U.S. Department of Health and Human  Services 
Office of Inspector General 
 
 
Medicaid Fraud 
Control Units 
NOTICE  THIS DRAFT 
Fiscal Year 2018 
RESTRICTED TO OFFICIAL 
USE 
 
Annual Report 
This document is a draft report of 
the Office of Inspector General 
and is subject to revision; 
 
therefore, recipients of this draft 
should not disclose its contents for 
purposes other than for official 
review and comment under any 
circumstances.  This draft and all 
copies thereof remain the property 
of, and must be returned on 
demand to, the Office of Inspector 
General. 
 
OOEEII--0099--1198--0000213800   Suzanne Murrin 
MAparricl h2 021081 9  Deputy Inspector General
   for Evaluation and 
ooiigg..hhhhss..ggoovv   Inspections  March 2019  U.S. Department of Health and Human Services 
OEI-09-19-00230 
Office  of Inspector General 
 
At a Glance 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report 
 
 
Medi caid Fraud Control Units (MFCUs or Units) investigate and prosecute Medicaid provider fraud and patient abuse or neglect.   
In 2018, Units operated in 49 States and the District of Columbia.  The Department of Health and Human Services Office of 
Inspector General is the designated Federal agency that oversees and annually approves Federal funding for MFCUs through 
a recertification process.  For this report, we analyzed the annual statistical data on case outcomes (such a s convictions; civil 
settlements and judgments; and recoveries) that the 50 MFCUs submitted for fiscal year 2018.     
TABLE OF CONTENTS 
BACKGROUND  1 
Methodology  3 
   
CASE OUTCOMES    
The number of convictions remained similar to those in recent years  4 
Criminal recoveries returned to the same general level that existed prior to a spike last year  7 
The number of civil settlements and judgments declined for the second year in a row  8 
Civil recoveries declined for the second straight year  9 
   
APPENDICES   
A: OIG Priority Outcome: Maximizing MFCU Effectiveness   11 
B: Beneficial Practices Described in OIG Onsite Reports   12 
C: Fiscal Year 2018: MFCU Case Outcomes and Open Investigations by Provider Type   19 
and Case Type 
   
