project against plans and 
stakeholders' needs.[Footnote 24] 

While CMS has made progress toward meeting the programs' goals of 
providing a centralized data repository and enhanced analytical 
capabilities for program integrity efforts, the current implementation 
of IDR and One PI does not position the agency to identify, measure, 
and track financial benefits realized from reductions in improper 
payments as a result of the implementation of either system. 
Additionally, program officials have not developed and tracked outcome-
based performance measures to help ensure that efforts to implement 
One PI and IDR meet the agency's goals and objectives for improving 
the results of its program integrity initiatives. For example, outcome-
based measures for the programs would indicate improvements to the 
agency's ability to recover funds lost because of improper payments of 
fraudulent claims. Until CMS is better positioned to identify and 
measure financial benefits and outcome-based performance measures to 
help gauge progress toward meeting program integrity goals, it cannot 
be assured that the systems will contribute to improvements in CMS's 
ability to detect fraud, waste, and abuse in the Medicare and Medicaid 
programs, and prevent or recover billions of dollars lost to improper 
payments of claims: 

CMS Has Made Limited Progress toward Meeting Program Integrity Goals 
and Objectives through the Use of IDR: 

As stated in program planning documentation, IDR's overall goal is to 
integrate Medicare and Medicaid data so that CMS and its partners may 
access the data from a single source. Specifically, the implementation 
of IDR was expected to result in financial benefits associated with 
the program's goal to transition from a data environment of stove-
piped, disparate databases and systems to an integrated data 
environment. 

Officials with the Office of Information Services stated that they 
developed estimates of financial benefits expected to be realized 
through the use of IDR. In 2006, program officials projected financial 
benefits from IDR of $152 million at an estimated cost of $82 million, 
or a net benefit of about $70 million. In 2007 these officials revised 
their projection of total financial benefits to $187 million based on 
their estimates of the amount of improper payments they expected to be 
recovered as a result of analyzing data provided by IDR. The resulting 
net benefit expected from implementing IDR was estimated to be $97 
million in 2010 due to changes in program cost estimates. 

Table 6 includes CMS's estimated financial benefits, costs, and net 
benefits reported to OMB for the lifecycle of the program from fiscal 
year 2006 to 2010. [Footnote 25] 

Table 6: Reported Estimated and Actual Costs and Benefits of IDR: 

Benefits: 
2006 lifecycle estimate (FY 2005-2012)[A]: $152 million; 
2007 lifecycle estimate (FY 2005-2013): $187 million; 
2008 lifecycle estimate (FY 2005-2015): $187 million[B]; 
2009 lifecycle estimate (FY 2005-2016): $187 million[B]; 
2010 lifecycle estimate (FY 2005-2018): $187 million[B]; 
Actual costs and benefits (FY 2006-2010): Not known. 

Costs: 
2006 lifecycle estimate (FY 2005-2012)[A]: $82 million; 
2007 lifecycle estimate (FY 2005-2013): $86 million; 
2008 lifecycle estimate (FY 2005-2015): $92 million; 
2009 lifecycle estimate (FY 2005-2016): $116 million; 
2010 lifecycle estimate (FY 2005-2018): $90 million; 
Actual costs and benefits (FY 2006-2010): $44 million. 

Net benefit: 
2006 lifecycle estimate (FY 2005-2012)[A]: $70 million; 
2007 lifecycle estimate (FY 2005-2013): $101 million; 
2008 lifecycle estimate (FY 2005-2015): $95 million; 
2009 lifecycle estimate (FY 2005-2016): $71 million; 
2010 lifecycle estimate (FY 2005-2018): $97 million; 
Actual costs and benefits (FY 2006-2010): Not known. 

Source: GAO based on CMS data. 

[A] Initial estimates include planning costs from FY 2005. 

[B] Because the agency has not updated the benefits estimate, we 
carried this figure forward. 

[End of table] 

However, as of March 2011, program officials had not identified actual 
financial benefits of implementing IDR based on the recovery of 
improper payments. In our discussions with the Office of Information 
Services, program officials stated they determined that deploying IDR 
led to the avoidance of IT costs as a result of the retirement of 
several legacy systems attributable to the implementation of IDR. 
However, they had not quantified these or any other financial 
benefits. Until officials measure and track financial benefits related 
to program goals, CMS officials cannot be assured that the use of the 
system is helping the agency prevent or recover funds lost as a result 
of improper payments of Medicare and Medicaid claims. 

Additionally, while program officials defined and reported to OMB 
performance targets for IDR related to some of the program's goals, 
they do not reflect its goal to provide a single source of Medicare 
and Medicaid data for program integrity efforts. Although progress 
made to date in implementing IDR supports the program's goals to 
transition CMS to an integrated data environment, program officials 
have not defined and reported to OMB performance measures to gauge the 
extent to which the program is meeting this goal. Specifically, IDR 
officials defined performance measures for technical indicators, such 
as incorporating Medicare data into the repository, making the data 
available for analysis, and reducing the number of databases CMS must 
support, but they have not defined measures and targets that reflect 
the extent to which all the data needed to support program integrity 
initiatives are incorporated into a single source, including the 
Medicaid and shared systems data which have not yet been incorporated 
into IDR. Further, the IDR performance measures do not reflect 
indicators that may lead to the program's ability to achieve the 
financial benefits defined by the agency's program integrity 
initiatives. 

