Recommendation: The Commissioner of the FDA should ensure that PAC renews its charter. (Recommendation 1)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of Internal Revenue should require ETAAC and IRSAC to make decisions on proposed recommendations to IRS during open meetings. (Recommendation 2)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of Internal Revenue should require ETAAC and IRSAC to compile meeting minutes and make them publicly available. (Recommendation 3)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Census Bureau should require CSAC to compile meeting minutes and make them publicly available. (Recommendation 4)

Agency: Department of Commerce: Bureau of the Census
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Treasury should require FACA committees under Treasury's purview to provide access to meeting agendas and supporting documents on the committees' websites. (Recommendation 5)

Agency: Department of the Treasury
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of NIH should establish and implement a policy requiring all FACA committees under NIH's jurisdiction to post meeting minutes online. (Recommendation 6)

Agency: Department of Health and Human Services: Public Health Service: National Institutes of Health
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of GSA should encourage FACA committees to make information on agencies' responses to and implementation of specific recommendations publicly available online, unless exempted from public disclosure under the Freedom of Information Act. (Recommendation 7)

Agency: General Services Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of GSA should require agencies to develop and implement written policies or procedures to identify, calculate, and fully document FACA committee costs, and ensure agency staff enter accurate and complete cost data into the FACA database. (Recommendation 8)

Agency: General Services Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of GSA should direct the Committee Management Secretariat to require FACA committees to specify the exact date when they last updated cost data in the FACA database. This could be completed in a field in the database under the "Committee Cost" section or in another relevant data field. (Recommendation 9)

Agency: General Services Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: Congress should consider amending FACA to require agencies and advisory committees to make available online documents FACA already requires to be made available for public inspection and copying. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: When we determine what steps the Congress has taken, we will provide updated information.

Recommendation: The Secretary of the Treasury should ensure that information about the 90-day delay for displaying DOD procurement data on USAspending.gov is transparently communicated to users of the site. Approaches for doing this could include prominently displaying this information on the DOD agency profile page, in the unreported data section, and in search results that include DOD data. (Recommendation 1)

Agency: Department of the Treasury
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Treasury should ensure that information regarding how the Primary Place of Performance Address for Medicare payment data are reported is transparently communicated to the users of USAspending.gov. (Recommendation 2)

Agency: Department of the Treasury
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of OMB should ensure that information is collected regarding how centralized reporting of procurement requirements might reduce recipient reporting burden—including input from stakeholders such as contractors through an iterative and ongoing process—to inform OMB's planned expansion of the Central Reporting Portal.

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: In an October 2019 written response to the recommendation contained in GAO-19-299, OMB acknowledged the importance of collecting stakeholder input and described some steps that it has taken to do so in the past. The letter also stated OMB's intention to engage key stakeholders moving forward but was not specific regarding steps it planned to take related to the potential expansion of the Central Reporting Portal. GAO will continue to monitor this issue including what specific actions, if any, OMB takes in response to this recommendation.

Recommendation: The Secretary of the Treasury should fully comply with OMB's requirements by providing metadata in a single location that are easy to find on the USAspending.gov website. (Recommendation 3)

Agency: Department of the Treasury
Status: Open

Comments: Treasury agreed with the recommendation. As of September 2020, metadata are not available on USAspending.gov.

Recommendation: The Secretary of the Army should require monitoring of its processes used for recording all required real property information--to include evaluating on an ongoing basis whether or to what extent these activities are being carried out--and remediating any identified deficiencies. (Recommendation 1)

Agency: Department of Defense: Department of the Army
Status: Open
Priority recommendation

Comments: The Army concurred with this recommendation. As of February 2020, DOD officials told us that the Army has required monitoring of its processes used for recording all real property information. Specifically, the Army developed a 5-year plan to address the recommendations to improve data quality and accountability in conjunction with the ongoing DOD financial statement audit. The plan reportedly requires measuring results through directed physical inspections and record updates, using a single, standardized Accountable Property System of Record (APSR) for all assets. DOD officials also told us that the Army developed an automated validation and second-person verification to comply with the requirements and business rules of the DOD Real Property Information Model (RPIM), and that it continue to use OSD's validation and verification tool when providing annual data inputs to OSD's Real Property Assets Database, with any feedback to be addressed at senior Army levels. However, DOD officials did not provide any documentation that these requirements have been established. Once we receive that documentation, we will review it to assess the extent to which it meets the intent of our recommendation.