ENDNOTES  27 
 
ACKNOWLEDGMENTS  28 
   
   
BACKGROUND 
The function of Medicaid Fraud Control Units (MFCUs or Units) is to 
investigate and prosecute Medicaid provider fraud and patient abuse or 
neglect.1  The Social Security Act (SSA) requires each State to effectively 
operate a MFCU, unless the Secretary of Health and Human Services 
determines that (1) the operation of a Unit would not be cost-effective 
because minimal Medicaid fraud exists in a particular State and (2) the State 
has other adequate safeguards to protect beneficiaries from abuse or 
neglect.2  Forty-nine States and the District of Columbia (States) operated 
MFCUs in fiscal year (FY) 2018.  In December 2018, OIG certified two 
additional MFCUs in the territories of Puerto Rico and the U.S. Virgin 
Islands.3   
MFCUs are funded jointly by Federal and State Governments.  Each of the 
50 MFCUs that was operating in FY 2018 received Federal reimbursement 
equivalent to 75 percent of its total expenditures, with State funds 
contributing the remaining 25 percent.4  In FY 2018, combined Federal and 
State expenditures for the Units totaled approximately $294 million, of 
which $221 million represented Federal funds.5     
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, separate and 
distinct from the State Medicaid agency;6  
  employ an interdisciplinary staff that consists of at least an 
investigator, an auditor, and an attorney;7 
  develop a formal agreement, such as a memorandum of 
understanding (MOU), describing the Units relationship with the 
State Medicaid agency;8 and 
  have either statewide authority to prosecute cases or formal 
procedures to refer suspected criminal violations to an agency with 
such authority.9   
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  1 
OEI-09-19-00230   
As illustrated in Exhibit 1, MFCU cases 
typically begin as referrals from external 
sources or are generated internally from 
data mining.10  MFCU staff review referrals 
of possible fraud and patient abuse or 
neglect to determine the potential for 
criminal prosecution and/or civil action.  
If the Unit accepts a referral for 
investigation, the case may result in 
various possible outcomes.  Criminal 
prosecutions may result in convictions; 
civil actions may result in civil settlements 
or judgments.  Both criminal prosecutions 
and civil actions may include the 
assessment of monetary recoveries.  The 
Office of Inspector General (OIG) has the 
authority to exclude convicted individuals 
and entities from any federally funded 
health care program on the basis of 
convictions referred from MFCUs.11  In 
addition to achieving these case 
outcomes, Units may also make program recommendations to their 
respective State Governments that help strengthen program integrity and 
efforts to fight patient abuse or neglect.   
OIG Oversight of the  Reducing Medicaid fraud is a top priority for OIG, and its role in overseeing 
MFCUs helps achieve that priority.  OIG oversees the MFCU grant program 
MFCU Program  
by recertifying Units, conducting onsite reviews of Units, providing technical 
assistance to Units, and maintaining key statistical data about Unit caseloads 
and outcomes.  Further, OIG has identified enhancing Medicaid program 
integrityincluding efforts to maximize the effectiveness of MFCUsas an 
OIG Priority Outcome.  (See Appendix A for details.) 
Annually, OIG reviews each Units application for recertification; approval of 
this application is necessary for the Unit to receive Federal reimbursement.12  
To recertify a Unit, OIG assesses the Units compliance with the Federal 
requirements for MFCUs contained in statute, regulations, and OIG policy 
transmittals.  OIG also examines the Units adherence to 12 performance 
standards, such as those regarding staffing, maintaining adequate referrals, 
and cooperating with Federal authorities.13  
OIG conducts periodic onsite reviews of Units.  These reviews allow OIG to 
evaluate a Units outcomes; operations; compliance with Federal laws, 
regulations, and policies; and adherence to performance standards.  On the 
basis of these reviews, OIG issues public reports that contain findings and 
recommendations for improvement or corrective actions.  These reports 
may also note Unit practices that OIG identifies as particularly beneficial and 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  2 
OEI-09-19-00230   
that may be useful to other MFCUs.  Appendix B contains a list of beneficial 
practices that OIG has cited in MFCU reports published in recent years. 
OIG also provides ongoing technical assistance and guidance to Units.  
These activities may include responding to questions from the Units, 
providing training to Units, and issuing policy transmittals to all Units. 
Annually, OIG collects and presents statistical data reported by each MFCU, 
such as the numbers of open cases, indictments, convictions, and amounts 
of recoveries.  These data can be accessed on the OIG website in two 
formats: a statistical chart and an interactive map.  
Methodology  We based the information in this report on the FY 2018 Annual Statistical 
Reports that all 50 MFCUs submitted to OIG; the recertification materials 
that the MFCUs submitted to OIG; and OIG exclusions data.   
We aggregated case outcomes across all Units for FY 2018 and for each of 
the preceding 4 yearsFYs 2014 through 2017.  These outcomes include 
convictions; civil settlements and judgments; and recoveries.  For each of 
these outcomes, we calculated an average across the 5-year period of 
FYs 2014 through 2018.  We also calculated the return on investment (ROI) 
for MFCUs.14  Additionally, we identified the provider types with the highest 
numbers of criminal and civil outcomes in FY 2018 and the numbers of 
exclusions that OIG imposed in FY 2018 on individuals and entities as a 
result of conviction referrals from MFCUs.  We analyzed MFCU drug 
diversion cases, using data for FYs 2015 through 2018.  
Standards  OIG inspections of the MFCUs, and this annual report, differ from other OIG 
evaluations in that they support OIGs direct administration of the MFCU 
grant program.  However, they are subject to the same internal quality 
controls as other OIG evaluations, including internal peer review.   
We conducted this study in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of Inspectors General on 
Integrity and Efficiency.   
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  3 
OEI-09-19-00230   
CASE OUTCOMES 
The number of  In FY 2018, MFCU cases resulted in 1,503 convictions, similar to the numbers 
of convictions in other recent years.  This total included 1,109 convictions for 
convictions 
fraud and 394 convictions for patient abuse or neglect.  The distribution of 
remained similar to 
both types of convictionsconvictions of fraud, and convictions of abuse or 
those in recent years  neglectremained similar to the distributions in previous years.  Exhibit 2 
shows the number of convictions for each of the last 5 years.    
 
MFCU convictions led to the exclusion of individuals and entities from 
Federal health care programs, broadening the impact of those convictions. 
When MFCUs make referrals to OIG regarding convictions for fraud and 
patient abuse or neglect in their respective States, OIG has the authority to 
exclude those convicted individuals and entities from federally funded 
health care programs.  Through these referrals, MFCUs help ensure that 
individuals and entities convicted in one State are excluded from Medicaid 
programs in other States, as well as from other Federal programs related to 
health care.  On its website, OIG maintains the List of Excluded 
Individuals/Entities.  In FY 2018, OIG excluded 974 individuals and entities 
from participating in Federal health care programs as a result of conviction 
referrals from MFCUs.   
 
