Department of Health and Human Services 
OFFICE OF 
 
INSPECTOR GENERAL 
 
 
 
 
 
 
 
A S M
R IZONA  TATE  EDICAID 
 
F C U : 
  RAUD  ONTROL  NIT   
 
2015 O R  
  NSITE  EVIEW 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
Suzanne Murrin  
 
Deputy Inspector General  
for Evaluation and Inspections  
 
December 2015 
OEI-07-15-00280   
   
EXECUTIVE SUMMARY:  ARIZONA STATE MEDICAID FRAUD CONTROL  
UNIT:  2015 ONSITE REVIEW  
OEI-07-15-00280 
 
WHY WE DID THIS STUDY 
The Office of Inspector General (OIG) administers the Medicaid Fraud Control Unit 
(MFCU or Unit) grant awards, annually recertifies the Units, and oversees the Units 
performance in accordance with the requirements of the grant.  As part of this oversight, 
OIG conducts periodic reviews of all Units and prepares public reports based on these 
reviews. These reviews assess Unit performance in accordance with the 12 MFCU 
performance standards and Unit compliance with applicable Federal requirements. 
 
HOW WE DID THIS STUDY  
We conducted an onsite review of the Arizona Unit in July 2015.  We based our review 
on analysis of data from seven sources:  (1) a review of policies, procedures, and 
documentation related to the Units operations, staffing, and caseload for fiscal years 
(FYs) 2012 through 2014; (2) a review of financial documentation for FYs 2012 through 
2014; (3) structured interviews with key stakeholders; (4) a survey of Unit staff; 
(5) structured interviews with the Units management; (6) an onsite review of files for 
cases that were open in FYs 2012 through 2014; and (7) an onsite observation of Unit 
operations. 
 
WHAT WE FOUND 
The Unit was in general compliance with applicable laws, regulations, and policy 
transmittals; however, we identified one area for improvement.  For FYs 2012 through 
2014, the Arizona Unit reported 185 criminal convictions and combined criminal and 
civil recoveries of $4 million.  We found that almost all case files contained 
documentation of supervisory approval to open and close cases as well as of periodic 
supervisory reviews. In addition, we noted that the Unit collaborates with external 
stakeholders and educates the community to generate referrals.  However, the Unit did 
not report all convictions and adverse actions to Federal partners within required 
timeframes.  Subsequent to the period of our review, the Unit implemented processes to  
ensure future timely reporting. 
 
WHAT WE RECOMMEND   
We recommend that the Arizona Unit update its policies and procedures manual to 
include the Units new processes for reporting convictions and adverse actions to Federal 
partners within required timeframes.  The Unit concurred with our recommendation. 
   
   
TABLE OF CONTENTS 
Objective......................................................................................................1 

Background..................................................................................................1 

Methodology................................................................................................4 

Findings........................................................................................................5 

For FYs 2012 through 2014, the Arizona Unit reported  

185 criminal convictions and combined criminal and civil 

recoveries of $4 million  ...................................................................5 

Almost all case files contained documentation of supervisory 

approval to open and close cases as well as of periodic supervisory 

review ...............................................................................................6 

The Unit did not report all convictions and adverse actions to 

Federal partners within required timeframes; however, the Unit has 

subsequently implemented processes to ensure future timely 

reporting...........................................................................................7 

Other observation:   The Unit collaborates with external
  
stakeholders and educates the community to generate referrals ......8 

Conclusion and Recommendation .............................................................10 

Unit Comments and Office of Inspector General Response ..........11
  
Appendixes ................................................................................................12 

A: 2012 Performance Standards ...................................................12 

B: Arizona State Medicaid Fraud Control Unit Referrals by 

Referral Source for FYs 2012 Through 2014 ................................16 

C: Investigations Opened and Closed By Provider Category 

for FYs 2012 Through 2014 ..........................................................17 

D: Detailed Methodology .............................................................19 

E: Point Estimates and 95-Percent Confidence Intervals Based 

on Reviews of Case Files...............................................................23 

F: Unit Comments.........................................................................24 

Acknowledgments......................................................................................26 

 
   
OBJECTIVE 
To conduct an onsite review of the Arizona State Medicaid Fraud 
Control Unit (MFCU or Unit). 
BACKGROUND 
The mission of State MFCUs is to investigate and prosecute 
Medicaid provider fraud and patient abuse and neglect under State 
law.1  Each State must maintain a certified Unit unless the Secretary 
of Health and Human Services determines that operation of a Unit 
would not be cost-effective because (1) minimal Medicaid fraud 
exists in that State and (2) the State has other adequate safeguards to 
protect Medicaid beneficiaries from abuse and neglect.2  Currently, 
49 States and the District of Columbia (States) have created such 
Units.3  In fiscal year (FY) 2014, combined Federal and State grant 
expenditures for the Units totaled $235 million.4, 5   That year, the 
50 Units employed 1,958 individuals.6    
Each Unit must employ an interdisciplinary staff that consists of at 
least an investigator, an auditor, and an attorney.7 Unit staff review 
complaints referred to the Unit and determine their potential for 
criminal prosecution and/or civil action.  In FY 2014, the 50 Units 
collectively obtained 1,318 convictions and 874 civil settlements or 
judgments.8  In addition, the Units reported recoveries of 
approximately $2 billion.9  
______________________________________________________ 
1 Social Security Act (SSA)    1903(q).  Regulations at 42 CFR   1007.11(b)(1) 
 
add that the Units responsibilities may include  reviewing complaints of 
 
misappropriation of patients private funds in  residential health care facilities. 

2  SSA  1902(a)(61). 
   
3 North Dakota and the territories of  American Samoa, Guam, the Northern 

Mariana Islands, Puerto Rico, and the U.S. Virgin Islands have  not established 
 
Units. 

4 All FY references in this report are based on the Federal FY (October 1  through 
 
September 30). 
 
5  Office of  Inspector General (OIG),  MFCU  Statistical Data for Fiscal Year 2014. 

Accessed at http://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2014-statistical-chart.htm  on August 3, 2015. 

