U.S. Department of Health and Human Services 
 
Office of Inspector General 
 
 
 
 
Louisiana Medicaid Fraud 
Control Unit: 2020 Inspection  
 
 
 
 
 
Suzanne Murrin 
Deputy Inspector General for Evaluation and Inspections 
August 2021, OEI-12-20-00650  U.S. Department of Health and Human Services 
O  ffice of Inspector General 
   
Report in Brief 
 
Au gust 2021, OEI-12-20-00650 
 
Louisiana Medicaid Fraud 
Louisiana Medicaid Fraud Control Unit:  
Control Unit (MFCU or Unit) 
2020 Inspection 
Case Outcomes 
Federal Fiscal Years 2018-2020  
What OIG Found 
  227 indictments  We found that the Louisiana Unit generally adhered to the performance 
standards and complied with applicable laws, regulations, and policy 
  162 convictions 
transmittals during Federal fiscal years (FYs) 2018-2020, with one exception: 
  50 civil settlements and 
  One case in our review of case files was ineligible for Federal 
judgments 
matching funds during the review period. 
  $48.9 million in recoveries  
We also identified two beneficial practices that may be useful as a model to 
  other Units. 
  The Unit hired an outreach coordinator to promote the Units 
Unit Snapshot 
mission among its stakeholders. 
The Unit is part of the Louisiana 
Department of Justices Criminal    The Unit and a neighboring Unit sponsored combined training 
Division. 
events for employees of both Units. 
The 64-person Unit staff36 
What OIG Recommends and How the Unit Responded 
investigators, 12 attorneys,  
To address the one finding, we recommend that the Louisiana Unit repay 
8 auditors, and 8 support staffis 
Federal matching funds spent on the case that was ineligible for Federal 
located in Baton Rouge, Lafayette, 
funding.  The Unit concurred with our recommendation. 
Monroe, and Shreveport.  
 
     
 TABLE OF CONTENTS 
 
 
 
BACKGROUND  1 
Methodology 
PERFORMANCE ASSESSMENT  5 
Case Outcomes  5 
The Unit reported 227 indictments, 162 convictions, and 50 civil settlements and judgments 
for fiscal years 2018-2020 
The Unit reported total recoveries of $48.9 million for fiscal years 2018-2020 
Performance Standard 1: Compliance with requirements  6 
On the basis of the information we reviewed, the Unit generally complied with applicable laws, 
regulations, and policy transmittals, with one exception 
One case in our review of case files was ineligible for Federal matching funds during the 
review period 
Performance Standard 2: Staffing  6 
During our review period, the Unit maintained reasonable staff levels and employed staff 
consistent with levels in accordance with its approved budget 
Performance Standard 3: Policies and procedures  7 
The Unit maintained a policies and procedures manual specific to its operations; this manual 
was available to all staff on a shared network drive 
Performance Standard 4: Maintaining adequate referrals  7 
The Unit took steps to maintain its referrals of fraud and of patient abuse or neglect 
The Unit hired an outreach coordinator to promote the Units mission among its stakeholders 
Performance Standard 5: Maintaining a continuous case flow    8 
The Unit maintained a continuous case flow 
Performance Standard 6: Case mix  8 
During our review period, the Unit investigated 1,750 cases, of which 1,301 involved fraud and  
449 involved patient abuse or neglect; the cases covered 51 different provider types 
Performance Standard 7: Maintaining case information  8 
The Unit maintained case files in an effective manner and retained a case management system 
that allowed access to case information 
 
  Performance Standard 8: Cooperation with Federal authorities on fraud cases  9
The Unit cooperated at a high level with its Federal partners 
Performance Standard 9: Program recommendations  9
During our review period, the Unit made a program recommendation to the State Medicaid 
agency 
Performance Standard 10: Agreement with Medicaid agency  9
 The Units memorandum of understanding with the State Medicaid agency reflected current 
practice, policy, and legal requirements  
Performance Standard 11: Fiscal control  9
In our limited review, we identified no significant deficiencies in the Units fiscal control of its 
resources during our review period 
Performance Standard 12: Training  10
The Unit maintained a training plan for each professional discipline 
The Unit and a neighboring Unit sponsored combined training events for employees of both 
Units 
CONCLUSION and RECOMMENDATION  11
Repay Federal matching funds spent on the case that was ineligible for Federal funding  11
UNIT COMMENTS and OIG RESPONSE  12
DETAILED METHODOLOGY   13
APPENDICES  16
A.  Referrals by Source for Fiscal Years 2018-2020  16
B.  Unit Comments  17
ACKNOWLEDGMENTS AND CONTACT  18
ABOUT THE OFFICE OF INSPECTOR GENERAL  19
 