 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  4 
OEI-09-19-00230   
Significantly more convictions for fraud involved personal care 
services (PCS) attendants and agencies than any other provider type  
Of the 1,109 fraud convictions in FY 2018, 496 (45 percent) involved PCS 
 
attendants and agencies.  For additional information on the prevalence of 
Medicaid fraud involving  personal care services and efforts to combat such 
fraud, see OIGs December 2018 Top Management  and Performance  
Challenges Facing  HHS (p. 27).   
Exhibit 3 shows the  provider types with the most fraud convictions in  
FY 2018.    
 
Convictions from drug diversion cases continued to increase in  
FY 2018 
Convictions from drug  diversion cases increased from 191 in FY 2017 to  
199 in FY 2018, with associated recoveries of $7.7 million in FY 2018.  
In a Medicaid context, drug diversion cases involve investigating  the 
fraudulent billing of Medicaid for drugs diverted  from legal and medically 
necessary uses.  MFCUs may conduct drug diversion investigations jointly 
with other State or Federal agencies, such as OIG or the U.S. Drug 
Enforcement  Administration.  On the next page, Exhibit 4 shows the  number 
of convictions associated with drug diversion cases during FYs 2015 through 
2018.      
 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  5 
OEI-09-19-00230   
 
In FY 2018, more convictions for patient abuse or neglect involved 
nurse aides than any other provider type 
In FY 2018, nurse aides accounted for 129 of the total 394 convictions for 
patient abuse or neglect (33 percent).  Exhibit 5 shows the provider types 
with the most convictions for patient abuse or neglect. 
 
Appendix C showsby provider typethe number of convictions and 
recovery amounts for cases of patient abuse or neglect.   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  6 
OEI-09-19-00230   
Criminal recoveries  Criminal recoveries of $314 million in FY 2018 were less than half of the 
amount in FY 2017 but at the same general level as the amounts from 
returned to the 
FYs 2014 through 2016.  As shown in Exhibit 6, criminal recovery amounts 
same general level 
per year during the 5-year period of FYs 2014 through 2018 averaged over 
that existed prior to  $400 million, whereas recoveries in FY 2017 were close to $700 million.  
a spike last year   The spike in the criminal recovery amount in FY 2017 was (in part) the result 
of a single large fraud case with a recovery amount totaling $268 million.15   
 
In FY 2018, one case that resulted in significant criminal recoveries was 
prosecuted by the Florida Unit.  The case involved two operators of 
a behavioral health clinic who were ordered to pay about $1.37 million in 
restitution.  The two individuals participated in a conspiracy to commit 
health care fraud by not disclosing that one of them had been excluded 
from participating in Medicaid.16   
 
Appendix C showsby provider typethe number of convictions and 
recovery amounts for criminal cases.  Appendix C also provides a variety of 
other statistics about MFCU caseloads and outcomes, again broken out by 
provider type.   
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  7 
OEI-09-19-00230   
The number of civil  In FY 2018, MFCUs were responsible for 810 civil settlements and judgments, 
which represents the second year of decline in a row and is slightly below 
settlements and 
the 5-year average.  Exhibit 7 shows the number of civil settlements and 
judgments  
judgments for FYs 2014 through 2018 in relation to the 5-year average.   
declined for the 
second year in a row 
 
Significantly more civil settlements and judgments involved 
pharmaceutical manufacturers than any other provider type 
Of the 810 civil settlements and judgments in FY 2018, 217 (27 percent) 
involved pharmaceutical manufacturers.  Exhibit 8 shows the provider types 
with the most civil settlements and judgments in FY 2018. 
 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  8 
OEI-09-19-00230   
Civil recoveries  Civil recoveries decreased to $545 million in FY 2018, which represents 
a decrease from FYs 2016 and 2017.  Exhibit 9 shows the amounts of civil 
declined for the 
recoveries for FYs 2014 through 2018 in relation to the 5-year average.  The 
second straight year  
occurrence of large monetary settlements in certain years and the timing of 
  these settlements contributes to this variability.  
 