6 Ibid. 

7  SSA  1903(q)(6); 42  CFR 1007.13. 

8 OIG,  MFCU  Statistical Data  for Fiscal Year 2014. Accessed at 

http://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2014-statistical-chart.htm  on August 3, 2015. 
9 Ibid. 
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)   1 
   
   
Units are required to have either statewide authority to prosecute 
cases or formal procedures to refer suspected criminal violations to 
an agency with such authority.10 In Arizona and 43 other States, the 
Units are located within offices of  State Attorneys General that have 
this authority.  In the remaining six States, the Units are located in 
other State agencies; generally, such Units refer cases to other  
offices with prosecutorial authority.11 Additionally, each Unit must 
be a single, identifiable entity of State government, distinct from the 
single State Medicaid agency and must develop a formal 
agreementi.e., a memorandum of understanding (MOU)that 
describes the Units relationship with that agency.12   
Oversight of the MFCU Program  
The Secretary of Health and Human Services delegated to OIG the 
authority both to annually certify the Units and to administer grant 
awards to reimburse States for a percentage of their costs of operating 
certified Units.13   All Units are currently funded by the Federal 
Government on a 75-percent matching basis, with the States 
contributing the remaining 25 percent.14   To receive Federal 
reimbursement, each Unit must submit an initial application to OIG.15   
OIG reviews the application and notifies the Unit if the application is 
approved and the Unit is certified. Approval and certification are for a 
1-year period; the Unit must be recertified each year thereafter.16 In 
addition to annual recertification, OIG performs periodic onsite 
reviews of the Units. 
States must operate Units that effectively carry out their statutory 
functions and meet program requirements.17   To clarify the criteria that  
OIG applies in assessing whether a Unit is effectively carrying out 
these functions and meeting program requirements, OIG developed and 
issued 12 performance standards.18  Examples of the standards include 
maintaining an adequate caseload through referrals from several 
______________________________________________________ 
10  SSA  1903(q)(1).  
11 OIG,  Medicaid Fraud Control Units.  Accessed at http://oig.hhs.gov/fraud/ 

medicaid-fraud-control-units-mfcu/index.asp on February 25, 2015. 

12  SSA  1903(q)(2); 42  CFR  1007.9(d). 
  
13 The portion of funds reimbursed to States by the Federal  Government for its
  
share of expenditures for the Federal Medicaid program, including the MFCUs, is 

called Federal Financial Participation.  

14  SSA 1903(a)(6)(B).  

15 42  CFR  1007.15(a). 
 
16 42 CFR   1007.15(b) and  (c). 

17  SSA  1902(a)(61). 
 
18  77  Fed.  Reg. 32645 (June 1, 2012). 

Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   2 
     
   
sources, maintaining a training plan for all professional disciplines, and 
establishing policies and procedure manuals.  See Appendix A for a 
description of each of the 12 performance standards.  
Arizona Medicaid Program  
Arizonas State Medicaid program provides services to Medicaid 
enrollees through managed care.19   Through what is known as a 
section 1115 waiver, Arizona was the first State to enroll the majority 
of its Medicaid beneficiaries statewide in mandatory managed care.20,  21   
As of July 2011, nearly 90 percent of Medicaid beneficiaries in 
Arizona were enrolled in managed care.  The State Medicaid agency 
contracts with nine MCOs and pays them a fixed amount for Medicaid 
enrollees.22  In FY 2014, combined Federal and State expenditures for 
Arizonas Medicaid program were approximately $9.5 billion.23  
Arizona MFCU 
The Arizona Unit is housed within the criminal division of the Arizona 
Office of the Attorney General and operates in three locations.  The 
Units headquarters is located in Phoenix, Arizonas capital.  The Unit 
operates two subunits, located in Prescott and Tucson. 
At the time of our review, the Unit employed 19 staff members 
including the director, the special agent supervisor, 8 special agents, 
4 attorneys, 1 auditor, and 4 support staff members. 
Referrals. The Unit receives referrals from a variety of sources, 
including the State Medicaid agency, local law enforcement, 
Adult Protective Services, and the State Long-Term Care Ombudsman.  
______________________________________________________ 
19 Medicaid managed care is a type of  health care delivery system that provides 
Medicaid health benefits  and services to enrollees through contracted 
arrangements between State Medicaid agencies and managed care organizations 
(MCOs). MCOs receive a set payment per member per month from the State 
Medicaid agency for these services. 
20 The only beneficiary population that is not mandatorily enrolled into managed 
care is the American  Indian/Alaska Native population.  This population may elect 
to remain in Arizonas fee-for-service Medicaid program, or can elect to receive 
health  benefits through Medicaid managed care. 
21 States must comply with Title XIX (Medicaid) and Title XXI (Childrens Health  
Insurance Program) of the SSA.  Arizona began providing  Medicaid services on  
October 1, 1982.  Since then, the Arizona Health Care Cost Containment 
SystemArizonas State Medicaid agencyhas been exempt from specific 
provisions  of the SSA,  pursuant to a waiver under section 1115  of the SSA.  
22 Centers for Medicare & Medicaid Services (CMS), Managed Care in Arizona. 
Accessed at http://www.medicaid.gov/Medicaid-CHIP-Program-Information/By-
State/arizona.html on April 30, 2015. 
23 OIG,  MFCU  Statistical Data  for Fiscal Year 2014. Accessed at 
http://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/  
expenditures_statistics/fy2014-statistical-chart.htm  on August 3, 2015. 
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   3 
     