   
BACKGROUND 
 
 
Objectives 
To examine the performance and operations of the Louisiana Medicaid Fraud 
Control Unit (MFCU or Unit). 
Medicaid Fraud Control Units 
Medicaid Fraud Control Units investigate (1) Medicaid provider fraud and (2) patient 
abuse or neglect in facility settings and prosecute those cases under State law or refer 
them to other prosecuting offices.1, 2, 3  Under the Social Security Act (SSA), a MFCU 
must be a single, identifiable entity of State government, separate and distinct 
from the State Medicaid agency, and employ one or more investigators, attorneys, 
and auditors.4  Each State must operate a MFCU or receive a waiver.5   
Currently, 50 States, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands 
operate MFCUs.6  Each Unit receives a Federal grant award equivalent to 90 percent of 
total expenditures for new Units and 75 percent for all other Units.7  In Federal fiscal 
year (FY) 2020, combined Federal and State expenditures for the MFCUs totaled 
approximately $306 million.8   
   
_____________________________________________________________________________________________________________________________ 
1 SSA  1903(q)(3).  Regulations at 42 CFR  1007.11(b)(1) clarify that a Units responsibilities include the 
review of complaints of misappropriation of patients private funds in health care facilities. 
2 As of December 27, 2020, MFCUs may also receive Federal financial participation to investigate and 
prosecute abuse or neglect of Medicaid beneficiaries in a noninstitutional or other setting.  Consolidated 
Appropriations Act, 2021, Public Law 116-260, Division CC, Section 207. 
3 References to State in this report refer to the States, the District of Columbia, and the U.S. territories. 
4 SSA  1903(q). 
5 SSA  1902(a)(61). 
6 The territories of American Samoa, Guam, and the Northern Mariana Islands have not established Units. 
7 SSA  1903(a)(6).  For a Units first 3 years of operation, the Federal Government contributes 90 percent 
of funding, and the State contributes 10 percent.  Thereafter, the Federal Government contributes 75 
percent, and the State contributes 25 percent. 
8 OIG analysis of MFCU annual statistical reporting data for FY 2020.  The FY 2020 was from October 1, 
2019, through September 30, 2020. 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Background | 1  OIG Grant Administration and Oversight of Medicaid Fraud 
Control Units 
The Office of Inspector General (OIG) administers the grant award to each Unit and 
provides oversight of Units.9, 10  As part of its oversight, OIG conducts desk reviews of 
each Unit as part of the annual recertification process.  OIG also conducts periodic 
inspections and reviews.  Finally, OIG provides ongoing training and technical support 
to the Units. 
In its annual recertification desk review, OIG examines the Units reapplication 
materials, case statistics, and questionnaire responses from Unit stakeholders.  
Through the recertification review, OIG assesses a Units performance, as measured by 
the Units adherence to published performance standards;11 the Units compliance 
with applicable laws, regulations, and OIG policy transmittals;12 and the Units case 
outcomes. 
OIG further assesses Unit performance by conducting inspections and reviews on 
selected Units.  These inspections and reviews result in public reports of findings and 
recommendations for improvement.  In these reports, OIG may also provide 
observations regarding Unit operations and practices, including beneficial practices 
that may be useful to share with other Units.  Finally, OIG provides training and 
technical assistance to Units during inspections and reviews, as appropriate, and on 
an ongoing basis. 
Louisiana MFCU 
The Unit is an autonomous entity within the Criminal Division of the Louisiana 
Department of Justice (LA DOJ).  The Unit has a main office, headquartered in Baton 
Rouge, and three satellite offices, located in Lafayette, Monroe, and Shreveport.  At 
the time of our inspection, the Unit employed 64 staff36 investigators (including the 
chief investigator, 5 investigative teams each led by a different supervisory 
investigator, and an operations manager), 12 attorneys (including the director and  
2 supervising attorneys), 8 auditors, and 8 support staff (including 1 outreach 
_____________________________________________________________________________________________________________________________ 
9 As part of grant administration, OIG receives and examines financial information from Units, such as 
budgets and quarterly and final Federal Financial Reports that detail MFCU income and expenditures. 
10 The SSA authorizes the Secretary of Health and Human Services to award grants (SSA  1903(a)(6)) and to 
certify and annually recertify the Units (SSA  1903(q)).  The Secretary delegated these authorities to OIG in 
1979. 
11 MFCU performance standards are published at 77 Fed. Reg. 32645 (June 1, 2012) and are located at 
https://oig.hhs.gov/authorities/docs/2012/PerformanceStandardsFinal060112.pdf.  The performance 
standards were developed by OIG in conjunction with the MFCUs and were originally published at 59 Fed. 
Reg. 49080 (Sept. 26, 1994). 
12 OIG occasionally issues policy transmittals to provide guidance and instruction to MFCUs.  Policy 
transmittals are located at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/index.asp.  
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Background | 2  coordinator).13  In its 4 offices across Louisiana, the MFCU staffed 53 employees in 
