Office of Inspector General

We are often asked if we have the Medicare Exclusion Database (MED) in our system. We do not collect the MED directly from CMS, but we do have this data in our system. The reason for this is because we collect our data from the primary source, as the Office of Inspector General is the primary source, we do not see a need to collect this data from the CMS as well.

We are precise in our collection. We believe in quality over quantity here at Typhoon Data. We don’t see a need in collecting “Everything”. Instead, we collect the pertinent, actionable, and primary source records that can help you and your clients get a full and complete picture on your health care providers. We take pride in our knowledge of these sources.

Last week, we got official and final confirmation that collecting the MED is not necessary.

Exact verbiage from CMS in regards to the MED:

“The Medicare Exclusion Database (MED) is a national database populated with information from the Office of the Inspector General.”

a threatened penalty for disobeying a law or rule.
“a range of sanctions aimed at deterring insider abuse”

Sanction is a term that is often used when referring to databases like ours. I’m often asked “do you have a sanction database?” or “is this a sanction check?”

We do have sanctions in our dataset. For example, Office of Foreign Assets Control (OFAC) has many lists of sanctioned individuals.

However, it’s a common misconception that an entire dataset like ours is a Sanction Database or Sanction search. Sanctions usually refer to Financial Sanctions. Financial Sanctions are restrictive measures imposed on individuals or entities in an effort to curtail their activities and to exert pressure and influence on them.

Our focus at Typhoon Data is to assemble a data set of all Federal and State Exclusions and Board Disciplinary Actions. Many organizations publish critical information for our customers, and we gather all of it, including Opt out affidavits, abuse registries, and imposter lists.

Federal and State Exclusions are Individuals and Entities that are excluded from participation in Medicare, Medicaid and other federal and state healthcare programs.

Termination occurs when the Medicare program, a State Medicaid program, or CHIP has taken an action to revoke a provider’s billing privileges, a provider has exhausted all applicable appeal rights or the timeline for appeal has expired, and there is no expectation on the part of a provider or supplier or the Medicare program, State Medicaid program, or CHIP that the revocation is temporary.

Disciplinary Actions (aka Board Actions) is the language used to describe the types of actions that occur at a board level. These can be minor, like a fine or civil penalty. Or they can be major, like a revocation or suspension of a medical license.

The difference between these? Though these both are targeted to the medical world, Disciplinary Actions cannot occur unless you are licensed, or attempting to become licensed. However, anyone can become excluded. Many times, a severe enough action will result in an exclusion, however this is not always the case.

Our dataset has much more than just these sources. We have a myriad of sources that are going to help give you the complete picture on your provider. We include Medicare Opt-Out’s, Abuse Registries, License Conditions, Imposter Alerts, Federal and State Actions, Press Releases, etc. Often times all of these different types of data fall into one category. Sanctions.

It would appear that the term “sanction” has been adopted to include any or all of the possible actions taken by the Federal government, state governments, or boards. As has been noted the terminology used by the many reporting entities varies greatly including;
Board Action
Medicare Opt-Out
Abuse Registries
License Condition
Imposter List
Federal and State Action
Press Release

That’s why, when asked if we have a sanction dataset, I’m always careful to ask follow-up questions about what specific sources the customer might want or need. If my customer is unsure of what exactly they need, we try to always stay up to date on the compliance regulations so we can offer them exactly what they need to meet the standards.

Medicaid Fraud

The Medicaid Fraud Control Units report was just released. Here are a few highlights:

  1. 1,564 convictions (slightly up from 1,557 the year before).
  2. Almost $1.9 billion in recoveries. The total cost of recovery was “$259 million in State and Federal Funds” making it “an average of over $7 for every dollar spent.”
  3. The provider type with the most convictions was “PCS Attendant, PCS Agency, or other Home Care Aide” with 552.
    1. The next provider type was “Nurse (LPN, RN, or other licensed), PA, or NP) with 171.
    2. “Nurse Aid” came after that with 153.
    3. Followed by “Family Practice Physician” with 57.
    4. And coming in last was “Home Health Agency” with 48.  
  4. 74% of the convictions involved fraud, 26% involved abuse or neglect.
  5. Pharmaceutical manufacturers accounted for “almost half of the civil settlements and judgments.”
  6. There were 998 civil settlements/judgments, the highest number in the last five years.

That sums up the most interesting data from this year’s report. The one that stands out the most to me is that pharmaceutical manufacturers accounted for “almost half of the civil settlements and judgments.” The report provides some insight:

Pharmaceutical manufacturer settlements typically relate to the marketing of prescription drugs. An additional 70 settlements and judgments involved laboratories, 67 involved medical device manufacturers, and 57 involved retail and wholesale pharmacies.  

The context is helpful, especially knowing that most of the settlements/judgments were because of marketing related issues. As always, if you have specific questions about compliance, data availability, the nuances of a particular source, or the best place to find the data you’re looking for, please don’t hesitate to reach out to me directly at or to call me at 800-780-5901, Extension 103.