   
Unit referrals by referral source for FYs 2012 through 2014 can be 
found in Appendix B.  Generally, referrals are received by the special 
agent supervisor by postal mail or telephone.  The special agent 
supervisor is responsible for obtaining information about the referral 
and may conduct a preliminary investigation before opening a case. 
Investigations and prosecutions. When a case is opened, it is 
assigned to a special agent and attorney for investigation and, as 
appropriate, for prosecution. The Unit has statewide authority to 
prosecute criminal cases of Medicaid fraud and patient abuse.  The 
Unit does not pursue civil Medicaid fraud cases, which are instead 
prosecuted by the State Medicaid Agencys Office of Inspector 
General. See Appendix C for details on investigations opened and 
closed. 
Previous OIG Onsite Review  
In 2009, OIG published a report regarding its onsite review of the 
Arizona Unit.  OIG found that the Unit was in full compliance with all 
applicable Federal regulations and the 12 MFCU performance 
standards.  
METHODOLOGY 
We conducted an onsite review of the Arizona Unit in July 2015.  
We based our review on analysis of data from seven sources:  
(1) a review of policies, procedures, and documentation related to 
the Units operations, staffing, and caseload for FYs 2012 through 
2014; (2) a review of financial documentation for FYs 2012 through 
2014; (3) structured interviews with key stakeholders; (4) a survey of 
Unit staff; (5) structured interviews with the Units management; 
(6) an onsite review of files for cases that were open in FYs 2012 
through 2014; and (7) onsite observation of Unit operations.  
Appendix D provides a detailed methodology.   
Standards 
These reviews are conducted in accordance with the Quality Standards 
for Inspection and Evaluation issued by the Council of the Inspectors 
General on Integrity and Efficiency. 
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FINDINGS 
Our review of the Arizona Unit found that it was generally in  
compliance with applicable laws, regulations, and policy transmittals.  
Additionally, the Unit collaborates with external stakeholders and 
educates the community to generate referrals.  Although we found no 
evidence of significant noncompliance, we identified one area for  
improvement.  Specifically, the Unit did not report all convictions and 
adverse actions to Federal partners within required timeframes.  
However, the Unit has susbsequently implemented processes to ensure 
future timely reporting. 
For FYs 2012 through 2014, the Arizona Unit 
reported 185 criminal convictions and combined 
criminal and civil recoveries of $4 million 
For FYs 2012 through 2014, the Unit reported 185 criminal 
convictions. Of the Units 185 convictions over the 3-year period, 
135 involved provider fraud, 8 involved patient abuse and neglect, 
and 42 involved patient funds. 
For the same period, the Unit reported combined criminal and civil 
recoveries of approximately $4 million.  See Table 1 for the Units 
yearly recoveries and expenditures. The Unit obtained 55 percent of 
its recoveries from global cases during the 3-year review period.24  
Table 1:  Arizona MFCU Recoveries and Expenditures, 
FYs 20122014*  
Type of Recovery   FY 2012   FY 2013   FY 2014   3-Year Total  
Global Civil  $462,297   $443,797  $1,357,762  $2,263,856  
Nonglobal Civil  $0  $0  $0  $0 
Criminal  $880,288   $645,915   $301,869   $1,828,073 
     Total Recoveries  $1,342,585   $1,089,713   $1,659,631   $4,091,929 
     Total Expenditures  $1,634,293   $1,806,079   $2,037,742   $5,478,114  
Source:  OIG analysis of Unit-submitted documentation, 2015. 
* Due to rounding, dollar figures for each category of recoveries do not always sum to the total recovery  
amount for  that category.  
______________________________________________________ 
24 Global cases are civil false claims actions involving the U.S. Department of 
Justice and other State MFCUs.  The National Association  of Medicaid Fraud 
Control Units facilitates the settlement of global cases. 
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The Arizona Medicaid program provides and pays for services 
through MCOs.25 Accordingly, the Unit has significant experience 
investigating and prosecuting matters involving managed care 
settings. Matters that the Unit investigates include falsified 
identities, double billing, falsified prescriptions, and elder abuse, 
which are similar to matters that might be investigated by other State 
MFCUs. 
According to the Unit, part of the reason it has been able to 
successfully investigate and prosecute matters involving managed 
care is that the Unit does not focus on the payer involved in each 
case.  The Unit director said, A crime is a crime regardless of  
whether it occurred in a managed care or a fee-for-service setting.  
As a result, the Unit does not make a distinction between managed 
care cases and fee-for-service cases.  Rather, the Unit focuses on 
investigating and prosecuting the case and relies on the State 
Medicaid agency to calculate restitution, which is equivalent to the 
amount falsely billed by the provider.26  
Almost all case files contained documentation of 
supervisory approval to open and close cases as 
well as of periodic supervisory review 
The Unit documented supervisory approval to open 100 percent of 
cases and to close 99 percent of closed cases.  According to 
Performance Standard 5(b), Unit supervisors should approve the 
opening and closing of cases to ensure continuous case flow and 
timely completion of cases.  Supervisory approval to open and close 
cases demonstrates that Unit supervisors are monitoring the intake of 
cases and the timeliness of case resolutions.  
The Units policy requires that supervisory reviews occur on a 
quarterly basis (i.e., every 90 days), and our review found that 
94 percent of cases contained documentation indicating such review.  
According to Performance Standard 7(a), supervisory reviews should 
be conducted periodically and noted in the case file.  Appendix E 
______________________________________________________ 
25 Nearly all of Arizonas Medicaid enrollees receive services through MCOs.  The 
only population that is not mandatorily enrolled into managed care is the 
American  Indian/Alaska Native population. 
26 Once the State Medicaid agency calculates the restitution,  it reports the billing  
information to  the Unit.  Using this information, the Unit pursues a restitution  
order against the provider as part  of the resolution  of its case.  After the conclusion  
of the Units case, the State Medicaid agency pursues a separate civil recoupment  
action,  which may include civil forfeitures. 
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contains the point estimates and 95-percent confidence intervals for 
these statistics. 
The Unit did not report all convictions and adverse 
actions to Federal partners within required 
timeframes; however, the Unit has subsequently 
implemented processes to ensure future timely 
reporting 
The Unit did not report all convictions to OIG for the purpose of 
program exclusion or all adverse actions to the National Provider 
Data Bank (NPDB) within the required timeframes; however, the 
Unit has subsequently implemented new processes to ensure that 
future convictions and adverse actions are reported to these Federal 
partners within the required timeframes.  According to Performance 
Standard 8(f), the Unit should transmit to OIG reports of all 
convictions for the purpose of exclusion from Federal health care 
programs within 30 days of sentencing.  Additionally,  Federal 
regulations require that for any adverse actions generated as a result 
of investigations or prosecutions of healthcare providers, Units must 
report the action to the NPDB within 30 days.27  
Eighty-one percent of the Units convictions were not 
reported to OIG for the purpose of program exclusion 
within the required timeframe 
The Unit reported all 185 of its convictions to OIG for the purpose of 
program exclusion; however, 81 percent (150 of 185) of the Units  
convictions were not reported within 30 days of sentencing.  Of the  
convictions that were not reported timely, 119 were reported over 
120 days after sentencing, 8 were reported within 91 to 120 days of 
sentencing, and 23  were reported within 31 to 90 days of sentencing.  
If a Unit fails to ensure that convicted individuals are referred for  
______________________________________________________ 
27 Examples of final adverse actions include, but are not limited to, convictions, 
civil judgments (but  not civil settlements), and program exclusions.  See 45 CFR 
 60.5.  In addition to Federal  regulations, the Performance Standards also  require 
Units to report to NPDB.  Performance Standard 8(g) states that the Unit should 
report qualifying cases to the Healthcare Integrity & Protection  Databank 
[HIPDB],  the National Practitioner  Data  Bank, or  successor data  bases.  The 
NPDB is intended to  restrict the ability of physicians, dentists, and other health  
care practitioners to move from State to State without  disclosure or discovery of 
previous medical malpractice and adverse actions.   We reviewed the reporting of  
adverse actions under NPDB requirements because the HIPDB and the NPDB  
were  merged during  our review period  (FYs 2012  through 2014).  78 Fed. Reg.  
20473 (April 5, 2013). 
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exclusion, those individuals may be able to continue to submit claims  
and receive payments from Federal health care programs.   
The Unit reported that staff turnover contributed to the Units not 
submitting records of convictions to OIG for the purpose of program 
exclusion. The Unit said that it notified OIG of this issue in 
December 2013 and worked with OIG for approximately 6 months to  
submit all records of convictions. 
Seventy percent of the Units adverse actions were not 
reported to the NPDB within the required timeframe  
The Unit reported all 109 adverse actions to the NPDB; however, 
70 percent (76 of 109) were not reported within 30 days of the 
action. Of the adverse actions that were not reported timely, 66 were 
reported over 90 days after the action; 4 were reported within 
61 to 90 days of the action; and 6 were reported within 31 to 60 days 
of the action. The Unit said thatas with reporting convictions to 
OIG for program exclusionstaff  turnover contributed to these 
delays. 
The Unit has implemented new processes to ensure 
future timely reporting to Federal partners 
In May 2015, the Unit implemented new processes to ensure that 
convictions are reported to OIG and adverse actions are reported to 
the NPDB within the required timeframes.  Such processes include 
(1) providing a memorandum to Unit support staff outlining a timeline 
for reporting convictions and adverse actions, (2) creating a tickler 
calendar to remind staff to collect and prepare conviction information 
for submission to OIG and report adverse actions to the NPDB, 
(3) providing staff with a copy of OIGs presentation on the exclusion 
program and the Health Resources and Services Administrations 
presentation on NPDB reporting, (4) including conviction and adverse 
action reporting as part of the Units checklist for case closing, and 
(5) an ongoing reminder at each staff meeting to report convictions 
and adverse actions within the required timeframes.   
Other observation:  The Unit collaborates with 
external stakeholders and educates the 
community to generate referrals 
The Unit collaborates with the State Medicaid agency and MCOs to 
ensure that they provide quality referrals to the Unit.  The Unit 
director reported that Unit staff attend quarterly compliance-officer 
meetings held between the State Medicaid agency and the MCOs.  
These meetings are led by the State Medicaid agency and include 
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representation from all of the States contracted MCOs.  The Unit 
director said that these meetings give the Unit an opportunity to 
provide guidance as to what constitutes a quality referral and the 
types of referrals that will result in opening a case for investigation.  
For FYs 2012 through 2014, the Unit reported that it opened 
19 cases for criminal investigation as a result of referrals provided by 
the State Medicaid agency. Of these 19 cases, 13 involved referrals 
originating from MCOs. 
To help generate referrals, the Unit also educates the community 
about the Units role in investigating and prosecuting cases of 
Medicaid fraud and patient abuse. The actions the Unit takes to 
educate the community include providing training to Adult 
Protective Services and distributing MFCU manuals regarding fraud 
and elder abuse to law enforcement and community advocacy 
organizations. The Unit director reported that providing training 
connects the Unit to the community, and as a result, helps generate 
cases. 
 