Baton Rouge, 6 in Lafayette, 4 in Monroe, and 1 in Shreveport. 
Referrals 
When the Unit receives referrals, the Units support staff assigns them to one of seven 
Unit attorneys through the Units case management system.  Each attorney screens 
his/her assigned referrals to determine whether the referrals should be opened as 
cases and sends these case recommendations to the chief investigator and operations 
manager.  The chief investigator makes the final decision to open referrals as cases by 
approving the Units opening memorandum.     
Investigations and Prosecutions 
After the Unit opens a case, the Units operations manager assigns an investigator, 
attorney, and auditor to the case.  Throughout the investigation, the investigator and 
his/her supervisory investigator meet quarterly with Unit management to discuss the 
progress of the case.  If warranted, the assigned attorney, in consultation with the U.S. 
Attorneys Offices or the District Attorneys Office, prosecutes the case.   
Louisiana Medicaid Program 
The Louisiana Department of Health (LDH) administers the States Medicaid program. 
As of July 1, 2019, 90 percent of the Louisiana Medicaid programs beneficiaries were 
enrolled in a managed care plan for some or all of the beneficiarys care.14  In FY 2020, 
Louisianas total Medicaid expenditures were $12.9 billion.15  The LDHs Medicaid 
program integrity unit is responsible for identifying potential fraud cases and 
submitting them to the Louisiana Unit. 
Prior OIG Report 
OIG conducted a previous onsite review of the Louisiana Unit in 2012.16  In that 
review, OIG found that (1) 28 percent of the Units case files lacked documentation in 
_____________________________________________________________________________________________________________________________ 
13 The Unit had three directors during our review period of FYs 2018-2020.  In July 2018, the director left, and 
a new director served until June 2019.  The current director accepted the position beginning in July 2019. 
14 Kaiser Family Foundation, Share of Medicaid Population Covered under Different Delivery Systems, 
https://www.kff.org/medicaid/state-indicator/share-of-medicaid-population-covered-under-different-
delivery-
systems/?currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22,%22sort%22:%22asc%22%7
D. Accessed on February 19, 2021. 
15 OIG, MFCU Statistical Data for FY 2020, https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2020-statistical-chart.pdf.   Accessed on March 22, 2021. 
16 OIG, Louisiana State Medicaid Fraud Control Unit: 2012 Onsite Review, https://oig.hhs.gov/oei/reports/oei-
09-12-00010.pdf.  Accessed on February 17, 2021. 
 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Background | 3  accordance with the Units periodic supervisory reviews, while 22 percent of the Units 
case files did not have any documentation of periodic supervisory reviews at all;   
(2) the Unit did not refer 14 percent of sentenced providers to OIG for program 
exclusion within an appropriate timeframe; (3) the Unit had not updated its 
memorandum of understanding (MOU) with the LDH to reflect current law and 
practice; and (4) the Unit did not report its program income appropriately.   
In its report, OIG recommended that the Unit (1) revise its policies and procedures to 
ensure that periodic supervisory reviews are documented in Unit case files; (2) ensure 
that it refers all sentenced providers for exclusion to OIG within an appropriate 
timeframe; (3) revise its MOU with the LDH to reflect current law and practice; and  
(4) ensure that all program income is reported properly.  On the basis of information 
received from the Unit in 2013, OIG considered the recommendations implemented. 
Methodology 
OIG conducted the inspection of the Louisiana MFCU in December 2020.  Due to the 
COVID-19 public health emergency, the OIG team was not able to conduct the 
inspection onsite as planned and conducted the inspection remotely.  Our inspection 
covered the 3-year period of FYs 2018-2020.  We based our inspection on an analysis 
of data and information from the following 6 sources: (1) Unit documentation; 
(2) financial documentation; (3) structured interviews with key stakeholders; 
(4) structured interviews with the Units managers and selected staff; (5) a review of a 
random sample of 98 case files from the 1,682 nonglobal case files that were open at 
some point during our review period; and (6) a review of all convictions submitted to 
OIG for program exclusion and all adverse actions submitted to the National 
Practitioner Data Bank (NPDB) during our review period.  We were unable to observe 
Unit operations.  In examining the Units operations and performance, we applied the 
published performance standards, but we did not assess adherence to every 
performance indicator for every standard.  (See the Detailed Methodology.) 
Standards 
We conducted this inspection in accordance with the Quality Standards for Inspection 
and Evaluation issued by the Council of the Inspectors General on Integrity and 
Efficiency.  These inspections differ from other OIG evaluations in that they support 
OIGs direct administration of the MFCU grant program, but they are subject to the 
same internal quality controls as are other OIG evaluations, including internal and 
external peer review. 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Background | 4  PERFORMANCE ASSESSMENT  
 
