Department of Health and Human Services 
 
 
OFFICE OF 
 
INSPECTOR GENERAL 
 
 
 
 
 
 
 
 
M S M
ARYLAND  TATE  EDICAID 
 
 
F C U :
RAUD  ONTROL  NIT   
 
 
2016 O R  
NSITE  EVIEW
 
 
 
 
 
 
 
Suzanne Murrin 
Deputy Inspector General  
for Evaluation and Inspections 
 
September 2016 
OEI-07-16-00140   
   
EXECUTIVE SUMMARY:  MARYLAND STATE MEDICAID FRAUD CONTROL 
UNIT:  2016 ONSITE REVIEW 
OEI-07-16-00140 
 
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 Units adherence to the 12 MFCU performance standards 
and compliance with applicable Federal statutes and regulations. 
 
HOW WE DID THIS STUDY 
We conducted an onsite review of the Maryland Unit in March 2016.  We based our 
review on analysis of data from seven sources:  (1) policies, procedures, 
and documentation related to the Units operations, staffing, and caseload; (2) financial 
documentation for fiscal years (FYs) 2013 through 2015; (3) structured interviews with 
key stakeholders; (4) a survey of Unit staff; (5) structured interviews with the Units 
management; (6) a sample of files for cases that were open in FYs 2013 through 2015; 
and (7) observation of Unit operations. 
 
WHAT WE FOUND 
For FYs 2013 through 2015, the Maryland Unit reported 42 convictions, 61 civil 
judgments and settlements, and combined criminal and civil recoveries of over 
$70 million.  Our review found that the Unit was generally in compliance with applicable 
laws, regulations, and policy transmittals.  The Unit maintained proper fiscal control of 
its resources and developed an internal boot camp training for staff.  However, we 
identified three areas where the Unit should improve its operations.  First, 22 percent of 
the case files lacked documentation of at least one required periodic supervisory review.  
Second, although the Unit reported all convictions and adverse actions to Federal 
partners, it did not report some within required timeframes.  Finally, the Units staff 
levels were significantly below the number of staff that the Unit requested and OIG 
approved.  Over one-quarter of the Units approved positions were vacant, including two 
supervisory positions. 
 
WHAT WE RECOMMEND  
We recommend that the Maryland Unit:  (1) ensure it conducts and documents 
supervisory reviews of Unit case files according to the Units policies and procedures, 
(2) ensure that convictions and adverse actions are consistently reported to Federal 
partners within required timeframes, and (3) maintain staff levels in accordance with 
staffing allocations the Unit requested and OIG approved.  The Unit concurred with all 
three recommendations. 
 
 
   
   
   
 
TABLE OF CONTENTS 
Objective ......................................................................................................1 
Background ..................................................................................................1 
Methodology ................................................................................................4 
Findings........................................................................................................5 
For FYs 2013 through 2015, the Unit reported 42 criminal 
convictions, 61 civil judgments and settlements, and combined 
criminal and civil recoveries of over $70 million ............................5 
Twenty-two percent of the case files lacked documentation of at 
least one required periodic supervisory review; however, 
supervisors documented the opening and closing of cases ..............6 
Although the Unit reported all convictions to OIG and all adverse 
actions to the National Practitioner Data Bank (NPDB), it did not 
report some convictions and adverse actions within required 
timeframes ........................................................................................7 
At the time of our review, the Units staff levels were significantly 
below the number of staff that the Unit requested and OIG 
approved ...........................................................................................9 
The Unit maintained proper fiscal control of its resources ..............9 
Other observation:  The Unit conducted boot camp training 
for new staff .....................................................................................9 
Conclusion and Recommendations ............................................................ 11 
Unit Comments and Office of Inspector General Response ..........12 
Appendixes ................................................................................................13 
A:  2012 Performance Standards ...................................................13 
B:  Unit Referrals by Referral Source for FYs 2013 Through 
2015................................................................................................17 
C:  Detailed Methodology ..............................................................18 
D:  Point Estimates and 95-Percent Confidence Intervals Based 
on Reviews of Case Files ...............................................................21 
E:  Unit Comments.........................................................................22 
Acknowledgments......................................................................................24 
   