   
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CONCLUSION AND RECOMMENDATION 
For FYs 2012 through 2014, the Arizona Unit reported 185 criminal 
convictions, 4 civil judgments and settlements, and combined  
criminal and civil recoveries of $4 million.  
Our review found that the Unit was in general compliance with 
applicable laws, regulations, and policy transmittals.  However, we 
identified one area for improvement in the Units operations.  
Specifically, we found that for FYs 2012 through 2014, the Unit did 
not report all convictions and adverse actions to Federal partners 
within required timeframes.  Subsequent to the period of review, the 
Unit implemented processes to ensure future timely reporting. 
We recommend that the Arizona Unit: 
Update its policies and procedures manual to include the 
Units new processes for reporting convictions and 
adverse actions to Federal partners within required 
timeframes  
The Unit has implemented new processes to ensure that convictions 
are reported to OIG and adverse actions are reported to the NPDB 
within the required timeframes.  The Unit should update its policies 
and procedures manual to include the new processes to ensure that 
convictions are reported to OIG within 30 days and that adverse 
actions are reported to the NPDB within 30 days. 
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UNIT COMMENTS AND OFFICE OF INSPECTOR GENERAL  
RESPONSE 
The Arizona Unit concurred with our recommendation.  The Unit 
stated that it has already implemented processes to ensure that 
convictions are reported to OIG within 30 days of sentencing and 
adverse actions are reported to the NPDB within 30 days of the final 
action. The full text of the Units comments is provided in 
Appendix F.  
   
