FPS2

To Whom It May Concern:

Pursuant to the Freedom of Information Act, I hereby request the following records:

According to the the CMS Website, in 2011, the Centers for Medicare & Medicaid Services (“CMS”) developed and implemented the Fraud Prevention System (“FPS”), now FPS2, to implement predictive analytics technologies to identify and prevent the payment of fraudulent claims in the Medicare Fee-for-Service Program. The FPS 2 develops models to identify fraud waste and abuse and monitor the models to validate effective alerting.

I am seeking:

1) Contracts, memorandums of understanding, and statements of work between the department and any outside party regarding the implementation and development of FPS2 of any service to detect or predict fraud

2) Documentation of FPS 2 or predictive models that the agency currently uses (including those used as aids to human decision making). This documentation should include, where available: executive summaries of the algorithm/model's purpose, lists of the data sources, breakdowns of how the model weights various input data, descriptions of the statistical or machine learning techniques employed, the results of validation and accuracy testing, disparate impact studies, and algorithmic impact reports.

3) A data dictionary/library for each predictive or detection model or algorithm identified in response to items 1 and 2 of this requests.

4) Copies of any internal or independent audits of the identified models or algorithms.

5) Aggregate or disaggregated data, if any exists, breaking down the risk scores or outputs of the fraud model.

6) Training data code and model files for the above algorithms.

As required under FOIA, I request that the agency provide the above records in their native digital format, where applicable (such as a CSV, Excel, or other digital data format), and transferred to me electronically.

News media status and fee waiver:

As a reporter for WIRED, I qualify as a news media requester for the purpose of fees. See 5 U.S.C. 552(a)(4)(A)(ii). Further, because this request is being made for a journalistic purpose regarding a matter of public interest, I further ask that you waive any fees. See 5 U.S.C. § 552(a)(4)(A)(iii). Disclosure of information regarding the use of predictive analytics will contribute significantly to public understanding of how CMS uses advanced machine learning technology. This request is not primarily in the commercial interest of myself or WIRED.

Additionally, please notify me of costs before taking any billable steps.

Segregability:

If you deny this request in whole or in part, I request that you respond with the statutory
exemption underlying the denial and the reasoning therein. If an asserted exemption applies to
only a portion of a record, please delete or redact the portion to which the exemption applies and
provide the remainder of the record, as required under the FOIA.

If you have any questions about my request, please do not hesitate to e-mail me or call
me. Conde Nast's legal counsel is also copied on this letter. We look forward to a response as quickly as possible under the provisions of the Freedom of Information
Act (5 U.S.C. Section 552).

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 20 business days, as the statute requires.

Sincerely,

Dhruv Mehrotra