   
OBJECTIVE 
To conduct an onsite review of the Maryland State Medicaid Fraud 
Control Unit (MFCU or Unit). 
BACKGROUND  
The mission of MFCUs is to investigate and prosecute Medicaid provider 
fraud and patient abuse or neglect under State law.1  The SSA requires 
each State to operate a MFCU, unless the Secretary of Health and Human 
Services (HHS) determines that operation of a Unit would not be 
cost-effective because minimal Medicaid fraud exists in a particular State 
and that 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 MFCUs.3 
Each Unit must employ an interdisciplinary staff that consists of at least an 
investigator, an auditor, and an attorney.4  Unit staff review referrals of 
provider fraud and patient abuse or neglect to determine their potential for 
criminal prosecution and/or civil action.  In fiscal year (FY) 2015, the 
50 Units collectively reported 1,553 convictions, 795 civil settlements or 
judgments, and approximately $745 million in recoveries.5, 6 
Units must meet a number of requirements established by the SSA and 
Federal regulations.  For example, each Unit must: 
  be a single, identifiable entity of State government, distinct from 
the single State Medicaid agency;7   
  develop a formal agreement, such as a memorandum of 
understanding, which describes the Units relationship with the 
State Medicaid agency;8 and   
                        ____________________________________________________________ 
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 SSA  1903(q)(6); 42 CFR  1007.13. 
5 Office of Inspector General (OIG), MFCU Statistical Data for Fiscal Year 2015.  
Accessed at http://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2015-statistical-chart.htm on February 17, 2016. 
6 All FY references in this report are based on the Federal FY (October 1 through     
September 30). 
7 SSA  1903(q)(2); 42 CFR  1007.5 and 1007.9(a). 
8 42 CFR  1007.9(d).  
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  1 
   
   
  have either statewide authority to prosecute cases or formal 
procedures to refer suspected criminal violations to an agency with 
such authority.9   
MFCU Funding 
Each MFCU is funded jointly by its State and the Federal government.  
Federal funding for the MFCUs is provided as part of the Federal 
Medicaid appropriation, but it is administered by OIG.10  Each Unit 
receives Federal financial participation equivalent to 75 percent of its total 
expenditures, with State funds contributing the remaining 25 percent.11  In 
FY 2015, combined Federal and State expenditures for the Units totaled 
$251 million, $188 million of which represented Federal funds.12   
Oversight of the MFCU Program 
The Secretary of HHS delegated to OIG the authority to administer the 
MFCU grant program.13  To receive Federal reimbursement, each Unit must 
submit an initial application to OIG for approval and be recertified each year 
thereafter.   
In annually recertifying the Units, OIG evaluates Unit compliance with 
Federal requirements and adherence to performance standards.  The Federal 
requirements for Units are contained in the SSA, regulations, and policy 
guidance.14  In addition, OIG has published 12 performance standards that it 
uses to assess whether a Unit is effectively performing its responsibilities.15  
The standards address topics such as staffing, maintaining adequate referrals, 
and cooperation with Federal authorities.  Appendix A contains the 
performance standards.   
OIG also performs periodic onsite reviews of the Units, such as this review 
of the Maryland MFCU.  During these onsite reviews, OIG evaluates Units 
compliance with laws, regulations, and policies, as well as adherence to the 
12 performance standards.  OIG also makes observations about best 
practices, provides recommendations to the Units, and monitors the 
implementation of the recommendations.  These evaluations differ from 
                        ____________________________________________________________ 
9 SSA  1903(q)(1). 
10 SSA  1903(a)(6)(B). 
11 Ibid.  
12 OIG, MFCU Statistical Data for Fiscal Year 2015.  Accessed at 
http://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2015-statistical-chart.htm on February 17, 2016.   
13 The SSA authorizes the Secretary of HHS to award grants to the Units 
(SSA  1903(a)(6)(B)); the Secretary delegated this authority to OIG.   
14 On occasion, OIG issues policy transmittals to provide guidance and instructions to 
MFCUs.   
15 77 Fed. Reg. 32645 (June 1, 2012).  Accessed at 
http://www.oig.hhs.gov/authorities/docs/2012/PerformanceStandardsFinal060112.pdf on 
April 7, 2016.   
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  2 
   