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APPENDIX A 
2012 Performance Standards28   
1. A  UNIT CONFORMS WITH ALL APPLICABLE STATUTES, REGULATIONS, AND POLICY DIRECTIVES, 
INCLUDING:  
A. Section 1903(q) of the Social Security Act,  containing the basic requirements for operation of a MFCU;  
B. Regulations for operation of a MFCU contained in 42 CFR part 1007; 
C. Grant administration requirements at 45 CFR part 92 and Federal cost principles at 2 CFR part 225; 
D. OIG policy transmittals as maintained on the OIG Web site; and  
E. Terms and conditions of the notice of the grant award.  
2. A  UNIT MAINTAINS REASONABLE STAFF LEVELS AND OFFICE LOCATIONS IN RELATION TO THE 
STATES MEDICAID PROGRAM EXPENDITURES AND IN ACCORDANCE WITH STAFFING  
ALLOCATIONS APPROVED IN ITS BUDGET.   
A. The Unit employs the number of staff that is included in the Units budget estimate as approved by OIG.  
B. The Unit employs a total number of professional staff that is commensurate with the States total Medicaid 
program expenditures and that enables the Unit to effectively investigate and prosecute (or refer for 
prosecution) an appropriate volume of case referrals and workload for both Medicaid fraud and patient abuse 
and neglect. 
C. The Unit employs an appropriate mix and number of attorneys, auditors, investigators, and other 
professional staff that is both commensurate with the States total Medicaid program expenditures and that 
allows the Unit to effectively investigate and prosecute (or refer for prosecution) an appropriate volume of case 
referrals and workload for both Medicaid fraud and patient abuse and neglect. 
D. The Unit employs a number of support staff in relation to its overall size that allows the Unit to operate 
effectively.  
E. To the extent that a Unit maintains multiple office locations, such locations are distributed throughout the 
State, and are adequately staffed, commensurate with the volume of case referrals and workload for each 
location. 
3. A  UNIT ESTABLISHES WRITTEN POLICIES AND PROCEDURES FOR ITS OPERATIONS AND 
ENSURES THAT STAFF ARE FAMILIAR WITH, AND ADHERE TO, POLICIES AND PROCEDURES.   
A. The Unit has written guidelines or manuals that  contain current policies and procedures, consistent with 
these performance standards, for the investigation and (for  those Units with prosecutorial authority) prosecution 
of Medicaid fraud and patient abuse and neglect.  
B. The Unit adheres to current policies and procedures in its operations. 
C. Procedures include a process for referring cases, when appropriate, to Federal and State agencies.  
Referrals to State agencies, including the State Medicaid agency, should identify  whether further investigation 
or other administrative action is warranted, such as the collection of overpayments or suspension of payments.  
D. Written guidelines and manuals are readily available to all Unit staff, either online or in hard copy.  
E. Policies and procedures address training standards for Unit employees.  
4. A  UNIT TAKES STEPS TO MAINTAIN  AN  ADEQUATE VOLUME AND QUALITY OF REFERRALS FROM  
THE STATE MEDICAID  AGENCY AND OTHER SOURCES.    
______________________________________________________ 
28 77 Fed. Reg. 32646, (June 1, 2012). 
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A. The Unit takes steps, such as the development of operational protocols, to ensure that the State Medicaid 
agency, managed care organizations, and other agencies refer to the Unit all suspected provider fraud cases.  
Consistent with 42 CFR 1007.9(g), the Unit provides  timely  written notice to the State Medicaid agency when 
referred cases are accepted or declined for investigation. 
B. The Unit provides periodic feedback to the State Medicaid agency  and other referral sources on the 
adequacy of both the volume and quality  of its referrals. 
C. The Unit provides timely information to the State Medicaid or other agency when the Medicaid or other 
agency requests information on the status of MFCU  investigations, including when the Medicaid agency 
requests quarterly certification pursuant to 42 CFR 455.23(d)(3)(ii).  
D. For those States in which the Unit has original jurisdiction to investigate or prosecute patient abuse and 
neglect cases, the Unit takes steps, such as the development of operational protocols, to ensure that pertinent 
agencies refer such cases to the Unit, consistent with patient confidentiality and consent.  Pertinent agencies 
vary by State but may include licensing and certification agencies, the State Long Term Care Ombudsman, and 
adult protective services offices.  
E. The Unit provides timely information, when requested, to those agencies identified in (D) above regarding 
the status of referrals. 
F. The Unit takes steps, through public outreach or other means, to encourage the public to refer cases to the 
Unit. 
5. A  UNIT TAKES STEPS TO MAINTAIN  A  CONTINUOUS CASE FLOW  AND TO  COMPLETE CASES IN AN  
APPROPRIATE TIMEFRAME BASED ON  THE COMPLEXITY OF THE CASES.  
A. Each stage of an investigation and prosecution is completed in an appropriate timeframe.  
B. Supervisors approve the opening and closing of all investigations and review the progress of cases and take 
action as necessary to ensure that each stage of an investigation and prosecution is completed in an 
appropriate timeframe.  
C. Delays to investigations and prosecutions are limited to situations imposed by resource constraints or other 
exigencies. 
6. A  UNITS CASE MIX, AS PRACTICABLE, COVERS ALL SIGNIFICANT PROVIDER TYPES AND 
INCLUDES A  BALANCE OF FRAUD AND, WHERE APPROPRIATE, PATIENT ABUSE AND NEGLECT 
CASES.    
A. The Unit seeks to have a mix of cases from all significant provider types in the State. 
B. For those States that rely substantially on managed care entities for the provision of Medicaid services, the 
Unit includes a commensurate number of managed care cases in its mix of cases.  
D. As part of its case mix, the Unit maintains a balance of fraud and patient abuse and neglect cases for those 
States in which the Unit has original jurisdiction to  investigate or prosecute patient abuse and neglect cases.  
C. The Unit seeks to allocate resources among provider types based on levels of Medicaid expenditures or 
other risk factors. Special Unit initiatives may focus on specific provider types. 
E. As part of its case mix, the Unit seeks to maintain, consistent with its legal authorities, a balance of criminal 
and civil fraud cases. 
7. A  UNIT MAINTAINS CASE FILES IN AN EFFECTIVE MANNER  AND DEVELOPS A  CASE  
MANAGEMENT SYSTEM THAT ALLOWS EFFICIENT ACCESS TO CASE INFORMATION AND OTHER 
PERFORMANCE DATA.    
A. Reviews by supervisors are conducted periodically, consistent with MFCU policies and procedures, and are 
noted in the case file. 
B. Case files include all relevant facts and information and justify the opening and closing of the cases. 
C. Significant documents, such as charging documents and settlement agreements, are included in the file.  
D. Interview summaries are written promptly, as defined by the Units policies and procedures.  
E. The Unit has an information management system that manages and tracks case information from initiation to 
resolution. 
F. The Unit has an information management system that allows for the monitoring and reporting of case 
information, including the following:  
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   13 
     
   
1. The number of cases opened and closed and the reason that cases are closed. 
2. The length of time taken to determine whether to open a case referred by the State Medicaid agency  or other 
referring source.  
3. The number, age, and types of cases in the Units inventory/docket 
4. The number of referrals received by the Unit and the number of referrals by  the Unit to other agencies.  
5. The number of cases criminally prosecuted by the Unit or referred to others for prosecution, the number of 
individuals or entities charged, and the number of pending prosecutions. 
6. The number of criminal convictions and the number of civil judgments. 
7. The dollar amount of overpayments identified. 
8. The dollar amount of fines, penalties, and restitution ordered in a criminal case and the dollar amount of 
recoveries and the types of relief obtained through civil judgments or prefiling settlements. 
8. A  UNIT COOPERATES WITH OIG AND OTHER FEDERAL AGENCIES IN THE INVESTIGATION AND 
PROSECUTION OF MEDICAID  AND OTHER HEALTH CARE FRAUD.    
A.  The Unit communicates on a regular basis with OIG and other Federal agencies investigating or 
prosecuting health care fraud in the State.  
B. The Unit cooperates and, as appropriate, coordinates with OIGs Office of Investigations and other Federal 
agencies on cases being pursued jointly, cases involving the same suspects or allegations, and cases that have 
been referred to the Unit by  OIG or another Federal agency.   
C. The Unit makes available, to the extent authorized by law and upon request by  Federal investigators and 
prosecutors, all information in its possession concerning provider fraud or fraud in the administration of the 
Medicaid program. 
D. For cases that require the granting of extended jurisdiction to investigate Medicare or other Federal health 
care fraud, the Unit seeks permission from OIG or other relevant agencies under procedures as set by those 
agencies. 
E. For cases that have civil fraud potential, the Unit investigates and prosecutes such cases under State 
authority  or refers such cases to OIG or the U.S. Department of Justice.  
F. The Unit transmits to OIG, for  purposes of program exclusions under section 1128 of the Social Security Act, 
all pertinent information on MFCU convictions within 30 days of sentencing, including charging documents, plea 
agreements, and sentencing orders. 
G. The Unit reports qualifying cases to the Healthcare Integrity & Protection Databank, the National Practitioner 
Data Bank, or successor data bases. 
9. A  UNIT MAKES STATUTORY OR PROGRAMMATIC RECOMMENDATIONS, WHEN WARRANTED, TO  
THE STATE GOVERNMENT.    
A. The Unit, when warranted and appropriate, makes statutory  recommendations to the State legislature to 
improve the operation of the Unit, including amendments to the enforcement provisions of the State code. 
B. The Unit, when warranted and appropriate, makes other regulatory or administrative recommendations 
regarding program integrity issues to the State Medicaid agency  and to other agencies responsible for Medicaid 
operations or funding.  The Unit monitors actions taken by the State legislature and the State Medicaid or other 
agencies in response to recommendations.  
10. A  UNIT PERIODICALLY REVIEWS ITS MEMORANDUM OF UNDERSTANDING (MOU) WITH THE 
STATE MEDICAID AGENCY TO  ENSURE THAT IT REFLECTS CURRENT PRACTICE, POLICY, AND  
LEGAL REQUIREMENTS.    
A. The MFCU documents that it has reviewed the MOU at least every 5 years, and has renegotiated the MOU  
as necessary, to ensure that it reflects current practice, policy, and legal requirements. 
B. The MOU meets current Federal legal requirements as contained in law or regulation, including 42 CFR  
455.21, Cooperation with State Medicaid fraud control units, and 42 CFR  455.23, Suspension of payments 
in cases of fraud. 
C. The MOU is consistent with current Federal and State policy, including any policies issued by  OIG or CMS.  
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   14 
     