In discussing this matter, IDR officials stated that the performance 
measures for the program are only intended to track progress toward 
implementing technical capabilities of the system, such as the amount 
of data from specific sources incorporated into the repository and 
made available through software tools to analysts. They do not define 
performance indicators, measures, and targets for incorporating data 
from future sources of data until plans are made and funds are 
provided by the agency's business offices to begin activities to 
implement new functionalities into IDR. IDR program officials also 
stated that they do not define or track business-related performance 
indicators for achieving specific program integrity goals; rather, 
they depend upon business owners to measure and track these indicators 
based upon the use of IDR data to achieve business goals. However, 
without performance measures that reflect business owners' and other 
stakeholders' needs for the program to deliver a single source of all 
Medicare and Medicaid data needed to conduct analyses, and lacking 
measures that reflect the success of the program toward achieving 
financial benefits projected for program integrity initiatives, 
program officials lack key management information needed to ensure 
that the data and infrastructure components provided by IDR enhance 
CMS's ability to meet its program integrity goals and objectives. 
Without this assurance, the effectiveness of the system's capability 
to increase rates of fraud, waste, and abuse detection and, 
consequently, decrease the amount of money lost to improper payments 
of claims will remain unknown. 

CMS Is Not Yet Positioned to Demonstrate Improvements in Its Ability 
to Meet Goals and Objectives for Detecting Fraud, Waste, and Abuse 
through the Use of One PI: 

The Center for Program Integrity's overall goal for One PI was to 
provide robust tools for accessing a single source of information to 
enable consistent, reliable, and timely analyses to improve the 
agency's ability to detect fraud, waste, and abuse. Achieving this 
goal was intended to result in the recovery of significant funds lost 
each year from improper payments of Medicare and Medicaid claims. In 
September 2007, program officials projected financial benefits from 
implementing One PI--nearly $13 billion over the 9-year lifecycle of 
the project. According to program officials, these benefits were 
expected to accrue from the recovery of improper payments of Medicare 
and Medicaid claims and reduced program integrity contractor 
expenditures for supporting IT required to maintain separate databases. 

In September 2007, One PI officials projected and reported to OMB 
benefits of nearly $13 billion. They subsequently revised this 
estimate to approximately $21 billion. Program officials told us that 
increases in the projected financial benefits were made based on 
assumptions that accelerated plans to integrate Medicare and Medicaid 
data into a central data repository would enable One PI users to 
identify increasing numbers of improper payments sooner than 
previously estimated, thus allowing the agency to recover more funds 
lost due to payment errors. Table 7 provides data CMS reported to OMB 
on estimated benefits and costs, actual costs as of the end of fiscal 
year 2010, and net benefits projected to be realized as a result of 
implementing One PI from fiscal year 2007 through 2010. 

Table 7: Reported Estimated and Actual Costs and Benefits of One PI: 

Benefit: 
2007 lifecycle estimate (FY 2006-2013)[A]: $12.722 billion; 
2008 lifecycle estimate (FY 2006-2014): $15.785 billion[B]; 
2009 lifecycle estimate (FY 2006-2015): $21.358 billion[B]; 
2010 lifecycle estimate (FY 2006-2015): $21.358 billion[B]; 
Actual costs and benefits (FY 2006-2010): Not known. 

Costs: 
2007 lifecycle estimate (FY 2006-2013)[A]: $199 million; 
2008 lifecycle estimate (FY 2006-2014): $233 million; 
2009 lifecycle estimate (FY 2006-2015): $275 million; 
2010 lifecycle estimate (FY 2006-2015): $255 million; 
Actual costs and benefits (FY 2006-2010): $114 million. 

Net benefit: 
2007 lifecycle estimate (FY 2006-2013)[A]: $12.523 billion; 
2008 lifecycle estimate (FY 2006-2014): $15.552 billion; 
2009 lifecycle estimate (FY 2006-2015): $21.083 billion; 
2010 lifecycle estimate (FY 2006-2015): $21.103 billion; 
Actual costs and benefits (FY 2006-2010): Not known. 

Source: GAO analysis of CMS data. 

[A] One PI officials initially projected system benefits from fiscal 
year 2008 through fiscal year 2013. 

[B] Because the agency has not updated the benefits estimate, we 
carried this figure forward. 