In assessing the performance and operations of the Louisiana Unit, OIG 
identified the Units case outcomes and found that the Unit generally 
complied with all legal requirements except that we made one 
compliance-related finding.  For each of the performance standards, we 
made a finding and/or observation(s), including highlighting two 
beneficial practices.   
CASE OUTCOMES17   
The Unit reported 227 indictments, 162 convictions, and 50 civil 
Observations  settlements and judgments for FYs 2018-2020.  Of the 162 convictions, 
131 involved provider fraud and 31 involved patient abuse or neglect.   
 
 
The Unit reported total recoveries of $48.9 million for FYs 2018-2020.  
 
 
Source: OIG analysis of Unit statistical data, FYs 2018-2020. 
Note: Global civil recoveries derive from civil settlements or judgments in global cases, which are 
cases that involve the U.S. Department of Justice and a group of State MFCUs and are facilitated by 
the National Association of Medicaid Fraud Control Units. 
_____________________________________________________________________________________________________________________________ 
17 OIG provides information on MFCU operations and outcomes but does not direct or encourage MFCUs to 
investigate or prosecute a specific number of cases.  MFCU investigators and prosecutors should apply 
professional judgment and discretion in determining what criminal and civil cases to pursue. 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Performance Assessment | 5  STANDARD 1  A Unit conforms with all applicable statutes, regulations, and policy 
  directives. 
 
On the basis of the information we reviewed, the Unit generally 
complied with applicable laws, regulations, and policy transmittals, with 
one exception. 
One case in our review of case files was ineligible for Federal matching 
Finding 
funds during the review period.  According to statute and regulations in 
effect during our review period, MFCUs can receive Federal funds only for 
the investigation and prosecution of cases of patient abuse or neglect, 
including misappropriation of funds or property, that occur in Medicaid-
funded health care facilities or in board and care facilities.18  From our 
review of sampled case files that were open during our review period, we 
found one case of alleged misappropriation of funds that did not occur in 
a Medicaid-funded facility or board and care facility, and was therefore
according to statute and regulationsnot eligible for Federal financial 
participation (FFP).19  As a result, costs associated with this case were not 
eligible for FFP. 
STANDARD 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. 
 
