Kusserow on Compliance: OIG reports the new Medicaid data system inadequate

The OIG reported that historical inadequacies in Medicaid data have hindered program integrity, research, budgeting, and policy. As a result the OIG has designated the improvement of Medicaid data as a top management HHS challenge. In 2016, the federal Government and states spent $574 billion on Medicaid, serving more than 74 million enrolled individuals. Complete, accurate, and timely Medicaid data are vital for the effective administration and oversight of the Medicaid program by states and the federal Government. The Transformed Medicaid Statistical Information System (T-MSIS) is a new data system that was developed to improve the completeness, accuracy, and timeliness of Medicaid data. The OIG provided a status update on the implementation of T-MSIS, building on its previous review of the 2013 T-MSIS pilot.

In conducting its review, the OIG analyzed the implementation status of T-MSIS using 40 states’ approved plans for data submission; and interviewed staff from CMS and 16 states about their experiences implementing T-MSIS. The OIG reported the following:

  1. States and CMS reported early implementation challenges resulted in delays with T-MSIS
  2. Technological problems and competing priorities for states’ resources caused delays
  3. The goal date for when T-MSIS will contain data from all states has been repeatedly postponed
  4. CMS expects that all states will be reporting to T-MSIS by the end of 2017
  5. 21 of 53 state programs were submitting data to T-MSIS
  6. States and CMS continue to raise concerns about completeness and reliability of the data
  7. States indicate that they are unable to report data for all the T-MSIS data elements
  8. Even with a revised data dictionary for each data element, states and CMS report concerns about states’ varying interpretations of data elements
  9. Without uniform interpretations of data elements, the data submitted will not be consistent across states, making any analysis of national trends or patterns inherently unreliable.

The OIG concluded that successfully getting all states’ data into T-MSIS requires states and CMS to prioritize T-MSIS implementation. However because of CMS’s history of delaying target dates for implementation, the OIG expressed concerned that CMS and states will delay further rather than assign the resources needed to address the outstanding challenges. The OIG further noted that without a fixed deadline, some states and CMS may not make the full implementation of T-MSIS a management priority.

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2017 Strategic Management Services, LLC. Published with permission.