Why is CMS presenting gross error rates rather than net error rates?
A6. In order to promote consistency in improper payment reporting across federal agencies, Improper Payments Information Act (IPIA) requires agencies to follow a number of methodological requirements when calculating error rates and improper payment estimates. IPIA mandates that agencies use gross figures when reporting improper payment amounts and rates. In the past, the OIG and CMS reported Medicare FFS error rates and improper payment estimates using net figures. A gross improper payment amount is calculated by adding underpayments to overpayments. A net improper payment amount is calculated by subtracting underpayments from overpayments. All of the numbers repored in the November 2005 report are gross. Q7. Why can’t some of the improper payments from the 2005 report be compared to the 2004 report? A7. In previous reports the CERT program and the HPMP calculated improper payment estimates in a slightly different manner. Unlike HPMP, the CERT program did not exclude coinsurance and d