Medicare Program Integrity Manual (Pub. 100-08), Ch. 7 § 7.3.2.3
Prioritized Problem List
7.3.2.3 - Prioritized Problem List
(Rev. 599, Issued: 06-26-15, Effective: 12-07-15, Implementation: 12-07-15)
The SAR requires the MAC to assess their prioritized IPRS problem list and report on
that assessment to date. The SAR shall summarize the MR activities, improper payment
interventions, and MR activities taken to address each of the identified prioritized
problems in the MAC’s IPRS.
This section shall include details on both prioritized problems that were contained in the
IPRS, in addition to newly identified problems. Units or measurements used to quantify
baseline problem measurements, improvement goals, and the achievement or non-
achievement of the improvement goals shall be consistent throughout the SAR and IPRS.
For each specific prioritized problem on the IPRS problem list, the MAC shall provide
the following information:
A. Prioritized problem description.
Each prioritized problem on the problem list shall include a problem description. This
section shall contain a brief description of problem characteristics and associated planned
MR activities and improper payment interventions. The MAC shall include information
regarding how the problem was identified (i.e., CERT, Recovery Auditor, CMS, OIG,
Comparative Billing Report (CBR), MAC internal data analysis, GAO, etc.)
Duplication of the details contained in the IPRS is not needed; rather, the MAC may refer
the reader to the previous IPRS for detailed descriptions, as required. The reader should
easily see that the problems already identified and defined in the IPRS correspond to the
SAR’s listing of numbered problems.
The MAC shall also provide the problem identification number or case number (if used)
that is not the ranking number of the prioritized problem. This number shall be consistent
in the IPRS and the SAR.
B. Whether the prioritized problem is a new or carry-over problem from the IPRS.
The MAC shall report on both the problems that were identified in the IPRS as well as
problems that have been added to the IPRS prioritized list as a result of data analysis.
Any prioritized problem removed since the last IPRS shall be explained.
For problems that have been newly identified and added to the SAR subsequent to the
IPRS submission, a detailed narrative is appropriate.