Minnesota provider directory audit
State-scoped view of the AINPI audit of the CMS National Provider Directory.
NPD release 2026-05-08 · methodology v0.2.0 · commit bebebde
Eugene Vestel — Founder, FHIR IQ · Health interoperability consultant
BioLinkedIngene@fhiriq.com· Last reviewed 2026-05-09
Why this page exists
On 2026-04-23 the Centers for Medicare & Medicaid Services issued a letter to all 50 State Medicaid Directors requesting a comprehensive two-year provider revalidation strategy within 30 days, citing 42 CFR §§ 431.107, 455.410, 455.414, 455.416, 455.21, and 455.450. The letter explicitly asks for “links to any public-facing data or reporting” that demonstrate ongoing verification of provider enrollment data. This page is one such artifact: a state-scoped, reproducible, source-cited slice of an independent audit of the federal NDH bulk export. Your state agency is welcome to cite it directly in its CMS response. See /methodology for the full versioned methodology and audit trail.
Minnesota: state slice published, program brief pending.
The NPD-derived data quality numbers below are computed for Minnesota. The Medicaid program / agency / MCO context block is populated for the states AINPI has briefed directly (VA, PA, OH today). To request a briefing for Minnesota, open an issue at github.com/FHIR-IQ/AINPI/issues.
NDH resources tied to Minnesota
Counts of resources where the FHIR resource's service-address state equals MN. These are the state-level denominators against which the findings below are computed.
- Practitioner
- 124,983
- Organization
- 47,957
- Location
- 20,287
Findings, Minnesota vs national
Each row links to the published national finding for full methodology, null hypothesis, and audience implications.
| Finding | Hypotheses | MN rate | National |
|---|---|---|---|
| NPI and taxonomy correctness 123,656 of 124,983 MN practitioner NPIs (98.9383%) match NPPES; 3,047 are flagged deactivated in NPPES while still active in the federal NDH. | H9, H10, H11, H12, H13 | 98.94% | — |
| Duplicate detection MN has 47,957 Organization resources covering 29,385 unique NPIs — 18,572 excess resources (38.7264%) appear duplicated. | H14, H15 | 38.73% | 13.55% |
| Temporal staleness 0 of 193,227 MN-resident resources carry a meta.lastUpdated on the 2026-05-08 release day. As at the national level, meta.lastUpdated is a release-time stamp; state-scoping does not change this finding. | H18 | 0.00% | 0.00% |
| Endpoint liveness Not state-computable: FHIR Endpoints in NDH do not carry a state field. State scoping requires joining Endpoint.managingOrganization to Organization._state. Approximately 97% of NDH Endpoints have no populated managingOrganization back-reference (see /findings/referential-integrity), so a state-scoped endpoint-liveness number would only cover the 3% with a resolvable back-reference. The national rate is the defensible reference. | H1, H2, H3, H4, H5 | n/a | 85.37% |
| Referential integrity Not state-computable: Cross-resource references in NDH are graph-level. State filtering on the source side (PractitionerRole.practitioner) is straightforward, but the target side (Organization, Location) may be in a different state, so a per-state integrity rate conflates two distinct populations. The national rate is the defensible reference. | H6, H7, H8 | n/a | 0.00% |
| Network adequacy gauge Not state-computable: Same constraint as endpoint-liveness: FHIR Endpoints lack a state field, and the indirect join via managingOrganization covers only ~3% of Endpoints. The 85% Medicare Advantage network-adequacy implied ceiling is itself a national reference, so a state-scoped recomputation here would not be meaningful for state Medicaid PR strategy. | H22 | n/a | 90.35% |
Verify a sample yourself
The records below are concrete NPIs that AINPI flagged on this state's population. Each row links to the authoritative public NPPES NPI Registry so you can independently confirm the flag. Disagreement on any record can be filed as a data quality bug with a reproducible counter-example.
| NPI | Display name | Flag | Reason | Verify |
|---|---|---|---|---|
| 1649127812 | WHEELER, KRAIG | npi-taxonomy-correctness | Not present in NPPES npi_raw | NPPES → |
| 1174478184 | TOTZKE, JUDY | npi-taxonomy-correctness | Not present in NPPES npi_raw | NPPES → |
| 1104774629 | LADD, NAOMI | npi-taxonomy-correctness | Not present in NPPES npi_raw | NPPES → |
| 1275480451 | THEOPHILOS, AMENTI | npi-taxonomy-correctness | Not present in NPPES npi_raw | NPPES → |
| 1770437097 | MARSH, TONIA | npi-taxonomy-correctness | Not present in NPPES npi_raw | NPPES → |
How to cite this page in your CMS PR strategy response
CMS's 2026-04-23 letter requests, in element 2: “The metrics you will use to measure the effectiveness and progress of your PR strategy, including links to any public-facing data or reporting.” Suggested citation language:
We have adopted the AINPI methodology framework (Vestel, FHIR IQ, v0.2.0) for ongoing verification of Minnesota provider-directory data against the federal CMS National Provider Directory and NPPES. State-scoped findings are published at https://ainpi.dev/states/mn, with a versioned methodology and reproducible analysis code under Apache-2.0.See CITATION.cff for a Zotero / EndNote-importable form. Pin to a specific release tag for academic reproducibility.
Methodology lineage
- NDH source
- CMS National Provider Directory, release 2026-05-08
- NPPES snapshot
bigquery-public-data.nppes.npi_raw, dated 2026-02-09- NUCC taxonomy
- v17.0, January 2026 release
- CMS Medicare/NUCC crosswalk
- October 2025 release
- Methodology version
- 0.2.0
- Generated
- 2026-05-09T00:21:13+00:00
What this audit does NOT cover
- Non-NPI providers. AINPI is NPI-keyed end-to-end. Atypical providers (e.g. personal-care assistants in some state programs) are out of scope. CMS's 2026-04-23 letter specifically calls these out as a population to address; a complementary state-roster join is required.
- CAQH credentialing data. Not in the NDH ingestion pipeline. See /insights for the full provenance discussion.
- Real-time attestation logs. NPD bulk files are periodic exports (current pinned release: 2026-05-08).
- Managed care plan internal directories. AINPI measures the federal NDH artifact only. Live MCO directory parity against the state FFS roster is a separate effort.
- Beneficiary or claims data. AINPI is provider-directory only. Nothing here implicates utilization, quality, or fraud evidence on individual providers.
Correction protocol
If you can demonstrate that any number on this page is wrong with a reproducible counter-example, file a data quality bug issue on GitHub. Confirmed corrections trigger a methodology version bump, an entry in the changelog, and a re-run of the affected JSON. The history is auditable in the public Git log.