Of FY 2018s civil recoveries of 
$545 million, $367 million (67 percent) 
were derived from global cases.17  (See 
sidebar.)  The remaining $178 million 
(33 percent) derived from nonglobal 
cases. 
As the result of one global case, 
a dental management company and its 
affiliated dental clinics were ordered to 
pay the United States and participating 
States a total of $23.9 million.  This was 
to resolve allegations that the company 
and its affiliated clinics had knowingly 
submitted false claims for payment to State Medicaid programs for 
medically unnecessary dental services performed on children insured by 
Medicaid.18 
As a result of a nonglobal case that the Alaska Unit investigated, a health 
care agency that provides services to persons with intellectual or 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  9 
OEI-09-19-00230   
developmental disabilities agreed to pay $2.3 million to resolve allegations 
that it billed for services not provided.  As part of the settlement agreement, 
the provider was also required to enter into a 5-year Corporate Integrity 
Agreement with OIG to help prevent future instances of fraud or abuse.19   
Appendix C shows the number of settlements and judgments and recovery 
amounts for civil cases, by provider type.   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  10 
OEI-09-19-00230   
APPENDIX A: OIG Priority Outcome:  
Maximizing MFCU Effectiveness 
It is a top OIG priority to strengthen the effectiveness of Medicaid Fraud Control Units (MFCUs) as key 
partners in combating fraud and abuse.  As part of its oversight, OIG constantly strives to support the 
MFCUs in ways that maximize their effectiveness.  Over the past few years, OIG has engaged in numerous 
actions to help drive MFCU effectiveness.  These include activities in five categories: (1) enhancing OIG 
oversight; (2) increasing the use of data; (3) expanding the MFCU program to better align with a growing 
and evolving Medicaid program; (4) targeting MFCU training where it can be of greatest assistance to 
MFCUs; and (5) increasing collaboration between MFCUs and OIG.   
To assess the impact of these efforts, OIG has established two key performance indicators:  
(1) indictment rate and (2) conviction rate.  The table below shows these rates for FYs 20152018 and the 
target that OIG aims to achieve in FY 2019.20   
 
KEY 
PERFORMANCE  FY 2015  FY 2016  FY 2017  FY 2018  FY 2019  FY 2020 
INDICATORS  (ACTUAL)  (ACTUAL)  (ACTUAL)  (ACTUAL)  TARGET  TARGET 
Indictment rate   16.1%  16.0%  17.2%  16.4%  17.0%  17.2% 
Conviction rate  91.2%  89.6%  88.6%  90.3%  90.7%  90.8% 
 
Calculations:  
Indictment rate = (total number of criminal cases with indictments or charges 
plus number of nonglobal civil cases open, filed, or referred for filing) 
divided by 
(total number of open cases) 
 
Conviction rate = (total number of criminal cases resulting in a defendant convicted) 
divided by 
(total number of cases resulting in a defendant acquitted, dismissed, or convicted)   
 
To calculate these measures, OIG aggregates data that Units submit through Annual Statistical Reports.   
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  11 
OEI-09-19-00230   
APPENDIX B: Beneficial Practices Described in OIG 
Onsite Reports   
This appendix summarizes MFCU practices that OIGin its more recent onsite-review reportshas 
highlighted as being beneficial to Unit operations.  Other Units should consider whether adopting similar 
practices in their States may yield similar benefits.   
All of OIGs reports on its onsite reviews of MFCUs are available at https://oig.hhs.gov/reports-and-
publications/oei/m.asp#mfcu.    
 
STATE   PRACTICE 
REPORT NUMBER  CATEGORY  DESCRIPTION 
Alaska  Successful  Unit stakeholders reported that the MFCU director 
OEI-09-16-00430  partnerships  made efforts to improve communication with 
agencies such as OIG and the State Medicaid agency.  
As a result, the number of joint OIG-MFCU cases 
tripled from FY 2012 to FY 2015. 
  Successful  Unit collaboration with Federal and State partners to 
partnerships and  investigate allegations of PCS fraud led to convictions 
program integrity  and significant monetary recoveries.  Further, the Unit 
improvements  made program integrity recommendations to 
safeguard against PCS provider fraud, and the State 
Medicaid agency implemented these 
recommendations.  
Arizona  Focus on managed  MFCU staff attended quarterly meetings with the 
OEI-07-15-00280  care   State Medicaid agency and managed care 
organizations (MCOs).  These meetings provided 
guidance to MCOs about what constitutes a quality 
referral and the types of referrals that will result in the 
MFCUs opening a case for investigation. 
Arkansas   Outreach activities  Outreach by the Unit built relationships with 
OEI-06-12-00720  stakeholders and aided the Units mission.  For 
example, Unit investigators led training for staff of the 
State Office of Long Term Care, about how to 
develop a potential referral to the MFCU.  
 