   
D. Consistent with Performance Standard 4, the MOU establishes a process to ensure the receipt of an 
adequate volume and quality of referrals to the Unit from the State Medicaid agency.  
E. The MOU incorporates by  reference the CMS Performance Standard for Referrals of Suspected Fraud from  
a State Agency to a Medicaid Fraud Control Unit. 
11. A  UNIT EXERCISES PROPER FISCAL CONTROL OVER UNIT RESOURCES.    
A. The Unit promptly submits to OIG its preliminary budget estimates, proposed budget, and Federal financial 
expenditure reports.   
B. The Unit maintains an equipment inventory that is updated regularly to reflect all property under the Units 
control. 
C. The Unit maintains an effective time and attendance system and personnel activity  records.  
D. The Unit applies generally accepted accounting  principles in its control of Unit funding. 
E. The Unit employs a financial system in compliance with the standards for financial management systems 
contained in 45 CFR 92.20.  
12. A  UNIT CONDUCTS TRAINING THAT  AIDS IN THE MISSION OF THE UNIT.    
A. The Unit maintains a training plan for each professional discipline that includes an annual minimum number 
of training hours and that is at least as stringent as required for professional certification.  
B. The Unit ensures that professional staff comply with their training plans and maintain records of their staffs 
compliance.  
C. Professional certifications are maintained for all staff, including those that fulfill continuing education 
requirements.  
D. The Unit participates in MFCU-related training, including training offered by  OIG and other MFCUs, as such 
training is available and as funding permits. 
E. The Unit participates in cross-training with the fraud detection staff of the State Medicaid agency.  As part of 
such training, Unit staff provide training on the elements of successful fraud referrals and receive training on the 
role and responsibilities of the State Medicaid agency.   
 
 
 
 
 
 
   
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   15 
     
   
APPENDIX B 
Arizona State Medicaid Fraud Control Unit Referrals by  
Referral Source for FYs 2012 Through 2014 
  FY 2012   FY 2013   FY 2014  
Abuse &   Patient  Abuse &   Patient  Abuse &   Patient 
Referral Source   Fraud   Fraud   Fraud  
Neglect   Funds   Neglect   Funds   Neglect   Funds  
Medicaid agency   
PI/SURS29   5  0  2  7  0  0  6  1  1 
Medicaid agency  
0  0  0  0  0  0  2  1  0 
other  
Managed care 
0  0  0  0  0  0  0  0  0 
organizations 
State survey and  
3  2  4  3  1  4  3  2  1 
certification agency 
Other State 
0  1  0  1  0  1  4  4  1 
agencies 
Licensing board  2  1  1  3  1  0  1  0  0 
Law  enforcement   40  6  8  19  4  14  27  6  3 
Office of Inspector 
4  0  0  11  1  3  7  0  1 
General 
Prosecutors  11  0  1  20  0  0  4  0  0 
Providers  4  2  1  8  1  1  4  0  2 
Provider 
0  0  0  0  0  0  0  0  0 
associations 
Private health 
0  0  0  0  0  0  0  0  0 
insurer 
Long-term-care 
0  0  0  0  0  0  0  0  0 
ombudsman  
Adult protective 
2  0  1  0  0  0  0  5  3 
services  
Private citizens  2  1  1  0  0  0  4  2  1 
MFCU hotline   0  0  0  0  0  0  0  0  0 
Self-generated   0  0  0  0  0  0  0  0  1 
Other   5  1  0  2  2  0  11  0  1 
   Total   78  14  19  74  10  23  73  21  15 
   Annual Total   111  107  109 
Source:  OIG analysis of Unit-submitted documentation, 2015. 
______________________________________________________ 
29 The abbreviation PI stands  for program integrity; the abbreviation  SURS 
stands for Surveillance and  Utilization Review Subsystem.  
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   16 
     
   
APPENDIX C 
Investigations Opened and Closed By Provider Category  
for FYs 2012 Through 2014 
Table C-1: Fraud Investigations  
Provider Category   FY 2012   FY 2013   FY 2014  
Facilities   Opened  Closed   Opened  Closed   Opened   Closed 
 Hospitals  0  0  2  0  0  0 
     Nursing facilities  0  0  1  0  1  0 
     Other long-term-care  
1  1  3  0  6  2 
     facilities  
     Substance abuse treatment       
0  0  0  0  0  0 
centers 
     Other   3  1  4  0  3  2 
   Subtotal   4  2  10  0  10  4 
Practitioners   Opened   Closed  Opened   Closed  Opened   Closed 
     Doctors of medicine or  
5  5  8  3  11  10 
     osteopathy  
Dentists  1  0  3  0  0  0 
Podiatrists  0  0  0  1  0  1 
     Optometrists/opticians  0  1  0  0  0  0 
     Counselors/psychologists  0  3  0  0  0  0 
     Chiropractors  0  0  0  0  0  0 
     Other   3  1  10  2  2  4 
   Subtotal   9  10  21  6  13  15 
Medical Support  Opened  Closed   Opened  Closed   Opened   Closed 
 Pharmacies  2  2  1  1  3  0 
Pharmaceutical 
10  3  9  0  2  0 
     manufacturers  
Suppliers of durable medical 
0  0  1  0  1  0 
     equipment and/or supplies 
     Laboratories  0  0  0  0  0  0 
     Transportation services  0  1  1  0  2  1 
     Home health care agencies  3  1  0  0  3  0 
     Home health care aides  5  2  10  3  9  14 
     Nurses, physician assistants, 
     nurse practitioners, certified   6  4  6  1  3  6 
nurse aides  
Radiologists  2  0  0  0  1  1 
     Medical supportother   27  16  21  9  23  40 
   Subtotal   55  29  49  14  47  62 
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   17 
     