Recommendation: The Secretary of the Navy should require monitoring of Navy and Marine Corps processes used for recording all required real property information--to include evaluating on an ongoing basis whether or to what extent these activities are being carried out--and remediating any identified deficiencies. (Recommendation 2)

Agency: Department of Defense: Department of the Navy
Status: Open
Priority recommendation

Comments: The Navy concurred with this recommendation. As of February 2020, DOD officials stated that the Navy required monitoring of its processes used for recording real property information. Specifically, the Navy established a requirement for a 100% inventory check to ensure existence and completeness of its real property information. As part of DOD larger effort to improve its financial management through the Financial Improvement and Audit Readiness (FIAR) guidance, DOD officials also told us that the Navy plans to implement the existence and completeness results provided by an independent Public Accounting Firm. Further, it will continue to use OSD's validation and verification tool when providing annual data inputs to OSD's Real Property Assets Database, with any feedback to be addressed at senior Navy levels. However, DOD officials did not provide any documentation that these requirements had been put in place. Once we receive that documentation, we will review it to assess the extent to which it meets the intent of our recommendation.

Recommendation: The Secretary of the Air Force should require monitoring of its processes used for recording all required real property information--to include evaluating on an ongoing basis whether or to what extent these activities are being carried out--and remediating any identified deficiencies. (Recommendation 3)

Agency: Department of Defense: Department of the Air Force
Status: Open
Priority recommendation

Comments: The Air Force concurred with this recommendation. As of February 2020, DOD officials told us that the Air Force has required monitoring of its processes for recording all required real property information. For example, the Air Force plans to establish a Data Quality Program (DQP) within the Air Force Civil Engineer Center Information Technology Functional Management Office to incorporate requirements for improving accuracy of its asset information in its Accountable Property System of Record (APSR). The Air Force also plans to revise its instruction AFI 32-9005 to define responsibility for the accuracy of data at the lowest level. Further, it plans to require use of OSD's validation and verification tool to identify and correct inaccuracies when providing annual data inputs to OSD's Real Property Assets Database, with any feedback to be addressed at senior Air Force levels. However, DOD officials did not provide any documentation that these requirements had yet been put in place. We await documentation of these requirements and will review them, once received, to assess the extent to which they meet the intent of our recommendation.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense for Acquisition and Sustainment, in collaboration with the military services, defines and documents which data elements within the RPAD submissions are most significant for decision-making. (Recommendation 4)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation to define and document which data elements within its Real Property Assets Database (RPAD) submissions are most significant for decision-making. As of February 2020, DOD officials told us they will conduct a review of all data elements in its Real Property Assets Database, including compiling list of all data elements actively being used by data consumers. DOD also plans to divide required data elements into blocks to begin strenuous monitoring for accuracy. DOD's estimated completion date for these actions is September 2023. We will continue to monitor the completion of DOD's planned actions.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense for Acquisition and Sustainment, in collaboration with the military services, coordinates on corrective action plans to remediate discrepancies in significant data elements in its real property data system that are identified by OSD's verification and validation tool. (Recommendation 5)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation to coordinate on corrective action plans to remediate discrepancies in significant data elements in its real property data system that are identified by OSD's verification and validation tool. As of February 2020, DOD officials told us they plan to establish a senior leader Functional Governance Board to monitor accuracy compliance. DOD also plans to establish quarterly progress reports to be posted on the Data Analytics Integration Support (DAIS) application for constant monitoring by all users. DOD's estimated completion date for these actions is September 2022. We will continue to monitor the completion of DOD's planned actions.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense for Acquisition and Sustainment, in collaboration with the military services, develops a strategy that identifies and addresses risks to data quality and information accessibility. At a minimum, this strategy should establish time frames and performance metrics for addressing risks related to (1) unfilled real property positions, (2) a lack of a department-wide approach to improving its data, and (3) implementation of OSD's expanded data platform. (Recommendation 6)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD partially concurred with this recommendation and stated that it plans to collaborate with the military services on separate service strategies that reflect each military service's operating environment. As of February 2020, DOD officials told us they plan to stabilize their Data Analytics Integration Support (DAIS) platform to improve data inventory by ensuring successful network connectivity for all military service users. DOD will update policy guidance to formalize the use of the DAIS platform for inventory submission by the military services. DOD also will develop and formalize in policy benchmarks and metrics to monitor data accuracy. DOD's estimated completion date for these actions is September 2023. We will continue to monitor the completion of DOD's planned actions.