continued on the next page 
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  12 
OEI-09-19-00230   
Beneficial Practices Described in OIG Onsite Reports (continued) 
STATE   PRACTICE  DESCRIPTION 
REPORT NUMBER  CATEGORY 
California  Focus on managed  The Unit provided quarterly training for MCO 
OEI-09-15-00070  care  representatives that resulted in increased fraud referrals 
from MCOs to the Unit. 
Outreach activities  The Unit hired a field representative to provide 
outreach and increase the number of fraud referrals 
sent to the Unit.  The field representative acted as a 
liaison between the Unit and other State agencies and 
also trained staff from these agencies about Medicaid 
fraud and the Units role in combating provider fraud 
and patient abuse or neglect. 
Co-location of Unit  Unit investigators have workstations at an OIG field 
and OIG staff  office, which facilitated the mutual referral of cases and 
improved communication and cooperation with OIG on 
joint cases. 
Florida  Co-location of Unit  Unit staff have workstations in an OIG field office, which 
OEI-07-15-00340  and OIG staff  improved communication and cooperation with OIG on 
joint cases, including fraud cases generated through 
the U.S. Department of Justices Medicare Strike Force. 
Idaho  Case management  The Unit implemented an investigative checklist that 
OEI-09-12-00220  tools  improved the Units case flow.  This Unit also used an 
investigative case plan for each case, which the case 
investigator discussed with Unit attorneys prior to 
monthly staff meetings. 
Kentucky  Successful  The Unit regularly met with the State Medicaid agency, 
OEI-06-17-00030  partnerships  other State agencies, and MCOs to encourage fraud 
referrals and improve communication and 
collaboration.  The results included improved quality, 
completeness, and timeliness of fraud referrals.  
  Improved staff skills  The Unit created an executive advisor position.  The 
executive advisor helped Unit attorneys develop 
litigation skills, mentored new attorneys, and served as 
a co-chair on Unit prosecutions. 
    continued on the next page 
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  13 
OEI-09-19-00230   
Beneficial Practices Described in OIG Onsite Reports (continued) 
STATE   PRACTICE 
REPORT NUMBER  CATEGORY  DESCRIPTION 
Maryland  Improved staff skills  The Unit developed an internal boot camp training 
OEI-07-16-00140  program that helped new staff develop a full 
understanding of the Units work.  Experienced 
MFCU staff gave 1- to 2-hour lectures on topics such 
as civil and criminal investigation procedures; 
interviewing techniques; and understanding medical 
codes.   
Massachusetts  Successful partnerships  The Unit developed partnerships with other State 
OEI-07-15-00390  and Federal agencies and used clinical experts to 
  facilitate the investigation and prosecution of drug 
diversion and other pharmacy cases. 
Case management  The Unit used its Intranet system to streamline its 
tools  administrative processes, such as periodic 
supervisory reviews of case files.  The Unit found 
that this helped improve case management and the 
effectiveness of investigations and prosecutions. 
Michigan   Co-location of Unit and  The Unit made workspace available to an OIG agent 
OEI-09-13-00070  OIG staff  within the Unit offices.  Co-location facilitated 
communication between the MFCU and OIG in 
assessing potential fraud referrals and working joint 
cases. 
Case management  Unit management and the Michigan Department of 
tools  Licensing and Regulatory Affairs (LARA) developed 
a streamlined process for referring cases of patient 
abuse or neglect.  This process helped to ensure 
that referrals from LARA were consistent with the 
Units statutory functions, thereby promoting Unit 
efficiency and case flow. 
Minnesota  Program integrity  The Unit helped develop legislation to protect 
OEI-06-13-02000  improvements  Medicaid beneficiaries by strengthening background 
checks for individuals who serve as guardians and 
conservators of adult Medicaid beneficiaries.   
     