   
 
Table C-1 (Continued):  Fraud Investigations  
Provider Category   FY 2012   FY 2013   FY 2014  
Program Related   Opened   Closed  Opened   Closed  Opened   Closed 
     Managed care organizations  0  1  0  0  0  0 
     Medicaid program  
0  0  0  0  1  0 
administration 
     Billing company   0  0  0  0  0  0 
     Other   1  0  1  0  2  0 
   Subtotal   1  1  1  0  3  0 
   Total Provider Categories   69  42  81  20  73  81 
Source:  OIG analysis of Unit-submitted documentation, 2015.  
 
Table C-2: Patient Abuse and Neglect Investigations  
Provider Category   FY 2012   FY 2013   FY 2014  
  Opened  Closed  Opened  Closed  Opened  Closed 
     Nursing facilities  1  1  3  0  0  3 
     Other long-term-care facilities   1  0  3     8  4 
Nurses, physician assistants, 
nurse practitioners,   4  0  1  0  1  3 
certified nurse aides 
     Home health aides  5  0  2  0  9  7 
     Other   3  0  1  2  3  1 
   Total   14  1  10  2  21  18 
Source: OIG analysis of Unit-submitted documentation,  2015. 
 
Table C-3: Patient Funds Investigations  
Provider Category   FY 2012   FY 2013   FY 2014  
  Opened  Closed  Opened  Closed  Opened  Closed 
     Nondirect care   2  0  1  0  1  0 
Nurses, physician assistants, 
nurse practitioners,   3  1  4  0  1  1 
certified nurse aides 
     Home health aides  0  0  0  0  2  0 
     Other   14  8  18  3  11  12 
Total   19  9  23  3  15  13 
Source: OIG analysis of Unit-submitted documentation,  2015.  
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   18 
     
   
APPENDIX D 
Detailed Methodology 
Data collected from the seven sources below was used to describe 
the caseload and assess the performance of the Arizona MFCU. 
Data Collection 
Review of Unit Documentation. We collected information for 
FYs 2012 through 2014 regarding the Units investigation of 
Medicaid cases, including information about the number of referrals 
the Unit received, the number of investigations the Unit opened and 
closed, the outcomes of those investigations, and the Units case mix.  
We also collected and analyzed information about the number of 
cases that the Unit referred for prosecution and the outcomes of 
those prosecutions. 
We gathered information from several sources, including the Units 
quarterly statistical reports; annual reports; recertification 
questionnaire; policies and procedures manual; and MOU with the 
State Medicaid agency.  Additionally, we confirmed with the Unit 
director that the information we had was current as of June 2015. 
Review of Unit Financial Documentation. We reviewed the Units 
control over its fiscal resources to identify any internal control issues 
or other issues involving use of resources.  Prior to the onsite review, 
we reviewed the Units financial policies and procedures; its 
response to an internal control questionnaire; and documents (such 
as financial status reports) related to MFCU grants.  
We reviewed three purposive samples to assess the Units internal 
control of fiscal resources. All three samples were limited to the 
review period of FYs 2012 through FY 2014.  The three samples 
included the following: 
1. 	  To assess the Units expenditures, we selected a purposive 
sample of 24 items from the Units 1,316 expenditure 
transactions.  We selected routine and nonroutine 
transactions representing a variety of budget categories and 
payment amounts. 
2. 	  To assess the Units travel expenditures, we selected a 
purposive sample of 24 items from the Units 153 travel 
transactions.  We selected a variety of travel expenditure 
categories related to both in-State and out-of-State travel, 
such as hotel stays, airfare, and conference expenses.   
3. 	  To assess employees time and efforti.e., their work 
hours spent on various MFCU taskswe selected a sample 
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   19 
     
   
of three pay periods, one from each fiscal year.  We then 
requested and reviewed documentation (e.g., time card 
records) to support the time and effort of the MFCU staff 
during the selected pay periods. 
We also reviewed a purposive sample of the Units supply inventory, 
including vehicles. Specifically, we selected and verified a 
purposive sample of 23 items from the current inventory list of  
82 items maintained in the Units Phoenix office.  To ensure a 
variety in our inventory sample, we included expensive items such as 
computers and vehicles as well as less expensive items such as 
radios and cameras. 
Interviews with Key Stakeholders. In June 2015, we interviewed key 
stakeholders, including officials in the United States Attorneys  
Offices, the State Attorney Generals Office, and other State agencies 
that interacted with the Unit (e.g., the Medicaid Program Integrity 
Unit, the Office of the State Long-Term Care Ombudsman, and Adult 
Protective Services).  Additionally, we interviewed two managed care 
health plans that interact with the Unit.  We also interviewed 
supervisors from OIGs Region IX offices who work regularly with the 
Unit. We focused these interviews on the Units relationship and 
interaction with OIG and other Federal and State authorities, and we 
identified opportunities for improvement.  We used the information 
collected from these interviews to develop subsequent interview 
questions for Unit management. 
Survey of Unit Staff. In June 2015, we conducted an online survey of 
all 17 nonmanagerial Unit staff within each professional discipline 
(e.g.,  investigators, auditors, and attorneys) as well as support staff.  
The response rate was 100 percent.  Our questions focused on 
operations of the Unit, opportunities for improvement, and practices 
that contributed to the effectiveness and efficiency of Unit operations 
and/or performance.  The survey also sought information about the 
Units compliance with applicable laws and regulations.   
Onsite Interviews with Unit Management.   We conducted structured 
interviews with the Units management in July 2015.  We  
interviewed the Unit director and the special agent supervisor.   We  
asked these individuals to provide information related to (1) the 
Units operations, (2) Unit practices that contributed to the 
effectiveness and efficiency of Unit operations and/or performance, 
(3) opportunities for the Unit to improve its operations and/or 
 
performance, and (4) clarification regarding information obtained 
from other data sources. 
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   20 
     