[End of table] 

However, the current implementation of One PI has not yet produced 
outcomes that position the agency to identify or measure financial 
benefits. Therefore, the net financial benefit of developing and 
implementing One PI remains unknown. Center for Program Integrity 
officials stated that at the end of fiscal year 2010--over a year 
after deploying One PI--it was too early to determine whether the 
program has provided any financial benefits because, since the program 
had not met its goal for widespread use of One PI, there were not 
enough data available to quantify financial benefits attributable to 
the use of the system. These officials anticipated that as the user 
community is expanded, they will be able to begin to identify and 
measure financial and other benefits of using the system. However, the 
officials also indicated that they had not yet defined mechanisms for 
determining the amount of money recovered as a result of detecting 
improper payments through the use of One PI. As with IDR, until the 
agency quantifies and tracks the progress it is making in delivering 
benefits intended to be realized through widespread use of One PI, CMS 
officials cannot be assured of the cost-effectiveness of implementing 
One PI to help the agency meet its goal to enable consistent, 
reliable, and timely analyses of data to improve the agency's ability 
to detect fraud, waste, and abuse. 

Additionally, in discussion groups held with active One PI users, 
program integrity analysts identified several issues that confirmed 
the agency's limited progress toward meeting the goals of the program. 
For example, while several users told us that the One PI system can 
support their work, they recognized limited progress toward the 
establishment of a single source of information and analysis tools for 
all fraud, waste, and abuse activities. Further, One PI users stated 
that the system enabled analysts to access national data not otherwise 
accessible to them and supported analysis across different Medicare 
programs. They also noted that the tools offered by One PI provided 
more functionality than other tools they use. However, of the analysts 
in the discussion groups, most did not use One PI as their only source 
of information and analysis for detecting improper payments. Rather, 
to help conduct their work, they relied on other analysis tools 
provided by CMS or their companies, along with data from CMS claims 
processing contractors or from private databases created by other 
contractors. 

One PI users in the discussion groups also told us that they use other 
tools because they are more familiar with those tools. Additionally, 
they stated that other databases sometimes provide data that are not 
currently accessible through One PI and IDR, such as demographic data 
about providers. Program integrity analysts further stated that they 
only use One PI as a cross-check of data and analysis from their own 
systems because they are not yet convinced that One PI can be used as 
a replacement for or adjunct to those data sources and tools. 

Further, CMS officials have not developed quantifiable measures for 
meeting the program's goals. CMS officials defined and reported to OMB 
performance measures and targets toward meeting the program's goals 
for enabling timely analyses of data to detect cases of fraud, waste, 
and abuse, but have not yet been able to quantify measures for these 
indicators. For example, performance measures and targets for One PI 
include increases in the detection of improper payments for Medicare 
Parts A and B claims. However, according to program integrity 
officials, measures had not yet been quantified because they had not 
yet identified ways to determine the extent to which increases in the 
detection of errors could be attributed to the use of One PI. 
Additionally, the limited use of the system has not generated enough 
data to quantify the amount of funds recovered from improper payments. 
Moreover, measures of One PI's program performance do not accurately 
reflect the current state of the program. Specifically, indicators to 
be measured for the program include the number of states using One PI 
(for Medicaid integrity purposes) and decreases in the Medicaid 
payment error rate, but One PI does not have access to those data 
because they are not yet incorporated into IDR. Therefore, these 
performance indicators are not relevant to the current implementation 
of the system. 

Finally, CMS officials did not consult external system users (e.g., 
program integrity contractors) in developing measures of One PI's 
effectiveness. According to industry experts, [Footnote 26] developing 
performance measures with stakeholder input early in the planning 
process can provide a mechanism for gauging the effectiveness of 
outcomes toward meeting business needs and achieving program goals as 
a program progresses. However, CMS officials did not consult external 
users of the system about how they would measure its effectiveness. 
According to program officials, program integrity stakeholders within 
CMS were involved in the development of the performance measures; 
however, external users of the system were not asked to provide input 
when it may have been used to establish an effective performance 
tracking tool, such as when defining ways to determine whether One PI 
meets stakeholders' needs. For example, program officials told us that 
they intend to determine user satisfaction, a performance measure 
reported to OMB, by conducting surveys at the end of training 
sessions. However, these surveys were conducted before the analysts 
actually used the system in their work and were focused on 
satisfaction with the training itself. In this case, involvement of 
external stakeholders when defining the measure could have led to more 
effective ways to determine user satisfaction, such as surveying 
analysts based on their experiences resulting from the use of One PI 
after a certain period of time defined by stakeholders. 

Until they define measurable performance indicators and targets that 
reflect the goals and objectives of CMS's program integrity 
initiatives, agency officials will continue to lack the information 
needed to ensure that the implementation of One PI helps improve the 
agency's ability to identify improper payments and to detect cases of 
fraud, waste, and abuse. Additionally, when lacking stakeholders' 
input into the process for determining measures of successful 
performance, One PI program officials may miss an opportunity to 
obtain information needed to define meaningful measures that reflect 
the success of the program toward meeting users' and the agency's 
needs. Because it lacks meaningful outcome-based performance measures 
and effective methods for tracking progress toward meeting performance 
targets, CMS does not have the information needed to ensure that the 
system is useful to the extent that benefits realized from the 
implementation of One PI help the agency meet program integrity goals. 

