This seems incredibly backwards. The actions of healthcare providers should not need to rise to the level of legally provable fraud before insurance companies have the
option of reporting them. We should be requiring the insurance companies to provide a constant stream of usable statistical data covering ALL providers to regulators/law enforcement who should in turn be free to investigate anything that looks suspicious to
them (the same way they would with a driver weaving in his lane or a congressman flashing around a suitcase full of money).
Furthermore: Healthcare providers operating in sectors with low barriers to entry should be constantly subject to random audit/inspection regardless of their stats. Do we wait for a customer to report glass in their food before we inspect a restaurant?