   
other OIG evaluations as they support OIGs direct administration of the 
MFCU grant program.  These evaluations are subject to the same internal 
quality controls as other OIG evaluations, including internal peer review. 
OIG provides additional oversight including the collection and dissemination 
of performance data, training, and technical assistance. 
Maryland MFCU 
The Unit, a division of the Maryland Office of the Attorney General, 
investigates and prosecutes cases of Medicaid fraud and patient abuse or 
neglect.  At the time of our March 2016 onsite review, the Unit employed 
28 staff members1 director, 1 senior civil attorney, 1 chief of 
investigations, 1 chief auditor, 11 investigators, 4 attorneys, 4 auditors, 
and 5 support staff.  The Unit director supervises the attorneys, the chief 
of investigations, and the chief auditor.  The chief of investigations 
supervises the investigators and the chief auditor supervises the auditors.  
The deputy director supervises the support staff.16  The Maryland Unit had 
total expenditures of approximately $3.7 million in combined State and 
Federal funds in FY 2015.17   
Referrals.  The Unit receives referrals from a variety of sources, including 
the State Medicaid Agency, other law enforcement agencies (e.g., county 
and city police departments), and private citizens.  Appendix B depicts 
Unit referrals by referral source for FYs 2013 through 2015.  An intake 
committee comprising the director, deputy director, senior civil attorney, 
senior criminal attorney, chief of investigations, and chief auditor meets 
monthly to review fraud referrals.  The intake committee decides whether 
the Unit will accept a fraud referral to be opened as a case.  The senior 
criminal attorney reviews each patient abuse and neglect referral to 
determine whether the matter is within the Units jurisdiction. 
Investigations and Prosecutions.  Opened fraud cases are assigned to 
criminal or civil teams, as appropriate.  Criminal teams include an attorney 
and three investigators, with assistance from an auditor as needed.  Civil 
teams include an attorney, an auditor, and an investigator.  The team 
develops an investigative plan and documents investigative and 
prosecutorial activities in case logs.  The attorney assigned to a fraud case 
is responsible for leading and directing the teams investigative activity 
and approving and finalizing an investigative plan.  The supervising 
                        ____________________________________________________________ 
16 The deputy director and senior criminal attorney positions were vacant at the time of 
our onsite review. 
17 OIG, MFCU Statistical Data for Fiscal Year 2015.  Accessed at 
http://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2015-statistical-chart.pdf on February 18, 2016. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  3 
   
   
attorney assigns opened patient abuse and neglect cases to an investigator 
with instructions outlining the initial case plan. 
Unit attorneys prosecute both criminal and civil cases.  Unit attorneys 
have the authority to prosecute civil cases in State court under the 
Maryland State False Claims Act.18  Unit attorneys may prosecute civil 
cases in Federal court in concert with the United States Attorneys Office, 
and may be designated as Special Assistant United States Attorneys.  
Previous Onsite Review 
In 2010, OIG published a report regarding its onsite review of the 
Maryland Unit.  OIG found that the Maryland Unit was in general 
compliance with all applicable Federal rules and regulations and the 12 
performance standards. 
METHODOLOGY 
Data Collection and Analysis 
We conducted the onsite review in March 2016.  We based our review on an 
analysis of data from seven sources:  (1) policies, procedures, and 
documentation related to the Units operations, staffing, and caseload; 
(2) financial documentation for FYs 2013 through 2015; (3) structured 
interviews with key stakeholders; (4) a survey of Unit staff; (5) structured 
interviews with the Units management; (6) a sample of files for cases that 
were open in FYs 2013 through 2015; and (7) observation of Unit 
operations.  Appendix C provides details of our methodology.   
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of the Inspectors General 
on Integrity and Efficiency. 
   
                        ____________________________________________________________ 
18 Md. Code, Health General,  2-601 through 2-611. 
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FINDINGS 
Our review of the Maryland Unit found that it was generally in 
compliance with applicable laws, regulations, and policy transmittals.  
However, 22 percent of case files lacked documentation of at least one 
required periodic supervisory review, and the Unit did not report some 
convictions and adverse actions to Federal partners within required 
timeframes.  In addition, the Unit did not maintain staff levels consistent 
with its approved budget. 
For FYs 2013 through 2015, the Unit reported 
42 criminal convictions, 61 civil judgments and 
settlements, and combined criminal and civil 
recoveries of over $70 million 
For FYs 2013 through 2015, the Unit reported 42 criminal convictions and 
61 civil judgments and settlements.  Table 1 provides details of the Units 
yearly convictions and civil judgments and settlements.  Of the Units 
42 convictions over the 3-year period, 29 involved provider fraud, and 
13 involved patient abuse or neglect.   
Table 1:  Maryland MFCU Criminal Convictions and Civil 
Judgments and Settlements, FYs 20132015 
3-Year 
Outcomes  FY 2013  FY 2014  FY 2015  Total 
Criminal Convictions  21  9  12  42 
Civil Judgments and Settlements  29  22  10  61 
Source:  OIG analysis of Unit-submitted documentation, 2016. 
The Unit reported criminal and civil recoveries of over $70 million for 
FYs 2013 through 2015ranging from nearly $7 million to almost $41.5 
million annually over the 3 years (shown in Table 2).  During the 3-year 
review period, global cases accounted for approximately 63 percent of 
the Units recoveries.19   
   