Conclusions: 

IDR and One PI program officials have made progress in developing and 
implementing IDR and One PI to support CMS's program integrity 
initiatives, but the systems do not yet provide all the data and 
functionality initially planned. Additionally, CMS program integrity 
officials have not yet taken appropriate actions to ensure the use of 
IDR and One PI on a widespread basis for program integrity purposes. 
Further, program officials have not defined plans and reliable 
schedules for incorporating the additional data into IDR that are 
needed to support its program integrity goals. Until the agency takes 
these steps, it cannot ensure that ongoing development, 
implementation, and deployment efforts will provide the data and 
technical capabilities needed to improve program integrity analysts' 
capabilities for detecting potential cases of fraud, waste, and abuse. 

Furthermore, because the systems are not being used as planned, CMS 
program integrity officials are not yet in a position to determine the 
extent to which the systems are providing financial benefits or 
supporting the agency's initiatives to meet its program integrity 
goals and objectives. Until it does so, CMS officials will lack the 
means to determine whether the use of the systems contributes to the 
agency's goal of reducing the number and amounts of improper payments 
made as a result of fraudulent, wasteful, or abusive claims for 
Medicare and Medicaid services. Furthermore, the contribution of IDR 
and One PI to the agency's efforts to save billions of dollars each 
year attributable to improper payments made due to fraud, waste, and 
abuse in the Medicare and Medicaid programs will remain unknown. 

Recommendations for Executive Action: 

To help ensure that the development and implementation of IDR and One 
PI are successful in helping the agency meet the goals and objectives 
of its program integrity initiatives, we are recommending that the 
Administrator of CMS take the following seven actions: 

* finalize plans and develop schedules for incorporating additional 
data into IDR that identify all resources and activities needed to 
complete tasks and that consider risks and obstacles to the IDR 
program; 

* implement and manage plans for incorporating data in IDR to meet 
schedule milestones; 

* establish plans and reliable schedules for training all program 
integrity analysts intended to use One PI; 

* establish and communicate deadlines for program integrity 
contractors to complete training and use One PI in their work; 

* conduct training in accordance with plans and established deadlines 
to ensure schedules are met and program integrity contractors are 
trained and able to meet requirements for using One PI; 

* define any measurable financial benefits expected from the 
implementation of IDR and One PI; and: 

* with stakeholder input, establish measurable, outcome-based 
performance measures for IDR and One PI that gauge progress toward 
meeting program goals. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report, signed by HHS's 
Assistant Secretary for Legislation and reprinted in appendix II, CMS 
stated that it concurred with all of our recommendations and 
identified steps agency officials were taking to implement them. Among 
these were actions to further refine training plans to better ensure 
that program integrity contractors are trained and able to meet 
requirements to use One PI, along with efforts to define measurable 
financial benefits expected from augmenting the data in IDR. If these 
and other identified actions are implemented in accordance with our 
recommendations, CMS will be better positioned to meet the goals and 
objectives of its program integrity initiatives. The agency also 
provided technical comments, which were incorporated as appropriate. 

As we agreed with your offices, unless you publicly announce the 
contents of this report earlier, we plan no further distribution of it 
until 30 days from the date of this letter. At that time, we will send 
copies of this report to appropriate congressional committees, the 
Administrator of CMS, and other interested parties. The report will 
also be available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have questions about this report, please contact 
me at (202) 512-6304 or melvinv@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Key contributors to this report are 
listed in appendix III. 

Signed by: 

Valerie C. Melvin: 
Director, Information Management and Human Capital Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

The objectives of our review were to (1) assess the extent to which 
the Centers for Medicare and Medicaid Services (CMS) has developed and 
implemented the Integrated Data Repository (IDR) and One Program 
Integrity (One PI) systems and (2) determine the agency's progress 
toward achieving defined goals and objectives for using the systems to 
help detect fraud, waste, and abuse in the Medicare and Medicaid 
programs. 

To assess the extent to which IDR and One PI have been developed and 
implemented, we collected and analyzed agency documentation that 
described planning and management activities. Specifically, we 
assessed project management plans and artifacts that described the 
status of the systems, such as program management review briefings to 
technical review boards, and memoranda approving continued development 
and implementation of the systems at key decision points in the 
systems' lifecycles. We observed the operation of CMS's data center 
where IDR is installed and viewed a demonstration of the One PI portal 
and analytical tools. We also discussed with officials from CMS's 
Office of Information Services and Center for Program Integrity plans 
for and progress made toward developing and implementing the systems. 
We focused our analysis on the extent to which the development and 
implementation of IDR and One PI met system and business requirements 
and plans for deploying the systems to CMS's program integrity 
analysts. 

To assess the agency's processes for defining system requirements, we 
reviewed IDR and One PI requirements management plans, system 
requirements, and documentation that traces requirements to 
functionality provided by the systems at different stages of 
implementation. Program documents we reviewed include the 2007 IDR 
Medicare Program Integrity Requirements, the 2006 One PI Startup 
Findings Draft, the 2010 One PI Requirements Management Plan, and 
detailed software requirements specifications for One PI. In addition, 
we discussed with IDR and One PI program officials their requirements 
development and management processes and procedures. We then assessed 
the department's current approach to requirements development and 
management against best practices identified in the Software 
Engineering Institute's Capability Maturity Model Integrated. 