   
Onsite Review of Case Files. We requested that the Unit provide us 
with a list of cases that were open at any point during FYs 2012 
through 2014. The Unit provided a list of 480 cases that were open 
during this period. For each of these 480 cases, the Unit provided 
data including the current status of the case; whether the case was 
criminal, civil, or global; and the date on which the case was opened.  
From this list of cases, we excluded 68 cases that were categorized 
as global and 1 case that had been closed prior to the period of our 
review and thus should not have been included in the list.  The 
remaining number of cases was 411. 
From these 411 cases, we selected a simple random sample of 
100 cases for review. From the initial sample of 100 case files, we 
selected a simple random sample of 50 files for a more indepth 
review of selected issues, such as the timeliness of investigations and 
case development. 
One case in our sample of 100 was not reviewed.  This case was 
mislabeled by the Unit as a criminal fraud case; however, it was a 
global case and therefore ineligible to be in the sample.  After 
excluding the ineligible case, we reviewed 99 case files total, of  
which 86 were for closed cases and 96 were for cases that had been 
open for longer than 90 days. 
Because there was 1 ineligible case in the 100 sampled cases, it is 
possible that there could be other ineligible cases in the population.  
Therefore, we estimated the number of cases in the population based 
on the eligible sample, as shown in Table D-1.  We estimated (1) the 
total number of eligible cases, (2) the number of eligible closed 
cases, and (3) the number of eligible cases that were open longer 
than 90 days. 
Table D-1: Estimates of the Population of Eligible Cases  
Population 
Sampled  95-Percent 
Estimate Description   of Eligible 
Cases   Confidence Interval  
Cases  
Total eligible cases  99  407  390410  
Eligible closed cases  86  353  323376  
Eligible cases open 
96  395  373406  
longer than 90 days 
Source:  OIG analysis of Arizona MFCU case files, 2015.  
Using the results of our review of the sampled cases, we reported 
one estimate for each of the above eligible populaitons.  The point 
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   21 
     
   
estimates and their 95-percent confidence intervals are in 
Appendix E. 
Onsite Review of Unit Operations. During our July 2015 onsite visit, 
we reviewed the Units workspace and operations.  Specifically, we 
visited the Unit headquarters in the State capital. While onsite, we 
observed the Units offices and meeting spaces; security of data and 
case files; location of select equipment; and the general functioning 
of the Unit. 
Data Analysis  
We analyzed data to identify any opportunities for improvement and 
any instances in which the Unit did not fully meet the performance 
standards or was not operating in accordance with laws, regulations, 
or policy transmittals.30  
   
______________________________________________________ 
30 All relevant  regulations, statutes, and  policy transmittals are available online at  
http://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu.  
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   22 
     
   
APPENDIX E 
Point Estimates and 95-Percent Confidence Intervals 
Based on Reviews of Case Files 
95-Percent Confidence 
Sample  Point  Interval  
Estimate  
Size*  Estimate  
Lower  Upper  
Percentage of case files that included 
documentation of supervisory approval for  99*  100.0%   96.6%   100.0%  
opening  
Percentage of closed case files that included 
documentation of supervisory approval for  86  98.8%  94.3%  99.7%  
closing  
Percentage of files for cases that were open 
longer than 90 days that included   96  93.8%  87.6%  97.5%  
documentation of periodic supervisory review  
*One sampled case file was ineligible to be in the sample.  This case was mislabeled as a criminal fraud case; 
however, it was a global case.   
Source:  OIG analysis of Arizona MFCU case files, 2015. 
 
    
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   23 
     
   
APPENDIX F 
Unit Comments 
   
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   24 
    Sincerely, 
Steven J. Duplissis, J.D. 
Director and Chief Counsel 
Health Care Fraud and Abuse Section 
S.ID:as 
#4750229 
1275 WEST WASHli.oroi., PHOENIX, AZ 85007  602.542.3881   'M'tW.AZAO.OOV 
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEl-07-15-00280)  25   
   
ACKNOWLEDGMENTS 
This report was prepared under the direction of Brian T.  Whitley, 
Regional Inspector General for Evaluation and Inspections in the 
Kansas City regional office, and Jennifer King, Deputy Regional 
Inspector General.  
Rae Hutchison served as the project leader for this study.  Other 
Office of Evaluation and Inspections staff who conducted the study 
include Dennis Tharp.  Office of Investigations staff also participated 
in the review.  Central office staff who provided support include 
Jordan R. Clementi, Kevin Farber, Lonie Kim, and Christine Moritz. 
Arizona State Medicaid Fraud Control Unit:  2015 Onsite Review (OEI-07-15-00280)                                   26 
     
Office of Inspector General
http://oig.hhs.gov  
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95452, as  
amended, is  to protect the integrity of the Department of  Health and Human Services  
(HHS) programs, as  well  as the health  and welfare of individuals served by those programs.  
This statutory mission is carried  out through a nationwide network of audits, investigations,  
and inspections conducted by the following operating components: 
Office of Audit Services 
The Office  of  Audit Services  (OAS) provides auditing services  for HHS, either by  conducting  
audits  with its own audit resources or by  overseeing  audit work done by others.  Audits  
examine the performance of HHS programs and/or its grantees and contractors in carrying  
out their respective responsibilities and are intended  to provide independent assessments of 
HHS programs and operations.  These assessments help reduce waste, abuse, and  
mismanagement and promote economy and efficiency  throughout  HHS. 
Office of Evaluation and Inspections 
The Office  of  Evaluation and Inspections (OEI)  conducts national evaluations to  provide 
HHS, Congress, and the public with timely, useful, and reliable information on significant 
issues.  These evaluations focus on preventing fraud,  waste, or abuse  and promoting  
economy, efficiency, and effectiveness of departmental programs.  To promote impact, OEI 
reports also present practical recommendations for improving program operations.  
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations  
of fraud and misconduct  related to HHS programs, operations, and individuals.  With  
investigators working in all 50 States and the District of Columbia, OI  utilizes its resources 
by actively  coordinating with the Department  of Justice  and other Federal, State, and local 
law enforcement authorities.  The investigative efforts of OI often lead to  criminal 
convictions, administrative sanctions,  and/or  civil monetary  penalties.  
Office of Counsel to the Inspector General 
The Office of Counsel to the  Inspector  General (OCIG) provides general legal services to 
OIG, rendering  advice and opinions on HHS programs and operations and  providing all  
legal support for OIGs  internal operations.  OCIG represents  OIG in all civil and 
administrative fraud and  abuse cases involving HHS programs, including False Claims Act, 
program exclusion, and civil monetary penalty cases.  In  connection with these cases, OCIG 
also negotiates and monitors corporate integrity agreements.  OCIG renders advisory 
opinions, issues compliance program  guidance, publishes fraud alerts, and provides other  
guidance  to  the health care industry concerning the anti-kickback statute and other  OIG  
enforcement authorities.