During our review period, the Unit maintained reasonable staff levels 
Observation 
and employed staff consistent with levels in accordance with its 
approved budget.  The Unit was approved by OIG for 69-70 staff and 
employed between 64-67 staff over the course of the 3-year review 
period.   
 
 
 
 
 
_____________________________________________________________________________________________________________________________ 
18 SSA  1903(a)(6) and (q)(4)(A); 42 CFR  1007.11(b) and 1007.19(d)(1).  
19 Although the case identified in the inspection was not eligible for FFP under existing statute during the 
review period, Division CC, Section 207 of the Consolidated Appropriations Act, 2021, Public Law 116-260 
(December 27, 2020), amended Section 1903(q)(4)(A)(ii) of the SSA to expand MFCU statutory grant 
authority to investigate and prosecute patient abuse or neglect of Medicaid beneficiaries in noninstitutional 
or other settings. 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Performance Assessment | 6  STANDARD 3  A Unit establishes written policies and procedures for its operations 
  and ensures that staff are familiar with, and adhere to, policies and 
procedures. 
 
The Unit maintained a policies and procedures manual specific to its 
Observation 
operations; this manual was available to all staff on a shared network 
drive.  The Unit reviewed and revised its entire policies and procedures 
manual in October 2016.  At the time of our inspection, the Unit was 
drafting an updated manual, which was planned for completion in 2021.20 
Unit management reported to us that the Unit instructs (1) newly hired 
employees to read the policies and procedures manual during the Units 
new employee orientation process and (2) Unit supervisors to ensure 
their subordinate employees are adhering to the Units policies and 
procedures.  
STANDARD 4  A Unit takes steps to maintain an adequate volume and quality of 
  referrals from the State Medicaid agency and other sources. 
 
The Unit took steps to maintain its referrals of fraud and of patient 
Observations 
abuse or neglect.  For its fraud referrals, the Unit communicated regularly 
with the LDHs Medicaid program integrity unit by conducting bimonthly 
 
meetings, which included discussions about referral issues, potential 
cases, and data mining.  Also, since the Unit directly receives referrals 
from the five Medicaid managed care organizations (MCOs) in the State, 
the Unit communicated quarterly with the MCOs to encourage referrals.  
For its patient abuse or neglect referrals, the Unit downloaded and 
screened incident reports directly from the statewide incident 
management system maintained by the LDHs Health Standards Section.21  
Appendix A includes all the Units sources of referrals for fraud and for 
patient abuse or neglect during FYs 2018-2020. 
The Unit hired an outreach coordinator to promote the Units mission 
Beneficial Practice 
among its stakeholders.  In FY 2020, the Unit hired an outreach 
coordinator to promote the Units mission among its various stakeholders, 
including nursing homes, rehabilitation facilities, local law enforcement 
agencies, and other State agencies.  The outreach coordinators 
responsibilities are to (1) develop outreach training regarding the Units 
mission; (2) present this training to the Units stakeholders; (3) coordinate 
_____________________________________________________________________________________________________________________________ 
20 The Unit completed the update to its policies and procedures manual in May 2021. 
21 The Health Standards Section of the Louisiana Department of Health is responsible for the licensing of 
Louisianas health care facilities that are subject to licensing statutes.  The Health Standards Section also 
conducts certification surveys and complaint surveys of certified health care facilities in the Medicaid 
program. 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Performance Assessment | 7  with the LA DOJ press office to draft and disseminate public press releases 
of the Units accomplishments; and (4) act as the Units liaison to receive 
referrals from stakeholders.  
STANDARD 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. 
 
The Unit maintained a continuous case flow.  Our review of the Units 
Observation 
case files found no significant delays in the completion of the 
investigations or in the subsequent prosecutions/settlements.  Further, 
nearly all the case files contained appropriate supervisory approval for 
documentation of case openings and applicable case closings as well as 
applicable quarterly case file reviews. 
 
STANDARD 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. 
 
During our review period, the Unit investigated 1,750 cases of which 
Observation 
1,301 involved fraud and 449 involved patient abuse or neglect; the 
cases covered 51 different provider types.  The Units cases involved a 
variety of provider types, including personal care services, dentists, clinical 
social workers, and mental health facilities.   
STANDARD 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. 
 