    continued on the next page 
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  14 
OEI-09-19-00230   
Beneficial Practices Described in OIG Onsite Reports (continued) 
STATE   PRACTICE 
REPORT NUMBER  CATEGORY  DESCRIPTION 
Nevada  Outreach activities  The Units outreach program consisted of educational 
OEI-09-12-00450  classes taught by Unit presenters who describe various 
  types of fraud and abuse or neglect; discuss Federal 
and State laws regarding fraud and abuse or neglect; 
and provide Unit contact information for reporting 
Medicaid-related crime.  The Units Train the Trainer 
program was instrumental in the success of the 
provider outreach program. 
New Mexico  Focus on managed  Unit management and the State Medicaid agency 
OEI-09-14-00240  care  worked closely to develop and implement an improved 
  referral process that ensures that the Unit receives all 
appropriate fraud referrals generated by MCOs. 
  Program integrity  The Unit consistently provided program integrity 
improvements  recommendations to the State Medicaid agency during 
quarterly joint protocol meetings.  One of these 
recommendations resulted in the inclusion of language 
into MCO contracts that clarified the State Medicaid 
agency role in referring to the MFCU all verified 
allegations of fraud, waste, or abuse in a managed care 
setting. 
New York  Strategic Plan  The Unit developed a written strategic plan to help Unit 
OEI-12-17-00340  staff make informed decisions regarding the optimal 
  use of resources.  The plan provides guidance to 
prioritize certain types of investigations, such as 
criminal investigations that are related to systematic 
patient abuse and neglect; fraud allegations against 
managed care companies; and fraud investigations of 
large providers.  The plan also establishes a priority for 
false claims investigations with higher potential for 
monetary recoveries or risk of patient harm. 
Successful  The Unit established data-analytics working groups to 
partnerships  provide guidance, training, and assessment of the 
Units data mining efforts.  The groups include: the 
Data Analytics Tool Group; the Data Sources group; the 
Fraud and Abuse group; and the Governance group. 
  Improved staff skills  The Unit used moot-court training to train Unit 
attorneys.  This training helped the Unit attorneys 
practice opening arguments to prepare for trial. 
continued on the next page 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  15 
OEI-09-19-00230   
Beneficial Practices Described in OIG Onsite Reports (continued) 
STATE   PRACTICE 
REPORT NUMBER  CATEGORY  DESCRIPTION 
North Carolina  Improved staff skills  The Unit partnered with another State agency to 
OEI-07-16-00070  create the North Carolina Financial Investigators 
  Academy.  The academy provided instruction to 
financial investigators on topics such as elements of 
criminal law; search and seizure procedures; 
interviewing; and testifying.  The Unit required all of 
its newly hired financial investigators to attend the 
academy, regardless of previous experience. 
Ohio  Successful  The Unit helped to establish the Ohio Program Integrity 
OEI-07-14-00290  partnerships  Group, which combines the knowledge and resources 
of all the State agencies that are responsible for 
Medicaid program integrity.  In addition, the Unit 
spearheaded the Managed Care Program Integrity 
Group, which meets quarterly. 
  Use of technology  The Unit employed a special projects team to provide 
technical support to all of its investigative teams. 
Oregon  Outreach activities  The Unit created a group that provided outreach to 
OEI-09-16-00200  help increase referrals of patient abuse or neglect and 
facilitate Unit work in remote areas of the State.  This 
group provided outreach about the Units mission and 
legal authorities by establishing Unit liaisons for each 
county in Oregon and attending multidisciplinary team 
meetings at the county level. 
South Dakota  Outreach activities  The Unit used providers who had previously been 
OEI-07-16-00170  investigated for Medicaid fraud to educate their peers.  
These providers gave presentations alongside Unit staff 
at training conferences, which helped to highlight 
Medicaid billing issues and the implications of Medicaid 
fraud. 
Texas  Outreach activities  To help increase the number of referrals, the Unit 
OEI-06-13-00300  instituted outreach to heighten public awareness of the 
Unit and its mission.  The Unit required each 
investigator and investigative auditor to make  
12 outreach contacts per year.  
continued on the next page  
 
 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  16 
OEI-09-19-00230   
Beneficial Practices Described in OIG Onsite Reports (continued) 
STATE   PRACTICE 
REPORT NUMBER  CATEGORY  DESCRIPTION 
Utah  Improved staff skills  The Unit required all Unit auditors and investigators to 
OEI-09-13-00490    become trained as Certified Fraud Examiners.  This 
training helped the Unit improve the efficiency and 
effectiveness of its provider fraud investigations. 
  Case management  The Unit used a spreadsheet to track investigator 
tools  workloads, which helped the Unit ensure the timely 
completion of investigations.  The spreadsheet tracked 
the number of cases assigned to each investigator, 
hours spent on each case, and case complexity.  The 
information was also helpful in making decisions about 
assigning new cases to investigators.   
  Focus on managed  Unit management worked with the State Medicaid 
care  agency and MCOs to add provisions in MCO contracts 
to help ensure that MCOs send fraud referrals to the 
Unit.  
Vermont  Successful  The Unit director created Provider Focus Teams in 
OEI-02-13-00360  partnerships  collaboration with the State Medicaid agency.  These 
teams facilitated existing cases, developed provider 
training, and made program recommendations. 
    The Unit Director helped create the Vermont Elder 
Justice Working Group, which consisted of 
representatives from State and Federal advocacy 
groups, regulatory agencies, and law enforcement 
agencies.  The groups mission was to improve health 
care for the elderly living in long-term care facilities by 
improving communication among stakeholders and law 
enforcement agencies. 
    continued on the next page  
 