To assess schedule estimates of the IDR and One PI programs, we used 
criteria defined in GAO's cost estimating and assessment guide to 
determine the extent to which relevant schedules were prepared in 
accordance with best practices that are fundamental to estimating 
reliable schedules. We identified information reported to the Office 
of Management and Budget (OMB) by CMS in fiscal year 2010 that defined 
program schedule estimates for the remaining lifecycles of the 
programs through 2016. We collected and analyzed program documentation 
that supported these estimates, such as work breakdown structures and 
staffing estimates. 

To assess each program's schedule estimates, we rated the IDR and One 
PI program management offices' implementation of nine scheduling best 
practices defined in our guidance. Based on these criteria, we 
analyzed the One PI integrated master schedule and the IDR validation, 
along with supporting documentation, and used commercially available 
software tools to assess the schedules. Specifically, we determined 
whether each schedule was developed by identifying and including 
critical elements of reliable scheduling best practices, such as 
identifying all resources needed to conduct activities, and whether 
risk assessment and contingency plans had been conducted for the 
schedules. 

We shared our guidance, the criteria against which we evaluated the 
program's schedule estimates, as well as our preliminary findings with 
program officials. We then discussed our preliminary assessment 
results with the program management officials. When warranted, we 
updated our analyses based on the agency response and additional 
documentation provided to us. We also analyzed changes to the program 
schedules over time. 

To determine the reliability of the data used to assess schedule 
estimates, we used a scheduling analysis software tool that identified 
missing logic and constraints, and checked for specific problems that 
could hinder the schedule's ability to dynamically respond to changes. 
We examined the schedule data to identify any open-ended activities 
(i.e., activities with no predecessor or successors), and searched for 
activities with poor logic, such as activities with constraints that 
keep the schedule rigid (e.g., start no earlier than, finish no later 
than, etc.). We found the data sufficiently reliable for the purposes 
of this review. 

To determine the number of system end users for One PI, we identified 
the universe of analysts trained to use One PI by examining 
documentation provided by CMS. Specifically, we obtained a list of 
trained users from the Center for Program Integrity. From that list, 
we selected program integrity analysts whom CMS identified as using 
the system to conduct analyses of IDR data to identify potential cases 
of fraud, waste, and abuse. We then compared this selection of 
analysts to data generated by the One PI system that recorded user 
login data from January 3, 2010, through October 16, 2010, to identify 
the current population of One PI users. Through this analysis, we 
identified 41 trained program integrity analysts who had used the 
system during the designated time period, including 8 Medicare drug 
integrity contractors, 23 zone program integrity and program safeguard 
contractors, and 10 CMS program integrity analysts. 

To ensure that the data that we used to identify One PI users were 
reliable, we held discussions with CMS officials who were 
knowledgeable of the user community and mechanisms for accessing the 
system. We discussed with them the list of trained end users and the 
computer-generated login information provided by the system. We also 
discussed the reliability of the computer-generated system login 
information. Specifically, agency officials confirmed that the data 
reported by the system were complete and accurate and that the method 
we used to identify active users--an analysis of system login data--
was valid. 

To determine the extent to which the IDR and One PI programs have 
achieved defined goals and objectives for using the systems to help 
detect fraud, waste, and abuse, we collected CMS's analyses of 
projected costs and benefits for IDR and One PI. We also collected and 
assessed data reported on the costs and benefits realized through the 
current implementation of the systems. To do so, we compared (1) 
actual costs and benefits attributed to each system through fiscal 
year 2010 and (2) current estimated total lifecycle costs and benefits 
for each system. We calculated the expected net benefit by subtracting 
estimated and actual system costs from estimated and actual system 
benefits for each system. To understand how costs and benefits for 
each system were derived, we met with officials from the Office of 
Information Services and from the Center for Program Integrity and 
discussed CMS's processes for estimating and tracking costs and 
benefits of both IDR and One PI. We also obtained from agency 
officials documentation about and descriptions of qualitative benefits 
provided by both systems. Additionally, we reviewed planning documents 
that described the goals and objectives of both programs, along with 
other documentation that described actions taken to address program 
goals and objectives. We reviewed and assessed supporting 
documentation for the measures, which the agency reported to OMB as 
having been met. 

To determine if CMS's approach to developing performance measures for 
IDR and One PI was consistent with federal guidance, we examined 
documents describing CMS's approach and held discussions with program 
officials about practices they followed when defining performance 
measures and targets. We compared program officials' practices to 
guidance defined by OMB. We also compared the performance measures 
defined for the two programs to CMS's goals and objectives for program 
integrity initiatives to determine if the IDR and One PI measures 
supported intended outcomes of agencywide efforts to better detect 
fraud, waste, and abuse. We supplemented our documentation review with 
interviews of officials from the Center for Program Integrity and the 
Office of Information Services to obtain additional information about 
the development of current and future performance measures for IDR and 
One PI. During our interviews, we discussed performance measures and 
strategic goals and initiatives for One PI and IDR, and the extent to 
which the agency involved internal and external stakeholders in the 
development of performance measures. 