The Unit maintained case files in an effective manner and retained a 
Observation 
case management system that allowed access to case information.  
Nearly 20 years ago, the Unit created its own electronic case management 
 
system, which was made available for all Unit staff to record and track 
case information.  OIG examined the Units electronic case management 
system by reviewing the random sample of 98 case files open during our 
review period.  In addition to assessing whether the system was efficient, 
we determined whether the case files contained the appropriate 
documentation, such as opening and closing documents, interview 
summaries, investigative activity summaries, and quarterly supervisory 
reviews.  We also consulted Unit staff to allow them to explain any 
occasional missing documentation.  In OIGs professional judgment, the 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Performance Assessment | 8  Units case files were maintained in an effective manner, and the case 
management system allowed efficient access to case information. 
STANDARD 8  A Unit cooperates with OIG and other Federal agencies in the 
  investigation and prosecution of Medicaid and other health care fraud. 
 
The Unit cooperated at a high level with its Federal partners.  Both OIG 
Observation 
and Unit management reported a strong working relationship between 
  them.  During our review period, the Unit and OIG agents worked on  
52 joint cases, including seven cases that were investigated jointly with 
the Gulf Coast Strike Force.  Additionally, all three U.S. Attorneys Offices 
in Louisiana noted the Units valuable assistance in resolving Federal 
health care fraud cases.   
STANDARD 9  A Unit makes statutory or programmatic recommendations, when 
  warranted, to the State government. 
 
During our review period, the Unit made a program recommendation to 
Observation 
the State Medicaid agency.  During our review period, the Unit identified 
a concern that program rules permitted mental health providers to bill an 
excessive number of hours in a single day.  The Unit recommended that 
the LDH prohibit individual mental health providers from receiving 
Medicaid reimbursement for working more than 12 hours in a single day, 
and the LDH implemented the Units recommendation. 
STANDARD 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. 
 
The Units MOU with the State Medicaid agency reflected current 
Observation 
practice, policy, and legal requirements.  The Unit finalized its current 
MOU with the Medicaid agency in December 2019. 
 
STANDARD 11  A Unit exercises proper fiscal control over its resources. 
 
 
In our limited review, we identified no significant deficiencies in the 
Observation 
Units fiscal control of its resources during our review period.  From the 
responses to a detailed fiscal controls questionnaire and from follow-up 
with Unit officials, we identified no significant issues related to the Units 
budget process, accounting system, case management, procurement, 
electronic data security, property, or personnel. 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Performance Assessment | 9   
STANDARD 12  A Unit conducts training that aids in the mission of the Unit. 
 
 
The Unit maintained a training plan for each professional discipline.  
Observations 
The Unit maintained an annual training plan that required Unit attorneys, 
investigators, and auditors to complete an annual minimum number of 
training hours.     
The Unit and a neighboring Unit sponsored combined training events 
Beneficial Practice 
for employees of both Units.  Since 2014, the Louisiana Unit and the 
Mississippi Unit alternated in hosting a combined training for their 
employees.  The Louisiana Unit hosted the training in 2014 and 2019, 
while the Mississippi Unit hosted in 2017.  The trainings included case 
studies, statistical trends, and roundtable discussions.  
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Performance Assessment | 10   
CONCLU SION AND RECOMMENDATION 
 
 
The Louisiana Unit reported strong case outcomes for FYs 2018-2020.  OIG observed 
that a number of positive practices may have contributed to the Units success, 
including strong collaboration with Federal law enforcement. 
From the information we reviewed, we found that the Louisiana Unit generally 
complied with applicable legal requirements, except that we found one case in our 
review of case files that was ineligible for Federal matching funds during the review 
period.  
To address the finding identified in this report, we made the following 
recommendation to the Louisiana Unit. 
We recommend that the Louisiana Unit: 
Repay Federal matching funds spent on the case that was 
ineligible for Federal funding 
The Unit should work with OIG to identify staff hours and expenditures associated 
with investigating the Units ineligible case and repay those Federal matching funds.  
   