     
 
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  17 
OEI-09-19-00230   
Beneficial Practices Described in OIG Onsite Reports (continued) 
STATE   PRACTICE 
REPORT NUMBER  CATEGORY  DESCRIPTION 
Virginia  Successful  The Units partnerships with the Food and Drug 
OEI-07-15-00290  partnerships    Administration, the Internal Revenue Service, and the 
  Social Security Administration led to successful 
Medicaid fraud prosecutions, particularly with regard to 
pharmaceutical manufacturers, and increased Unit 
recoveries. 
Use of technology  The Unit used specialty software designed to read the 
text in a document, analyze it for keywords, and 
systematically code it according to criteria established 
by an analyst.  This improved the Units ability to 
process and track evidence collected during 
investigations and to share that evidence with Federal 
and State partners working on joint cases. 
Washington  Focus on managed  The Unit worked with the State Medicaid agency to 
OEI-09-16-00010  care  revise both the MOU between the Unit and the agency 
    and the agencys contracts with MCOs to ensure that 
  the Unit received copies of all MCO fraud referrals. 
 
The Unit used a case closure form to make numerous 
Program integrity 
program integrity recommendations to State agencies 
improvements  
and tracked the responses to these recommendations 
in a database. 
West Virginia  Improved staff skills   Unit staff learned new skills and obtained certifications 
OEI-07-13-00080  as Certified Fraud Examiners and Certified Coding 
   Professionals. 
  Focus on managed  The Unit focused on managed care by holding 
care  meetings with MCO administrators to obtain referrals. 
Wyoming  Improved staff skills  The Unit used a MFCU investigator from a neighboring 
OEI-09-16-00530  State to help train its newly hired investigator.  As part 
of the training, the investigator from the neighboring 
State observed work on active Medicaid fraud cases 
and met with the new investigator, Unit management, 
and attorneys to discuss progress.  This was a  
cost-effective training option for the Unit and furthered 
a positive working relationship with the neighboring 
MFCU. 
     
