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Comprehensive Medicaid Integrity Plan (CMIP)
Source: Admin


The Centers for Medicare & Medicaid Service (CMS) launched the Medicaid Integrity Program (MIP) to increase the resources available to CMS to combat fraud, waste and abuse in the Medicaid program. The Medicaid Integrity Program was established in section 1936 of the Social Security Act (the Act) (Public Law 109-171) by Section 6034 of the Deficit Reduction Act of 2005 (DRA).

The Act has a requirement that CMS reviews and updates the plan on an annual basis.


The main purpose of the plan is to

  • Review provider actions
  • Audit claims
  • Identify overpayments
  • Educate providers, managed care entities, beneficiaries and others with respect to payment integrity and quality of care

Responsibilities of CMS

  • Review actions Medicaid providers, audit claims, identify overpayments, and educate providers and others on Medicaid program integrity issues
  • Provide effective support and assistance to States to combat Medicaid provider fraud and abuse

Statutory Requirements

Comprehensive Planning

·         DRA requirement:  “a comprehensive plan for ensuring the integrity of the program established under this title by combating fraud, waste, and abuse.”

·         CMS to consult with several entities to develop CMIP

Report to Congress

·         Annual report to Congress:

­         on the use of the funds

­         include information on the effectiveness of the use of those funds

Medicaid Integrity Contractors

·         Use contractors for four specific functions:

­         review actions of those seeking payment from State Medicaid plans

­         audit of those claims

­         identification of overpayments related to those claims

­         education of providers

­         and others with respect to payment integrity and quality of care

Support & Assistance to the States

·         Must employ 100 full-time equivalent employees “whose duties consist solely of protecting the integrity of the Medicaid program established under this section by providing effective support and assistance to States to combat provider fraud and abuse.”

State Cooperation

·         DRA requirements: States “must comply with any requirements determined by the Secretary to be necessary for carrying out the Medicaid Integrity Program established under Section 1936 [of the Social Security Act].”

OIG & Medi-Medi Funding

·         Section 6034 of the DRA, the Office of Inspector General and the Office of Financial Management’s (OFM) Program Integrity Group received enhanced funding (separate and apart from the Medicaid Integrity Program allocation) for Medicaid fraud efforts.

·         Additional funds for a national expansion of the Medi-Medi pilot project.


  • Suspending payments to suspect providers while simultaneously seeking recovery of identified overpayments
  • Provider may be subject to sanctions or penalties, which may include revocation of the provider’s agreement to participate in the Medical Assistance Program.



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