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Conclusion and Recommendation | 11    
UNIT COMMENTS AND OIG RESPONSE 
 
 
 
The Louisiana Unit concurred with our recommendation to repay the Federal 
matching funds spent on the Units case that was ineligible for Federal funding.  The 
Unit stated that it identified the staff time attributed to the case and is working to 
repay the matching funds to the Federal government. 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Unit Comments and OIG Response | 12   
DETAILED METHODOLOGY 
 
 
Data Collection and Analysis 
We collected and analyzed data from the six sources listed below to identify any 
opportunities for improvement and instances in which the Unit did not adhere to the 
performance standards or was not operating in accordance with laws, regulations, or 
policy transmittals.22  We also used the data sources to make observations about the 
Units case outcomes as well as the Units operations and practices concerning the 
performance standards.  In examining the Units operations and performance, we 
applied the published performance standards, but we did not assess adherence to 
every performance indicator for every standard. 
Review of Unit Documentation 
Prior to the inspection, we reviewed the recertification analysis for FYs 2018-2020, 
which involved examining the Units recertification materials, including (1) the Unit 
directors recertification questionnaires, (2) the Units MOU with the State Medicaid 
agency (LDH), (3) the LDHs Medicaid program integrity directors questionnaires, and 
(4) the OIG Special Agent in Charge questionnaires.  We also reviewed the Units 
policies and procedures manual and the Units self-reported case outcomes and 
referrals included in its annual statistical reports for FYs 2018-2020.  We examined the 
recommendations from the 2012 OIG onsite review report and the Units 
implementation of those recommendations.  
Review of Unit Financial Documentation 
We conducted a limited review of the Units control over its fiscal resources.  Prior to 
the inspection, we analyzed the Units response to a questionnaire about internal 
controls and conducted a desk review of the Units financial status reports.  We 
followed up with the LA DOJ and Unit officials to clarify issues identified in the 
questionnaire about internal controls. 
Interviews With Key Stakeholders 
In November 2020, we interviewed key stakeholders, including officials in the LDHs 
Medicaid program integrity unit, Louisianas Community Living Ombudsman Program, 
and the three U.S. Attorneys offices.  We also interviewed officials from OIGs Office 
of Investigations.  We focused these interviews on the Units relationship and 
_____________________________________________________________________________________________________________________________ 
22 Because we conducted the inspection remotely due to the public health emergency, we were unable to 
observe the workspace and operations of the Units headquarters in Baton Rouge. 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Detailed Methodology | 13  interaction with the stakeholders, as well as opportunities for improvement.  We used 
the information collected from these interviews to develop subsequent interview 
questions for Unit management and staff. 
Interviews With Unit Management and Selected Staff 
We conducted structured interviews with the Units management and selected staff in 
December 2020.  Of the Unit management, we interviewed the director, the chief 
investigator, the two supervisory attorneys, and the operations manager.  Of the staff, 
we interviewed one attorney, four supervisory investigators, two investigators, and 
one auditor.  In addition, we interviewed the supervisor of the Unitthe Deputy 
Attorney General of the LA DOJs Criminal Division.  We asked these individuals 
questions related to (1) Unit 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; (4) clarification regarding 
information obtained from other data sources; and (5) the Units training and 
technical assistance needs. 
Review of Case Files 
To craft a sampling frame, we requested that the Unit provide us with a list of cases 
that were open at any time during FYs 2018-2020 and include the status of each case; 
whether the case was criminal, civil, or global; and the dates on which the case was 
opened and closed, if applicable.  The total number of cases was 1,750.   
We excluded all global cases from our review of the Units case files because global 
cases are civil false claims actions that typically involve multiple agencies, such as the 
U.S. Department of Justice and a group of State MFCUs.  We excluded 68 global 
cases, leaving 1,682 case files.   
We then selected a simple random sample of 98 cases from the population of 1,682 
cases.  This sample allowed us to make estimates of the overall percentage of case 
files with various characteristics with an absolute precision of +/- 10 percent at the 
95-percent confidence level.  We reviewed the 98 case files for adherence to the 
relevant performance standards and compliance with statute, regulation, and policy 
transmittals.  During the review of the sampled case files, we consulted MFCU staff to 
address any apparent issues with individual case files, such as missing documentation. 
Review of Unit Submissions to OIG and the National Practitioner 
Data Bank 
We also reviewed all convictions submitted to OIG during our review period so that 
convicted individuals could be excluded from programs (162) and all adverse actions 
submitted to the NPDB during our review period (159).  We reviewed whether the 
Unit submitted information on all sentenced individuals and entities to OIG for 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Detailed Methodology | 14  program exclusion and all adverse actions to the NPDB for FYs 2018-2020.  We also 
assessed the timeliness of the submissions to OIG and the NPDB.
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Detailed Methodology | 15   
APPENDIX A 
 