                        ____________________________________________________________ 
19 Global cases are civil false claims actions involving the U.S. Department of Justice 
and a group of State MFCUs.  The National Association of Medicaid Fraud Control Units 
(NAMFCU) facilitates the settlement of global cases. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  5 
   
   
 
Table 2:  Maryland MFCU Recoveries and Expenditures,                  
FYs 20132015 
Type of Recovery  FY 2013  FY 2014  FY 2015  3-Year Total 
Global Civil  $20,799,249  $23,105,238  $526,035  $44,430,521 
Nonglobal Civil  $1,333,851  $18,340,654  $1,246,923  $20,921,428 
Criminal  $289,086  $48,049  $4,996,364  $5,333,499 
     Total           
$22,422,185  $41,493,941  $6,769,321  $70,685,448 
Recoveries** 
     Total 
$2,839,746  $3,510,342  $3,697,014  $10,047,102 
Expenditures 
Source:  OIG analysis of Unit-submitted documentation, 2016. 
* Due to rounding, dollar figures for each category of recoveries do not always sum to the total recovery amount. 
** Recovery amounts vary from year to year due to particular settlements.  For example, $15 million of the Units 
nonglobal civil recoveries in FY 2014 came from the settlement of one pharmaceutical case.  Similarly, $4.7 million 
of the Units criminal recoveries in FY 2015 came from one criminal case. 
 
Marylands global recoveries declined from more than $23 million in 
FY 2014 to less than $1 million in FY 2015.  This is consistent with a 
national trend of declining civil health care fraud complaints and 
settlements, especially those involving pharmaceutical companies.20 
Twenty-two percent of the case files lacked 
documentation of at least one required periodic 
supervisory review; however, supervisors 
documented the opening and closing of cases 
Twenty-two percent of the Units case files lacked documentation of at 
least one periodic supervisory review required by Unit policy.21  
Performance Standards 5(b) and 7(a) state that supervisors should 
periodically review the progress of cases, consistent with Unit policies and 
procedures, ensure that each stage of an investigation and prosecution is 
completed in an appropriate timeframe, and note in the case file that the 
reviews take place.  Unit policy states that the director, deputy director, 
chief of investigations, chief auditor, and appropriate supervising attorney 
                        ____________________________________________________________ 
20 From the 1990s through the early 2000s, a significant number of pharmaceutical 
companies were the subject of large monetary settlements in civil fraud actions.  As a 
condition of those settlements, pharmaceutical companies were required to adopt 
corporate integrity agreements that were designed to prevent future abusive 
practices.  Other corporations have adopted voluntary compliance programs, promoted by 
OIG, which may have further reduced the incidence of fraud allegations.  See OIG 
Compliance Program Guidance for Pharmaceutical Manufacturers, 68 Fed. Reg. 23731 
(May 5, 2003), available at 
http://www.oig.hhs.gov/authorities/docs/03/050503FRCPGPharmac.pdf. 
21 Appendix D contains the point estimates and 95-percent confidence intervals for all 
estimates derived from our case file review. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  6 
   