Recommendation: The Administrator of CMS should provide states with more information on how to fulfill the requirement for independent encounter data audits, including information on the required audit scope and methodology, and what should be described in the resulting report. (Recommendation 1)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: HHS agreed with our recommendation, noting that CMS would provide states with additional information on how to fulfill the requirement for independent encounter data audits. HHS also noted in January 2019 that CMS was developing voluntary guidance that will include information on best practices for validating encounter data. To implement this recommendation, the Administrator of CMS should inform states of the required audit scope and methodology as well as the resulting report. As of January 2020, HHS officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: The Administrator of CMS should provide states information on the required content of the annual assessment of encounter data reporting. (Recommendation 2)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: HHS agreed with our recommendation, noting that CMS would provide states further information on the required content of the annual assessment. In January 2019, HHS noted that CMS continues to develop guidance to states on how to fulfill the annual assessment requirement. As of January 2020, HHS officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: The Administrator of CMS should provide states with information on the circumstances under which CMS would defer or disallow matching funds in response to noncompliant encounter data submissions. (Recommendation 3)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: HHS neither agreed nor disagreed with our recommendation and noted steps it has already taken to remind states of their obligation to submit timely, quality encounter data, and prioritize data quality. In January 2019, HHS identified a possible step CMS could take in the event it finds deficiencies in states' encounter data reporting that cannot be resolved through informal monitoring and discussions with state Medicaid agencies. In particular, HHS noted that CMS would issue guidance on the parameters by which the agency would impose financial penalties on states for noncompliant encounter data submissions, if necessary. In February 2020, CMS officials told us that they continue to monitor state encounter data submissions and would issue guidance to states if they identify deficiencies in the data that cannot be resolved through informal monitoring and disccussions with state Medicaid agencies. To implement this recommendation, the Administrator of CMS should provide states with this information. We will update the status of this recommendation when we receive additional information.

Recommendation: The Secretary of Defense ensures that the Offices of the Under Secretary of Defense for Personnel and Readiness and Under Secretary of Defense for Acquisition and Sustainment in coordination with the Secretaries of the Army, Navy, and Air Force take interim steps to help ensure that standardized aviation mishap data elements are collected by the safety centers. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to a corrective action plan that DOD updated in July 2020, the department has taken some steps to implement this recommendation. According to the plan, DOD is developing standards for mishap data through the Safety and Information Management Working Group and is making progress towards finalizing mishap data element standards. DOD's internal tracking indicates that the draft business process model has been completed, but standardizing the DOD data elements is a work in-progress. DOD's estimated completion date for this effort is June 2021. Completing these actions would allow the military services' safety centers to collect relevant training-related data as part of the update of aviation mishap data elements, as GAO recommended in August 2018.

Recommendation: The Secretary of Defense ensures that the Offices of the Under Secretary of Defense for Personnel and Readiness and Under Secretary of Defense for Acquisition and Sustainment in coordination with the Secretaries of the Army, Navy, and Air Force update department-wide and service instructions and policies to clarify the responsibility of the Office of the Secretary of Defense for conducting analysis and its access to the military services' information on human factors that contributed to aviation mishaps. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to a corrective action plan that DOD updated in July 2020, the department has taken some steps to implement this recommendation. According to the plan, DOD is revising DOD Instruction 6055.07, which will clarify the department's policy that it is the responsibility of the Office of the Secretary of Defense for conducting analysis and its access to the military services' information on human factors that contributed to aviation mishaps. DOD's estimated completion date for this effort is July 2021. Completing this action would clarify the Office of the Secretary of Defense's role for conducting analyses and access to the military services' safety centers' data on aviation mishaps, as GAO recommended in August 2018.