Unit Referrals by Source for Fiscal Years 2018-2020 
 
 
FY 2018  FY 2019  FY 2020  Grand Totals  
Fraud  Abuse or  Fraud  Abuse or  Fraud  Abuse or  Fraud  Abuse or 
Referral Source 
Neglect  Neglect  Neglect  Neglect 
Adult Protective 
0  0  0  2  0  0  0  2 
Services 
Anonymous  11  1  9  3  4  0  24  4 
HHS-OIG  6  0  4  0  6  0  16  0 
Law enforcement
3  1  2  0  1  0  6  1 
other  
Licensing Board  3  3  8  0  0  0  11  3 
Long-Term Care 
1  2  3  3  0  4  4  9 
Ombudsman  
Managed care 
238  0  442  1  121  1  801  2 
organizations 
Medicaid agency
570  7  706  8  387  2  1,663  17 
PI/SURS1 
Medicaid agency
80  0  186  12  3  7  269  19 
other 
Private citizen  84  13  66  18  1  3  151  34 
Private health 
0  0  1  0  0  0  1  0 
insurer 
Provider  11  0  17  4  8  0  36  4 
Provider 
0  0  1  0  1  0  2  0 
association 
State survey and 
28  2,861  20  5,447  6  1,744  54  10,052 
certification agency 
State agency
9  1  13  2  12  2  34  5 
other 
Other  10  1  13  2  34  19  57  22 
     Total  1,054  2,890  1,491  5,502  584  1,782  3,129  10,174 
     Annual Total  3,944  6,993  2,366  13,303 
Source: OIG analysis of Unit Annual Statistical Reports, FYs 201820. 
1 The abbreviation PI stands for program integrity; the abbreviation SURS stands for Surveillance and Utilization Review System. 
 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Appendix A | 16  L
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APPENDIX B: Unit Comments
Louisiana Medicaid Fraud Control Unit: 2020 Inspection
OEI-12-20-00650                      Appendix B | 17 ACKNOWLEDGMENTS AND CONTACT 
 
Acknowledgments 
Keith Peters of the Medicaid Fraud Policy and Oversight Division served as the team 
leader for this inspection.  Susan Burbach of the Medicaid Fraud Policy and Oversight 
Division also participated in the inspection.  Office of Evaluation and Inspections staff 
who provided support include Kevin Farber and Sarah Swisher.  
Two agents from the Office of Investigations also participated in the inspection and 
provided technical assistance to the Unit.  
This report was prepared under the direction of Richard Stern, Director of the 
Medicaid Fraud Policy and Oversight Division. 
Contact 
To obtain additional information concerning this report, contact the Office of Public 
Affairs at Public.Affairs@oig.hhs.gov.  OIG reports and other information can be found 
on the OIG website at oig.hhs.gov. 
Office of Inspector General 
U.S. Department of Health and Human Services 
330 Independence Avenue, SW 
Washington, DC 20201 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  Acknowledgments and Contact | 18  ABOUT THE OFFICE OF INSPECTOR GENERAL 
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-
452, 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 beneficiaries 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: 
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 audits help reduce waste, abuse, and mismanagement and promote economy 
and efficiency throughout HHS. 
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. 
The Office of Investigations (OI) conducts criminal, civil, and administrative
investigations of fraud and misconduct related to HHS programs, operations, and 
beneficiaries.  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. 
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. 
Louisiana Medicaid Fraud Control Unit: 2020 Inspection 
OEI-12-20-00650  About OIG | 19