To obtain information about the extent to which One PI has been 
deployed and is being used by a broad community of program integrity 
analysts to meet CMS's goals and objectives, we invited the 41 users 
we identified in addressing the first objective of this engagement to 
participate in facilitated discussions about the data and tools needed 
to support fraud, waste, and abuse detection. Thirty-two of those 41 
users attended the discussion group meetings. During those meetings, 
we discussed the following topics: usage of One PI tools and data from 
IDR, comparison and contrasting of One PI and IDR with other tools and 
data sets, and benefits and challenges of using One PI and IDR for 
detecting fraud, waste, and abuse. We also discussed users' needs for 
analytical tools and data and for systems training. After those 
discussions, we sent written questions to all 32 discussion group 
participants to obtain more detailed information about their use of 
analytical tools and data sources. Thirty-one participants responded 
and provided additional supplementary information about their use of 
One PI and IDR. 

For each of the objectives, we assessed the reliability of the data we 
analyzed through interviews with agency officials knowledgeable of the 
user community and training program, mechanisms for accessing the 
systems, and the methods for tracking and reporting costs and 
schedules of the IDR and One PI programs. We found the data 
sufficiently reliable for the purposes of this review. 

We conducted this performance audit from June 2010 through June 2011 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Department of Health and Human Services: 

Department of Health & Human Services: 
Office of the Assistant Secretary for Legislation: 
Washington, D.C. 20201: 

May 25 2011:  

Valerie C. Melvin: 
Director, Information Management and Human Capital Issues: 
U.S. Government Accountability Office: 
441 G Street N.W. 
Washington, DC 20548:  

Dear Ms. Melvin:  

Attached are comments on the U.S. Government Accountability Office's 
(GAO) draft report entitled, "Fraud Detection Systems: Centers for 
Medicare and Medicaid Services Needs to Ensure More Widespread Use" 
(GA0-11-475).  

The Department appreciates the opportunity to review this draft report 
prior to publication.  

Sincerely,  

Signed by: 

Jim R. Esquea: 
Assistant Secretary for Legislation:
 
Attachment: 

[End of letter] 

General Comments Of The Department Of Health And Human Services (HHS) 
On The Government Accountability Office's (GAO) Draft Report Entitled, 
"Fraud Detection Systems: Centers For Medicare & Medicaid Services 
Needs To Ensure More Widespread Use" (GA0-11-475): 

The Department appreciates the opportunity to review and comment on 
this draft report. The purpose of this report was to assess the extent 
to which the Integrated Data Repository (IDR) and One Program 
Integrity (One PI) have been developed and implemented and to 
determine CMS' progress toward achieving its goals and objectives for 
using these systems to help detect fraud, waste, and abuse. 

The Centers for Medicare & Medicaid Services (CMS) is committed to 
continuing to develop and monitor integrated project schedules, 
training schedules, and performance measures that will achieve the 
goals and objectives of these systems. 

GAO Recommendation No. 1: 

The Administrator of CMS should finalize plans and develop schedules 
for incorporating additional data into IDR that identify all resources 
and activities needed to complete tasks and that consider risks and 
obstacles to the IDR program. 

CMS Response: 

CMS concurs with this recommendation. We will work to develop 
integrated project schedules that incorporate all resources required 
to complete tasks as well as identify potential risks that can cause 
schedule slippage. 

GAO Recommendation No. 2: 

The Administrator of CMS should implement and manage plans for 
incorporating data in IDR to meet schedule milestones. 

CMS Response: 

CMS concurs with this recommendation. CMS currently requires detailed 
project plans for projects that have been funded and approved to move 
forward to incorporate new data elements into the IDR. We will utilize 
project and risk management best practices to better ensure that 
projects meet schedule milestones. 

GAO Recommendation No. 3: 

The Administrator of CMS should establish plans and reliable schedules 
for training all program integrity analysts intended to use One PI. 

CMS Response: 

CMS concurs with this recommendation. Since the creation of the Center 
for Program Integrity (CPI) in April 2010, the One PI Team has worked 
to establish plans and reliable training schedules for all intended 
One PI users. Accomplishments include but arc not limited to: 

* Completed the revision of the One PI Training courses for both 
Advantage Suite and Business Objects; 

* At users' requests, created "advanced" training courses for both 
Advantage Suite and Business Objects; 

* Dozens of analysts from the program integrity contractors have been 
trained to use One PI since the beginning of 2011. 

* Doubled the number of available training courses from two classes a 
month to four classes a month. Fifty eight new users have been trained 
since January 2011. In the preceding period, July 2009 through 
December 2010, only 33 new users were trained. 

CMS will continue to further refine the One PI plans and schedules in 
order to provide training for all program integrity analysts that 
intend to use One PI as swiftly as possible. 