Recommendation: The Secretary of Defense ensures that the DOD Chief Management Officer in coordination with the offices of the Under Secretary of Defense for Personnel and Readiness and Under Secretary of Defense for Acquisition and Sustainment and the Secretaries of the Army, Navy, and Air Force identify relevant training-related data to collect as part of any update of the aviation mishap data elements and incorporate these data into future analyses. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to a corrective action plan that DOD updated in July 2020, the department has taken some steps to implement this recommendation. According to the plan, DOD is developing standards for mishap data through the Safety and Information Management Working Group and is making progress towards finalizing mishap data element standards. DOD's internal tracking indicates that the draft business process model has been completed, but standardizing the DOD data elements is a work in-progress. DOD's estimated completion date for this effort is June 2021. Completing these actions would allow the military services' safety centers to collect relevant training-related data as part of the update of aviation mishap data elements, as GAO recommended in August 2018.

Recommendation: The Under Secretary of Defense for Personnel and Readiness should fully include in the new policy for sexual harassment the principles in the Centers for Disease Control's framework for sexual violence prevention, including risk and protective factors, risk domains, and tertiary strategies. (Recommendation 1)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: In written comments on the draft report, DOD concurred with this recommendation. In April 2020, officials with the Office of the Undersecretary of Defense for Personnel and Readiness stated that development of a new sexual harassment prevention strategy was complete and going through DOD's internal review process. The officials stated that the Undersecretary's review and approval of the assessment report will be complete before the end of the fiscal year, September 30, 2020. We will continue to monitor DOD's efforts and update the status of this recommendation as more information becomes available.

Recommendation: The Under Secretary of Defense for Personnel and Readiness should direct the Assistant Secretary of Defense for Readiness to incorporate in its continuum of harm prevention strategy all the elements that are key for establishing a long-term, results-oriented strategic planning framework. The elements are (1) a mission statement, (2) long-term goals, (3) strategies to achieve goals, (4) external factors that could affect goals, (5) use of metrics to gauge progress, and (6) evaluations of the plan to monitor goals and objectives. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: In written comments on the draft report, DOD concurred with this recommendation. According to officials with the Office of the Undersecretary of Defense for Personnel and Readiness, development of a new sexual harassment prevention strategy is complete and the strategy is going through DOD's internal review process. Additionally, a Defense Equal Opportunity Reform Group assessment report containing a review of the department's efforts to prevent sexual harassment was also submitted to the Undersecretary of Defense for Personnel and Readiness. The official's stated that the Undersecretary's review and approval of both the new strategy and assessment report should be completed by the end of the fiscal year, September 30, 2020. We will continue to monitor DOD's efforts to address this recommendation and will update its status when more information becomes available.

Recommendation: The Administrator of CMS, in partnership with the states, should take additional steps to expedite the use of T-MSIS data for program oversight. Such steps should include, but are not limited to, efforts to (1) obtain complete information from all states on unreported T-MSISdata elements and their plans to report applicable data elements; (2) identify and share information across states on known T-MSIS datalimitations to improve data comparability; and (3) implement mechanisms, such as the Learning Collaborative, by whichstates can collaborate on an ongoing basis to improve thecompleteness, comparability, and utility of T-MSIS data.(Recommendation 1)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open
Priority recommendation