   
are to meet quarterly to review progress of cases and document the 
outcomes of these quarterly reviews in the case logs.22   
We found that nearly all files contained documentation of supervisory 
approval to open and close cases.  Performance Standard 5(b) states that 
Unit supervisors should approve the opening and closing of cases.  The 
Units policy also requires that case opening and case closing 
documentation be maintained in case files.  Specifically, we found that 
97 percent of the Units case files included documentation of supervisory 
approval to open the cases.  Supervisory approval to open cases indicates 
that Unit supervisors are monitoring the intake of cases, thereby 
facilitating progress in the investigation.  All 88 closed case files in the 
sample included documentation of supervisory approval to close the 
cases.23  Supervisory approval of the closing of cases helps ensure the 
timely completion and resolution of cases. 
Although the Unit reported all convictions to OIG and 
all adverse actions to the National Practitioner Data 
Bank (NPDB), it did not report some convictions and 
adverse actions within required timeframes 
Performance Standard 8(f) states that 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.  Federal regulations require 
that Units report any adverse actions resulting from investigations or 
prosecutions of healthcare providers to the NPDB within 30 calendar days 
of the date of the final adverse action.24  Performance Standard 8(g) also 
states that the Unit should report qualifying cases to NPDB.25 
                        ____________________________________________________________ 
22 Maryland Attorney General, Criminal Division, Medicaid Fraud Control Unit, 
Policies and Procedures Manual, B. Case Updates, p. 33. 
23 All closed case files in our sample included documentation of supervisory approval to 
close the cases.  However, we cannot be certainbecause of sampling errorthat all of 
the Units closed case files in the review period included this documentation.  As a 
statistical matter, we are 95-percent confident that at least 96.0 percent of the closed cases 
in the population had documentation of supervisory approval to close the case. 
24 SSA  1128E(g)(1) and 45 CFR  60.5.   
25 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 HIPDB and the NPDB were merged during our 
review period (FYs 2013 through 2015); therefore, we reviewed the reporting of adverse 
actions under NPDB requirements.  See 78 Fed. Reg. 20473 (April 5, 2013).  Examples 
of final adverse actions include, but are not limited to, convictions, civil judgments (but 
not civil settlements), and program exclusions.  See 45 CFR  60.3. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  7 
   
   
The Unit did not report one-third of its convictions to OIG 
within the required timeframe 
The Unit did not report 15 of its 42 convictions (36 percent) to OIG within 
30 days of sentencing.  On average, the Unit reported these convictions 
50 days after the sentencing dates; 2 convictions were reported more than 
90 days after the sentencing dates.   
The Unit director explained that the late reporting of convictions to OIG 
was due to staff delays in submitting the necessary paperwork to OIG.  The 
director provided a copy of an email she sent to all Unit staff on 
September 30, 2014, stating that all convictions must be reported to OIG 
within 30 days of sentencing.  This action improved the Units timeliness in 
reporting convictions to OIG.  Of the 12 convictions with dates of 
sentencing after September 30, 2014, in the review period, only 1 was 
reported late.   
Late reporting of convictions to OIG delays the initiation of the program 
exclusion process, which may result in improper payments to providers by 
Medicare or other Federal health care programs or possible harm to 
beneficiaries.  However, our analysis found that no Medicare or Medicaid 
claims were paid to the late-reported providers. 
The Unit did not report two-thirds of its adverse actions to 
NPDB within the required timeframe 
The Unit did not report 28 of 42 adverse actions (67 percent) to NPDB 
within 30 days of the adverse action.  On average, the Unit reported 
adverse actions 84 days after the action.  Table 3 shows the number of 
adverse actions that the Unit reported to NPDB after the required 
timeframe.  
Table 3:  Number of Adverse Actions Reported to NPDB After Required Timeframe 
Federal Partner  Adverse Actions  Adverse Actions   Adverse Actions   Total  Adverse Actions  
Reported To  Reported Within 31 to  Reported Within 61 to  Reported More Than  Reported More Than 
60 Days After the  90 Days After the  90 Days After the  30 Days After the Action  
Action  Action  Action 
NPDB  15  7  6  28 
Source:  OIG analysis of Unit adverse actions and dates reported to NPDB, 2016. 
The Unit director explained that the late reporting of adverse actions to 
NPDB was due to staff error.  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.  If a Unit fails to report adverse actions to 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  8 
   
