By Brian Craig, J.D.
The number of states meeting CMS’s standards in certain categories for data completeness and accuracy increased from six states to 41 states between October 2018 and August 2020.
A recent report by the Government Accountability Office (GAO) shows that while Medicaid data completeness and accuracy have improved in recent years, not all standards have been met. The GAO found that the completeness and accuracy of Transformed Medicaid Statistical Information System (T-MSIS) data—the CMS initiative to improve state-reported data available for overseeing Medicaid—have significantly improved in the last two years. Specifically, the number of states meeting CMS’s standards in certain categories for data completeness and accuracy increased from six states to 41 states between October 2018 and August 2020. The report also found that not all reporting standards have been met. For example, the GAO found that many states failed to submit acceptable data for inpatient managed care encounters (GAO Report, GAO-21-196, January 14, 2021).
Data reporting improvements. The GAO found completeness and accuracy of T-MSIS data have improved in the last two years. As to priority items, or areas of data CMS has identified as critical for program oversight such as beneficiary eligibility and managed care, data reporting has improved. For example, the GAO concluded that all states submitted some data for 67 of the 69 topics relevant to their Medicaid programs in 2020. The number of states meeting CMS’s standards for at least 10 of the first 12 priority items that are critical for program oversight increased from six states to 41 states between October 2018 and August 2020. The number of states meeting standards for reporting accurate enrollment of dual eligible beneficiaries increased from 25 states to 35 states during the same time period. Likewise, the number of states meeting standards for consistently reporting beneficiary data in the eligibility file increased from 22 states to 32 states between March 2020 and August 2020.
With respect to analytic files, or publicly available research-ready T-MSIS data, the GAO found that all states submitted some data for 67 of the 69 topics relevant to their Medicaid programs. This reflects an improvement from what the GAO found in 2017, when none of the six states reviewed submitted all T-MSIS data applicable to their programs. The GAO also found that states’ data for 52 of the 69 topics were acceptable and did not have significant problems that would affect usability.
Standards not met. While the GAO found certain areas of improvement , the GAO identified some areas where states have not met CMS’s reporting standards. For example, the GAO found that 30 states did not submit acceptable data for inpatient managed care encounters. Accurate encounter data are critical to ensuring that Medicaid managed care beneficiaries obtain covered services and that payments to managed care organizations are appropriate. In addition, 15 states did not meet CMS’s standards related to ensuring the consistency of managed care organization (MCO) identifiers across certain T-MSIS files and 11 states did not meet CMS’s standards related to consistency of capitated payments with MCO enrollment. Furthermore, the report found that 37 states did not meet the standards for the completeness and consistency of data on paid claims and 33 states did not meet standards related to priority key provider information in the claims files, including National Provider Identifiers (NPIs).
Recommendations. The GAO has made at least 13 recommendations related to improving T-MSIS data and expediting their use for program oversight. CMS has addressed five of these recommendations and has not fully addressed eight, including recommendations to improve data for overseeing payments to providers and managed care organizations. The GAO concluded that implementing these recommendations would help CMS strengthen program oversight through improved T-MSIS data.
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