GAO Recommendation No. 4: 

The Administrator of CMS should establish and communicate deadlines 
for program integrity contractors to complete training and use One PI 
in their work. 

CMS Response: 

CMS concurs with this recommendation. A training schedule has been 
compiled for all remaining analysts from the program integrity 
contractors that use One PI in their work. This schedule will be 
closely monitored and all appropriate zone program integrity 
contractor (ZPIC) staff will be trained in the use of One PI during 
the next 5 months. 

Due to recent protests for Zones 3 and 6, the last two ZPIC awards 
will be delayed until GAO makes their rulings. This will most likely 
occur around the second week of August 2011 and the outcome will 
determine if additional contractor staff will require training. It is 
possible that the final awards will go to companies with analysts that 
have already been trained. 

GAO Recommendation No. 5: 

The Administrator of CMS should conduct training in accordance with 
plans and established deadlines to ensure schedules are met and 
program integrity contractors are trained and able to meet 
requirements for using One PI. 

CMS Response: 

CMS concurs with this recommendation. CMS continues to refine the 
training strategy for One PI to ensure that training plans, to include 
deadlines for users to be trained, are met so that the program 
integrity contractors are able to meet their requirements to use One 
PI. 

GAO Recommendation No. 6: 

The Administrator of CMS should define any measurable financial 
benefits expected from the implementation of IDR and One PI. 

CMS Response: 

CMS concurs with this recommendation. CMS will define the measurable 
financial benefits expected from augmenting the data available in the 
IDR, so that One PI users will be able to fight fraud, waste, and 
abuse across all Medicare and Medicaid claim types. 

The majority of measurable financial benefits expected from the 
implementation of the IDR result from cost savings associated with 
retiring redundant legacy systems, databases, and data sources as well 
as the cost avoidance of leveraging the existing IDR platform to 
support new data requirements rather than building new data 
repositories in a silo. CMS will attempt to develop cost estimates for 
these activities. 

GAO Recommendation No. 7: 

The Administrator of CMS should, with stakeholder input, establish 
measurable, outcome-based performance measures for IDR and One PI that 
gauge progress toward meeting program goals. 

CMS Response: 

CMS concurs with this recommendation. CMS will continue to review the 
performance measures for the program to determine the set that will be 
used in the future. We will work with One PI stakeholders, to include 
the Office of the Inspector General and the Department of Justice, to 
create measurable, outcome-based performance measures that gauge 
progress toward meeting program goals. 

CMS will collaborate with IDR users and stakeholders to establish 
performance measures that tie to CMS program goals. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Valerie C. Melvin, (202) 512-6304 or melvinv@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Teresa F. Tucker (Assistant 
Director), Sheila K. Avruch (Assistant Director), April W. Brantley, 
Clayton Brisson, Neil J. Doherty, Amanda C. Gill, Kendrick M. Johnson, 
Lee A. McCracken, Terry L. Richardson, Karen A. Richey, and Stacey L. 
Steele made key contributions to this report. 

[End of section] 

Footnotes: 

[1] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: February 
2011). 

[2] The One PI portal is a Web-based user interface that enables a 
single login through centralized, role-based access to the system. 

[3] The Software Engineering Institute is a federally funded research 
and development center that conducts software engineering research in 
areas such as acquisition and process improvement and performance 
measurement. The institute is based at Carnegie Mellon University and 
is sponsored by the Department of Defense's Under Secretary for 
Acquisition, Technology, and Logistics. 

[4] Social Security Act §§ 1903 (codified at 42 U.S.C. § 1396b), 1905 
(codified at 42 U.S.C. § 1396d). 

[5] HIPAA established the Medicare Integrity Program and codified the 
program integrity activities previously known as "payment safeguards." 
Pub. L. No. 104-191, § 202, 110 Stat. 1936, 1996, SSA §1893 (codified 
at 42 U.S.C. § 1395ddd). 

[6] CMS is phasing out its use of program safeguard contractors, the 
predecessors to zone program integrity contractors. In implementing a 
2003 statute, CMS began to consolidate all program integrity functions 
for seven geographically based zones under one type of contractor to 
replace the program safeguard structure, which organized contractor 
functions by program types. This effort is ongoing. Currently, both 
types of contractors perform program integrity functions for the 
agency. 

[7] The Medi-Medi program was established in 2001 and designed to 
identify improper billing and utilization patterns by matching 
Medicare and Medicaid claims information on providers and 
beneficiaries to reduce fraudulent schemes that cross program 
boundaries. The Social Security Act provides funds for CMS to contract 
with third parties to identify program vulnerabilities in Medicare and 
Medicaid through examining billing and payment abnormalities. The 
funds also can be used in connection with the Medi-Medi program for 
two other purposes: (1) coordinating actions by CMS, the states, the 
Attorney General, and the HHS Office of the Inspector General to 
protect Medicaid and Medicare expenditures, and (2) increasing the 
effectiveness and efficiency of both Medicare and Medicaid through 
cost avoidance, savings, and recouping fraudulent, wasteful, or 
abusive expenditures. The program is implemented in 10 states. 