   
the NPDB, individuals may be able to find new healthcare employment 
with an organization that is not aware of their adverse actions. 
At the time of our review, the Units staff levels were 
significantly below the number of staff that the Unit 
requested and OIG approved 
According to Performance Standard 2, the Unit should maintain staff 
levels in accordance with the staffing levels approved in its budget.  As 
part of its oversight role, OIG approves the number of staff requested by 
the State in its annual budget.  For FY 2016, OIG approved 39 staff 
members.  At the time of our onsite review in March 2016, the Unit 
employed 28 staff members.  Over one-quarter of the Units approved 
positions were vacant, including two supervisory positions. 
Performance Standard 2 also states that a Unit must employ an appropriate 
number of staff to effectively investigate and prosecute an appropriate 
volume of case referrals and workload.  In the staff survey, 20 of 25 staff 
(80 percent) responded that the Unit did not have adequate staff and 
resources, given its caseload.  Specifically, two staff commented that 
when staff members left, cases were reassigned to remaining staff and that 
their increased workload impeded case progress.  Moreover, in 
October 2015, an official from the State Medicaid program integrity unit 
expressed concern with the Units responsiveness to referrals, and noted 
that the Unit had multiple vacancies.26 
The Unit maintained proper fiscal control of its 
resources 
The Unit maintained proper fiscal control of its resources during the 
review period, in accordance with the terms of Performance Standard 11.  
The Units financial documentation indicated that the Units requests for 
reimbursement for FYs 2013 through 2015 represented allowable, 
allocable, and reasonable costs.  In addition, the Unit maintained adequate 
internal controls relating to accounting, budgeting, personnel, 
procurement, property, and equipment.  
Other observation:  The Unit conducted boot camp 
training for new staff 
In FY 2014, the Unit developed an internal boot camp for all new staff.  
The training curriculum comprises 12 topics including civil and criminal 
procedure, interviewing, medical codes, and patient abuse and neglect.  
The training is conducted in person by experienced Unit staff in the form 
                        ____________________________________________________________ 
26 2015 Maryland Integrity/SURS Unit Questionnaire for Medicaid Fraud Control Unit 
recertification.  Referrals, p. 1, q. 7.  
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  9 
   
   
of 1 to 2 hour lectures per topic.  The Unit director considers the topics 
covered important in helping all new staff, regardless of position, develop 
a full understanding of the Units work.  One staff member who had 
completed the training remarked, The MFCU boot camp helped me to 
understand the legal side of the Unit and how my accounting experience 
would be used to assist with each of my assigned cases.   
   
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  10 
   
   
CONCLUSION AND RECOMMENDATIONS 
Our review of the Maryland Unit found that it was generally in 
compliance with applicable laws, regulations, and policy transmittals.  For 
FYs 2013 through 2015, the Maryland Unit reported 42 criminal 
convictions and 61 civil judgments and settlements and combined criminal 
and civil recoveries of over $70 million.  The Unit maintained proper 
fiscal control of its resources and developed an internal boot camp 
training for staff. 
However, we did identify three areas of concern.  Specifically, 22 percent 
of case files lacked documentation of at least one required periodic 
supervisory review.  In addition, the Unit did not report some convictions 
and adverse actions to Federal partners within required timeframes.  
Finally, the Units staff levels were significantly below the number of staff 
that the Unit requested and OIG approved.  Over one-quarter of the Units 
approved positions were vacant, including two supervisory positions. 
We recommend that the Maryland Unit:  
Ensure it conducts and documents supervisory reviews of Unit 
case files according to the Units policies and procedures  
Although most of the Units case files included documentation of 
supervisory approval for opening and closing cases, the Unit should take 
additional steps to ensure that its existing policy to document periodic 
supervisory reviews is followed in all case files.   
Ensure that convictions and adverse actions are consistently 
reported to Federal partners within required timeframes  
The Unit should ensure that convictions are consistently reported to OIG 
within 30 days of sentencing and that adverse actions are reported to 
NPDB within 30 days of the action.  The Unit may want to consider 
whether an automated reminder could be incorporated in the case 
management system to assist the Unit with timely reporting to Federal 
partners. 
Maintain staff levels in accordance with staffing allocations the 
Unit requested and OIG approved 
The Unit should develop a plan to promptly fill the more than one-quarter 
of its requested and approved positions that are currently vacant.    
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  11 
   