Comments: HHS concurred with this recommendation. As of February 2020, CMS has taken steps to improve T-MSIS data quality, but further efforts are needed to expedite the data's use in oversight. With regard to obtaining complete information from all states, CMS released additional guidance in March 2019, on state compliance with T-MSIS requirements. This guidance includes the need to resolve data issues associated with 12 top priority items and missing data elements, both of which are key for using T-MSIS data. Further, CMS identified an additional 11 top priority items, noting it also expected states to resolve data issues with these items. CMS reports that it has helped resolve data issues related to these 23 top priority items by sending states summary data on compliance with associated reporting requirements. CMS has notified states of their compliance status and asked non-compliant states to submit corrective action plans. However, CMS reports that the level of states' T-MSIS data completeness varies and agency state liaisons and technical assistants continue to work individually with states to identify, prioritize, and resolve key missing data elements. With regard to identifying and sharing information, CMS has made some T-MSIS data available for use through five T-MSIS analytical files, which include data on Medicaid and CHIP enrollment, demographics, service utilization, and payments. Further, CMS has created resources to support researchers in their use of these analytical files, including information on the completeness and accuracy of certain data elements. With regard to implementing mechanisms for collaboration across states, additional CMS action is needed. In particular, CMS's efforts to create a mechanism for states to disseminate information about T-MSIS data and its comparability across states remain limited and the agency has not launched its proposed Learning Collaborative to facilitate ongoing feedback and collaboration. While progress has been made, additional actions, such as establishing mechanisms for ongoing feedback and collaboration across states, are needed to consider this recommendation implemented.

Recommendation: The Administrator of CMS should articulate a specific plan and associated time frames for using T-MSIS data for oversight. (Recommendation 2)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: HHS concurred with this recommendation. As of February 2020, CMS has taken steps to articulate guidance to states, but has not outlined a specific plan and associated time frames for using T-MSIS data for oversight. Until CMS takes these actions, the recommendation remains open.

Recommendation: The Director of OMB should continue to provide ongoing technical assistance that significantly contributes to agencies making their own determinations about their DATA Act reporting requirements and monitor agency submissions. (Recommendation 1)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open
Priority recommendation

Comments: OMB stated in January 2020 that it believes that the assistance it has previously provided to help agencies make their own reporting determinations fulfills the recommendation's intent. However, because we continue to identify instances where agencies had not submitted these data, we continue to believe that OMB needs to follow up with agencies that are not submitting quarterly data to find out why they are not reporting. It also needs to update its list of agencies required to report.

Recommendation: The Director of OMB should clarify and align existing guidance regarding the appropriate definitions agencies should use to collect and report on Primary Place of Performance and establish monitoring mechanisms to foster consistent application and compliance. (Recommendation 2)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open
Priority recommendation

Comments: OMB has issued or contributed to guidance documents that are intended to help agencies collect and report on "Primary Place of Performance." We believe that providing specific examples of how agencies should approach challenging situations when reporting on this data element for grants would provide further clarity.

Recommendation: The Secretary of the Treasury should reasonably assure that ongoing monitoring controls to help ensure the completeness and accuracy of agency submissions are designed, implemented, and operating as designed. (Recommendation 4)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: In September 2019, Treasury officials stated that they are working to formalize a process for monitoring agency submissions. This process will include (1) emailing agencies prior to submission deadlines to remind them of the approaching submission deadlines; (2) following up with agencies that do not submit required data by the submission deadline and offering technical assistance as needed; and (3) forwarding a list of non-compliant agencies to OMB. GAO will continue to monitor Treasury's efforts to establish monitoring controls to help ensure the completeness and accuracy of the data.

Recommendation: The Secretary of the Treasury should disclose known data quality issues and limitations on the new USAspending.gov. (Recommendation 5)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of January 2020, Treasury has made progress by disclosing limitations related to unreported spending, among other things. Treasury is planning a major update to the USAspending.gov website to include more information about known data quality issues. Treasury plans to make this update to the website in the coming months and has an internal target date of June 2020 for completion. When completed, this action will help users make more informed decisions about how to interpret and use the data provided on the website.

Recommendation: To make it more likely that HHS will achieve its goals to reduce quality measure misalignment and associated provider burden, the Secretary of HHS should direct CMS and the Office of the National Coordinator for Health Information Technology to prioritize their development of electronic quality measures and associated standardized data elements on the specific quality measures needed for the core measure sets that CMS and private payers have agreed to use.