[8] Pub. L. No. 109-171, § 6034, 120 Stat. 4, 74-78 (2006). 

[9] Department of Health and Human Services, Office of the Inspector 
General, Medicare's Program Safeguard Contractors: Activities to 
Detect and Deter Fraud and Abuse, OEI-03-06-00010 (Washington, D.C., 
July 2007). 

[10] To meet requirements of the Federal Food, Drug, and Cosmetic Act, 
21 U.S.C. § 360, establishments that make or process drugs identify 
and report drugs for human use to HHS's Food and Drug Administration 
by a unique, three-segment number, called the National Drug Code. 

[11] Medicare Advantage plans are not currently required to report 
Part C claims data to CMS and, while CMS does not yet collect these 
data, it plans to do so in the future. Additionally, CMS intends to 
incorporate data about Part C patient encounters and episodes of care 
into IDR but has not yet begun to plan this activity. 

[12] CMS was recently required by the Small Business Jobs Act of 2010 
and received funding to add predictive modeling and other analytic 
techniques--known as predictive analytic technologies--both to 
identify and to prevent improper payments under the Medicare fee-for- 
service. Through such analysis, unusual or suspicious patterns or 
abnormalities could be identified and used to prioritize additional 
review of suspicious transactions before payment is made. 

[13] In addition to the data that CMS plans to incorporate into IDR, 
recent legislation mandates the inclusion of other data to support 
improvements in outcomes of program integrity efforts. Specifically, 
the Patient Protection and Affordable Care Act requires HHS to expand 
IDR to include claims and payment data from the Departments of 
Veterans Affairs and Defense, the Indian Health Service, and the 
Social Security Administration. According to HHS's OIG, the intention 
of this requirement of the act is to foster data-matching agreements 
among CMS and these agencies to make it easier to detect fraud, waste, 
and abuse. However, IDR program officials stated that CMS has not yet 
developed plans and established schedules for including the data 
required to meet this mandate. 

[14] GAO, Medicare: Antifraud Technology Offers Significant 
Opportunity to Reduce Health Care Fraud, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-95-77] (Washington, D.C.: Aug. 
11, 1995). 

[15] GAO, Information Technology: Centers for Medicare & Medicaid 
Services Needs to Establish Critical Investment Management 
Capabilities, [hyperlink, http://www.gao.gov/products/GAO-06-12] 
(Washington, D.C.: Oct. 28, 2005). The Information Technology 
Investment Management framework is a maturity model developed by GAO 
that comprises five progressive stages of maturity that an agency can 
achieve in its investment management capabilities. 

[16] The Medicaid Management Information System is the primary claims 
processing and information retrieval system that CMS requires states 
to use in their Medicaid programs. 

[17] GAO, Medicare: Improvements Needed to Address Improper Payments 
for Medical Equipment and Supplies, [hyperlink, 
http://www.gao.gov/products/GAO-07-59] (Washington, D.C.: Jan. 31, 
2007). 

[18] GAO, Medicare: Improvements Needed to Address Improper Payments 
in Home Health, [hyperlink, http://www.gao.gov/products/GAO-09-185] 
(Washington, D.C.: Feb. 27, 2009). 

[19] GAO, Medicare and Medicaid Fraud, Waste, and Abuse: Effective 
Implementation of Recent Laws and Agency Actions Could Help Reduce 
Improper Payments, [hyperlink, 
http://www.gao.gov/products/GAO-11-409T] (Washington, D.C.: Mar. 9, 
2011). 

[20] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for 
Developing and Managing Capital Program Costs, [hyperlink, 
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March 2009). 

[21] One PI program officials told us in April 2011 that about 20 more 
program integrity analysts had begun to use the system. The scope, 
methodology, and time frame of our study limited our analysis to data 
based on information available from CMS through October 2010. 
Therefore, we did not validate program officials' April estimate. 

[22] GAO, Secure Border Initiative: DHS Needs to Reconsider Its 
Proposed Investment in Key Technology Program, [hyperlink, 
http://www.gao.gov/products/GAO-10-340] (Washington, D.C.: May 5, 
2010) and DOD Business Systems Modernization: Planned Investment in 
Navy Program to Create Cashless Shipboard Environment Needs to be 
Justified and Better Managed, GAO-08-922 (Washington, D.C.: Sept. 8, 
2008). 

[23] OMB, Guide to the Performance Assessment Rating Tool. 

[24] Thomas Wettstein and Peter Kueng, A Maturity Model for 
Performance Measurement Systems, and Karen J. Richter, Ph.D., 
Institute for Defense Analyses, CMMI®for Acquisition (CMMI-ACQ) 
Primer, Version 1.2. 

[25] The number of lifecycle years reported for an IT project is 
defined by OMB. Agencies report accordingly. 

[26] Thomas Wettstein and Peter Kueng, A Maturity Model for 
Performance Measurement Systems. 

[End of section] 

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