   
UNIT COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
The Maryland Unit concurred with all three of our recommendations. 
Regarding the first recommendation, the Unit stated that it has modified 
and implemented internal procedures to ensure periodic supervisory 
reviews are conducted and documented in two ways: (1) supervisors now 
have case files accessible during the quartertly reviews enabling 
supervisors to annotate the files with significant investigative 
recommendations while all team members are present, and (2) the Units 
Computer Information Specialist now attends the quarterly reviews and 
documents them in the Units database. 
Regarding the second recommendation, the Unit stated that it has updated 
procedures to include additional controls so that convictions and adverse 
actions are consistently reported to Federal partners within required 
timeframes.  Unit procedures now require the chief of investigations to 
report convictions to OIG and adverse actions to NPDB.  Further, 
procedures require the Units management associate to monitor the Units 
litigation schedule and verify that reporting occurred within required 
timeframes. 
Regarding the third recommendation, the Unit stated that it has attempted 
to fill open positions in accordance with requested and approved staffing 
allocations.  The Unit added that the Office of the Attorney General 
(OAG), which oversees the hiring of personnel, has committed to filling 
additional available positions promptly and that hiring for those additional 
positions is proceeding.  We appreciate the OAGs commitment to filling 
the positions, but recommend that the Unit work with the OIG oversight 
division to develop an action plan to identify a specific timetable for its 
hiring plans.   
The Units comments are provided in Appendix E.   
   
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  12 
   
   
APPENDIX A 
2012 Performance Standards27  
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.   
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. 
                        ____________________________________________________________ 
27 77 Fed. Reg. 32645, June 1, 2012. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  13 
   
   
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:  
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 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  14 
   
   
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 the 
Centers for Medicare & Medicaid Services (CMS). 
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. 
 
 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  15 
   
   
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.  
   
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  16 
   
   
APPENDIX B 
Unit Referrals by Referral Source for FYs 2013 Through 2015 
  FY 2013  FY 2014  FY 2015   
Abuse &  Abuse &  Abuse & 
Referral Source  Fraud  Fraud  Fraud  Total 
Neglect1  Neglect  Neglect 
State Medicaid 
agency  SUR/S  24  3  29  3  23  3  85 
or OMIG 
State Medicaid 
0  1  0  3  2  40  46 
agency  other 
Managed care 
10  0  1  0  7  0  18 
organizations 
State survey and 
certification  1  23  2  32  3  57  118 
agency 
Other State 
3  3  1  1  0  0  8 
agencies 
Licensing board  0  0  0  0  1  0  1 
Law enforcement  1  105  2  83  2  124  317 
Office of 
Inspector  1  2  1  0  0  2  6 
General 
Prosecutors  1  4  3  2  0  1  11 
Providers  0  14  2  8  2  2  28 
Provider 
0  0  0  0  0  0  0 
associations 
Private health 
10  0  1  0  0  0  11 
insurer 
Ombudsman  0  2  0  0  0  0  2 
Adult protective 
0  0  1  0  0  1  2 
services 
Private citizens  82  6  79  9  74  5  255 
MFCU hotline2  0  0  0  0  NA  NA  0 
Anonymous3  NA  NA  NA  NA  3  1  4 
Other  4  0  3  2  3  0  12 
   Total  137  163  125  143  120  236  924 
   
   Annual Total  300  268 356  
Source:  OIG analysis of Unit Quarterly and Annual Statistical Reports, FYs 20132015, 2016. 
1 The category of abuse & neglect referrals includes patient funds referrals. 
2 The referral source MFCU hotline was not a category reported on the FY 2015 Annual Statistical Report. 
3 The referral source Anonymous was not a category reported on the FY 2013 and FY 2014 Quarterly Statistical Reports. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  17 
   
   
APPENDIX C 
 
Detailed Methodology 
Data collected from the seven sources below was used to describe the 
caseload and assess the performance of the Maryland MFCU. 
Data Collection  
Review of Unit Documentation.  Prior to the onsite visit, we analyzed 
information 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 this information from several sources, including the Units 
quarterly and annual statistical reports, its annual reports, its recertification 
questionnaire, its policy and procedures manual, and its memorandum of 
understanding with the State Medicaid agency.  We requested any 
additional data or clarification from the Unit as necessary. 
Review of Unit Financial Documentation.  To evaluate internal control of 
fiscal resources, we reviewed policies and procedures related to the Units 
budgeting, accounting systems, cash management, procurement, property, 
and staffing.  We reviewed records in the Payment Management 
System (PMS) 28 and revenue accounts to determine the accuracy of the 
Federal Financial Reports (FFRs) for FYs 2013 through 2015.  We also 
obtained the Units claimed grant expenditures from its FFRs and the 
supporting schedules.  From the supporting schedules, we requested and 
reviewed supporting documentation for the selected items.   
We selected three purposive samples to assess the Units internal control 
of fiscal resources.  The three samples were structured as follows:   
1.  To assess the Units expenditures, we selected a purposive sample 
of 72 accounting records.  We selected routine and nonroutine 
transactions representing a variety of budget categories and 
payment amounts.   
2.  To assess inventory, we selected and verified a purposive sample of 
19 items from the current inventory list of 158 items.  To ensure a 
                        ____________________________________________________________ 
28 The PMS is a grant payment system operated and maintained by the Department of 
Health and Human Services, Program Support Center, Division of Payment 
Management.  The PMS provides disbursement, grant monitoring, reporting, and case 
management services to awarding agencies and grant recipients, such as MFCUs. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  18 
   