Agency: Department of Health and Human Services
Status: Open

Comments: In January 2019, HHS told us that CMS completed an analysis to determine which measures-from the core measure sets that CMS and private payers have agreed to use-are feasible to develop as electronic clinical quality measures. Further, in April 2019, CMS officials told us they will consider developing new electronic clinical quality measures where appropriate and feasible to fill future measure needs or gaps identified by the Core Quality Measures Collaborative (CQMC). However, we determined that the actions did not fully address the recommendation because they do not include efforts to work with ONC to prioritize their development of electronic clinical quality measures for the CQMC core measure sets. We will update the status of this recommendation when we receive additional information.

Recommendation: To make it more likely that HHS will achieve its goals to reduce quality measure misalignment and associated provider burden, the Secretary of HHS should direct CMS to comprehensively plan, including setting timelines, for how to target its development of new, more meaningful quality measures on those that will promote greater alignment, especially measures to strengthen the core measure sets that CMS and private payers have agreed to use.

Agency: Department of Health and Human Services
Status: Open

Comments: In April 2019, HHS told us that CMS had conducted an assessment of the impact of selected measures used in its quality programs and has linked key component of that assessment to some meaningful measure areas that CMS has identified as priorities. However, this document did not include elements of a comprehensive plan--such as setting timelines-for how to target its development of new, more meaningful quality measures that will promote greater alignment. We will update the status of this recommendation when we receive additional information.

Recommendation: To ensure that MA encounter data are of sufficient quality for their intended purposes, the Administrator of CMS should establish specific plans and time frames for using the data for all intended purposes in addition to risk adjusting payments to MAOs.

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open
Priority recommendation

Comments: HHS generally agreed with this recommendation. Although CMS reports using MA encounter data for purposes other than risk adjustment, as of February 2020, it has not fully developed specific plans and time frames with dates for all uses. CMS reports that it has begun testing the use of MA encounter data for public health purposes, such as identifying beneficiaries with a history of opioid-related overdose and with other conditions, such as cancer and sickle cell. Further, CMS uses MA encounter data to help identify beneficiaries at risk in areas affected by public health emergencies. CMS reports that its Office of the Actuary (OACT) has used MA encounter data to analyze MA beneficiary utilization of certain Part B drugs. Further, OACT reports that it intends to assess other areas where it could use MA encounter data, such as analyses comparing Medicare fee-for-service and MA. As of February 2020, the agency has not developed specific plans and time frames for this and other intended purposes. For example, although CMS intends to use MA encounter data for program integrity purposes, it has not yet developed specific plans and time frames to do so. We will continue to monitor CMS's progress in developing specific plans and time frames with dates for all intended purposes of MA encounter data.

Recommendation: To ensure that MA encounter data are of sufficient quality for their intended purposes, the Administrator of CMS should complete all the steps necessary to validate the data, including performing statistical analyses, reviewing medical records, and providing MAOs with summary reports on CMS's findings, before using the data to risk adjust payments or for other intended purposes.

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open
Priority recommendation

Comments: HHS generally agreed with this recommendation, however, HHS did not commit to completing data validation before using MA encounter data for risk adjustment. As of February 2020, CMS has continued to make progress in examining the completeness and accuracy of MA encounter data, but more work remains to fully validate these data. CMS has developed and is implementing an MA Encounter Data Integrity and Monitoring plan, which includes data analysis, guidance, and monitoring. As part of this plan, CMS has established preliminary performance metrics for MA encounter data completeness and accuracy. CMS is also conducting analyses related to accuracy and completeness, but has not established performance benchmarks for these analyses. While the agency plans to communicate findings from the analyses to Medicare Advantage organizations, it has not yet done so. Finally, CMS has not verified MA Encounter data by reviewing medical records. While these steps are encouraging, without fully validating the completeness and accuracy of MA encounter data, CMS would be unable to confidently use these data for risk adjustment or other program management or policy purposes.