SNF, hospice, HHA, hospital owners on federal exclusion lists (Stage B: NPI-keyed + facility-state demographic)
Highest-stakes finding for vulnerable populations — the CMS Disclosure of Ownership IFR (2023) expanded ownership transparency precisely to surface concerning ownership structures. **Stage B result: 0 CONFIRMED-NPI matches and 1,779 CANDIDATE-DEMOGRAPHIC matches between owners in the four CMS Quarterly All Owners files (SNF + Hospice + HHA + Hospital) and federal exclusion lists (OIG LEIE + SAM.gov, active).** Tier 1 NPI-keyed match resolves owner ASSOCIATE_ID → NPI via the CMS PPEF (Public Provider Enrollment File, 2.47M individual NPIs) and returns 0 because exclusion forces revocation of Medicare enrollment — only 25 of 8,619 LEIE∪SAM-active NPIs are still in PPEF, and none are listed as owners. The null is itself evidence that CMS's exclusion-revocation pipeline is working for the active cohort. Tier 2 demographic match uses (LAST, FIRST, FACILITY_STATE) — facility state stands in for owner state, which the All Owners files do not populate for individuals. 17 of the 1,779 candidate matches are VA-state facilities. **Methodology #2 fix vs v1**: v1 joined on owner STATE which is 100% empty for individual owners in the source files — that v1 "0 demographic matches" result was a structural null, not a true zero.
Headline
AINPI identifies 1779 CANDIDATE-DEMOGRAPHIC matches and 0 CONFIRMED-NPI matches between owners of Medicare-enrolled SNFs, hospices, home health agencies, and hospitals (CMS All Owners 2026-04-01) and OIG LEIE active exclusions. Tier 1 (NPI-keyed) returns 0 because exclusion forces Medicare revocation — only 25 of 8,619 LEIE∪SAM-active NPIs are still in the CMS PPEF cross-walk, and none of those 25 are listed as owners. Tier 2 ((LAST, FIRST, FACILITY_STATE) demographic match) surfaces 1779 candidate rows: 17 are VA-state facilities. Skilled Nursing Facilities: 0 confirmed / 716 candidate; Hospices: 0 confirmed / 226 candidate; Home Health Agencies: 0 confirmed / 322 candidate; Hospitals: 0 confirmed / 515 candidate. Every candidate row must be verified against the LEIE portal before any state survey agency action.
unit: count
Null hypothesis
Zero owners listed in the CMS SNF / Hospice / HHA / Hospital All Owners files (2026-04-01) resolve to an NPI on OIG LEIE active or SAM.gov active. Secondary: zero owners under a (LAST, FIRST, FACILITY_STATE) demographic match against LEIE.
Denominator
444,106 individual-owner rows across SNF (185,329) + Hospice (53,536) + HHA (80,208) + Hospital (125,033) in the 2026-04-01 release. PPEF cross-walk covers 2.47M individual NPIs; LEIE NPI-populated = 8,608; SAM-active with NPI = 4,707; LEIE demographic keys (LAST, FIRST, STATE) = 78,688. Tier 1 ceiling is bounded by the 25 LEIE∪SAM-active NPIs still in PPEF — most excluded providers are revoked and therefore not in PPEF.
Data source
CMS Quarterly All Owners files × CMS Medicare Fee-For-Service Public Provider Enrollment File (PPEF, 2026-04-01, 2.98M rows) × OIG LEIE active × SAM.gov active. Tier 1: ASSOCIATE ID - OWNER → PECOS_ASCT_CNTL_ID → NPI → check against LEIE.NPI ∪ SAM.npi. Tier 2: (LAST, FIRST, FACILITY_STATE) demographic match against LEIE, with facility state resolved via PPEF ENRLMT_ID (100% lookup hit). See `analysis/claims_sources/nh_compare_ownership.py`.
Notes
Stage B methodology (0.6.1-draft) introduces NPI-keyed matching via the CMS PPEF (Medicare Fee-For-Service Public Provider Enrollment File, 2026-04-01). PPEF publishes NPI ↔ PECOS_ASCT_CNTL_ID for 2.47M individual NPIs; the All Owners files publish ASSOCIATE ID - OWNER (same identifier space) for every individual-owner record. Two source-data-shape facts drive the tier design: (1) CMS does NOT populate STATE - OWNER for individuals (100% empty in the 2026-04-01 release) — the v1 demographic match joined on this empty field and therefore produced a structural-null result. Stage B substitutes the facility's STATE_CD (resolved via PPEF ENRLMT_ID, 100% lookup hit). (2) Exclusion under 42 USC § 1320a-7 forces revocation of Medicare enrollment, so most excluded NPIs are not in PPEF (25 of 8,619 LEIE∪SAM-active NPIs remain in PPEF — likely recent exclusions not yet processed out). Tier 1 is therefore inherently small-N; the null is itself evidence that CMS's exclusion-revocation pipeline is working. Per-state CSV at /api/v1/states/va/h35-nh-ownership-flags.csv carries both tiers with match_tier column.