   
variety in our inventory sample, we included items that were 
portable and high value (e.g., vehicles, communication equipment).   
3.  To assess employee time and effort, we reviewed time card records 
from 10 pay periods across the 3 years of the review period for all 
Unit employees on staff. 
Interviews with Key Stakeholders.  In February and March 2016, 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 (i.e., the Medicaid Program Integrity 
Unit, the Office of the State Long-Term Care Ombudsman, and the Office of 
Health Care Quality).  We also interviewed supervisors from OIGs 
Region III 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 February 2016, we conducted an online survey of 
all 25 nonmanagerial Unit staff within each professional discipline 
(i.e., investigators, auditors, attorneys, and analysts) as well as support 
staff.  The response rate was 100 percent.  Our questions focused on Unit 
operations, opportunities for improvement, and practices that contributed 
to Unit effectiveness, efficiency, and 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 during the onsite review in 
March 2016.  We interviewed the Units director, chief of investigations, 
and chief auditor.29  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 performance, 
(3) opportunities for the Unit to improve its operations and/or 
performance, and (4) clarification regarding information obtained from 
other data sources. 
Onsite Review of Case Files and Other Documentation.  We requested that 
the Unit provide us with a list of cases that were open at any point during 
FYs 2013 through 2015.  We requested data on the 1,193 open cases that 
included, but was not limited to, the current status of the case; whether the 
                        ____________________________________________________________ 
29 We also interviewed the Units former deputy director, who served in this position 
during the review period.  This individual had since taken a position in the Maryland 
Office of Attorney General. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  19 
   
   
case was criminal, civil, or global; and the date on which the case was 
opened.  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 exclude those cases from our review of a 
Units case files.  Therefore, we excluded 368 cases that were categorized 
as global from the list of cases.  The remaining number of case files was 
825.   
From the 825 cases, we selected for review a simple random sample of 
100 cases.  From these 100 case files, we selected a simple random sample 
of 50 files for a more in-depth review of selected issues, such as the 
timeliness of investigations and case development. 
Based on our review of the sampled case files, we reported:  (1) the 
percentage of all case files that were open longer than 90 days that lacked 
documentation of periodic supervisory review, (2) the percentage of all 
case files that included documentation of supervisory approval for 
opening, and (3) the percentage of all closed case files that included 
documentation of supervisory approval for closing.  Appendix D contains 
these point estimates and their 95-percent confidence intervals.  
Onsite Review of Unit Operations.  During our March 2016 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. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  20 
   
   
APPENDIX D 
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 were open longer 
than 90 days that lacked documentation of  41  22.0%  10.8%  37.3% 
periodic supervisory review 
Percentage of case files that included 
documentation of supervisory approval for  100  97.0%  91.8%  99.4% 
opening 
Percentage of closed case files that included 
documentation of supervisory approval for  88  100.0%  96.0%  100.0% 
closing 
Source:  OIG analysis of Maryland MFCU case files, 2016. 
 
   
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  21 
   
   
APPENDIX E 
Unit Comments 
 
   
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  22 
   
   
   
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  23 
   
   
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; 
and in consultation with Richard Stern, Director of the Medicaid Fraud 
Policy and Oversight Division. 
Tricia Fields, of the Kansas City regional office, served as project leader 
for this study.  Other Office of Evaluation and Inspections staff who 
conducted the review include Dana Squires and Michala Walker.  Other 
Medicaid Fraud Policy and Oversight Division staff who participated in 
the review include Jordan Clementi.  Office of Investigations staff also 
participated in the review.  Office of Audit Services staff who conducted a 
financial review include Mike Jones, Marilyn Carrion, and Valerie 
Johnson.  Central office staff who contributed include Kevin Farber, Lonie 
Kim, and Joanne Legomsky. 
Maryland State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-07-16-00140)  24 
   
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.