 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  18 
OEI-09-19-00230   
APPENDIX C: FY 2018: MFCU Case Outcomes and 
Open Investigations by Provider Type and Case 
Type 
Exhibit C1: Number of convictions; settlements and judgments; and recoveries by 
provider type and case type 
CRIMINAL  CIVIL 
Settlements 
Amount of  and  Amount of 
PROVIDER TYPE  Convictions  Recoveries  Judgments  Recoveries 
Patient Abuse or Neglect 
Assisted Living Facility  11  $104,691  0  $0 
Developmental Disability Facility  23  $25,619  1  $5,960 
Hospice  0  $0  0  $0 
Nondirect Care Staff  23  $572,385  1  $83,000 
Nurse Aide (CNA or Other)  129  $206,954  1  $4,500 
Nursing Facilities  24  $68,168  21  $1,343,000 
Nurse (LPN, RN, NP) or Physician  69  $50,815  0  $0 
Assistant  
Personal Care Aide or Other Home Care  38  $108,804  1  $20,000 
Aide 
Other  77  $1,241,449  2  $15,000 
FraudFacility-Based Medicaid Providers and ProgramsInpatient and/or 
Residential 
Assisted Living Facility  5  $20,599  3  $116,508 
Developmental Disability Facility  1  $61,667  4  $830,000 
(Residential) 
Hospice   1  $23,925  1  $29,621 
Hospital   8  $37,041,364  23  $12,102,234 
Inpatient Psychiatric Services for  0  $0  1  $232,117 
Individuals Under Age 21 
Nursing Facility  8  $12,301,622  15  $36,351,638 
Other Inpatient Mental Health Facility  1  $77,106  0  $0 
Other Long-Term Care Facility  1  $667,103  1  $82,233 
continued on the next page 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  19 
OEI-09-19-00230   
Number of convictions; settlements and judgments; and recoveries by provider type and case 
type (continued) 
CRIMINAL  CIVIL 
Settlements 
Amount of  and  Amount of 
PROVIDER TYPE  Convictions  Recoveries  Judgments  Recoveries 
FraudFacility-Based Medicaid Providers and ProgramsOutpatient and/or 
Day Services 
Adult Day Center  1  $24,962  3  $192,625 
Ambulatory Surgical Center  0  $0  0  $0 
Developmental Disability Facility   4  $136,703  3  $2,295,373 
(Nonresidential) 
Dialysis Center  0  $0  2  $57,876 
Mental Health Facility (Nonresidential)  20  $10,684,901  8  $13,178,517 
Substance Abuse Treatment Center  14  $189,419  6  $5,236,675 
Other Facility (Nonresidential)  10  $4,145,686  21  $4,870,292 
FraudLicensed Practitioners 
Audiologist  3  $14,263,893  1  $51,546 
Chiropractor  1  $1,960  5  $1,635,320 
Clinical Social Worker  10  $4,124,692  6  $519,470 
Dental Hygienist  0  $0  0  $0 
Dentist  16  $11,303,329  43  $27,829,264 
Nurse (LPN, RN, or Other Licensed)  88  $1,961,017  7  $331,336 
Nurse Practitioner  11  $267,999  1  $4,457 
Optometrist  1  $3,401  2  $87,447 
Pharmacist  4  $3,184,775  0  $0 
Physician Assistant  5  $2,929  0  $0 
Podiatrist  1  $83,653  1  $80,677 
Psychologist  15  $3,097,639  1  $126,760 
Therapist (Non-Mental Health, PT, ST,  9  $776,174  3  $90,795 
OT, RT) 
Other Practitioner  29  $1,275,871  4  $9,737,935 
FraudMedical Services 
Ambulance  3  $866,500  4  $205,435 
Billing Services  5  $2,674,345  2  $903,555 
continued on the next page 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  20 
OEI-09-19-00230   
Number of convictions; settlements and judgments; and recoveries by provider type and case 
type (continued) 
CRIMINAL  CIVIL 
Settlements 
Amount of  and  Amount of 
PROVIDER TYPE  Convictions  Recoveries  Judgments  Recoveries 
FraudMedical Services (continued) 
Home Health Agency  27  $17,831,658  17  $25,867,737 
Lab (Clinical)  0  $53,313  22  $5,646,144 
Lab (Radiology and Physiology)  2  $25,310  1  $72,106 
Lab (Other)  0  $0  11  $1,206,484 
Medical Device Manufacturer  0  $0  57  $6,964,707 
Pain Management Clinic  5  $13,640,377  0  $0 
Personal Care Services Agency  36  $5,239,144  14  $777,787 
Pharmaceutical Manufacturer  0  $0  217  $311,330,073 
Pharmacy (Hospital)  0  $0  2  $309,555 
Pharmacy (Institutional Wholesale)  2  $47,417  23  $4,560,858 
Pharmacy (Retail)  32  $5,506,057  78  $32,425,607 
Suppliers of Durable Medical Equipment,  22  $14,828,695  57  $5,235,133 
Prosthetics, Orthotics and Supplies 
(DMEPOS) 
Transportation (Nonemergency)  30  $1,279,7729  14  $1,801,522 
Other   8  $293,163  19  $1,285,221 
FraudOther Individual Providers 
Emergency Medical Technician or  0  $0  0  $0 
Paramedic 
Nurses Aide (CNA or Other)  32  $222,997  1  $618,768 
Optician  0  $0  0  $0 
Personal Care Services Attendant  460  $5,415,614  16  $207,045 
Pharmacy Technician  5  $9,629  0  $0 
Unlicensed Counselor (Mental Health)  22  $2,950,522  2  $1,115,022 
Unlicensed Therapist (Non-Mental  4  $41,964  0  $0 
Health) 
Other  69  $2,611,250  5  $1,002,162 
FraudPhysicians (MD/DO) by Medical Specialty 
Allergist/Immunologist  0  $0  1  $128,695 
Cardiologist  3  $16,158,755  3  $394,180 
continued on the next page 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  21 
OEI-09-19-00230   
Number of convictions; settlements and judgments; and recoveries by provider type and case 
type (continued) 
CRIMINAL  CIVIL 
Settlements 
Amount of  and  Amount of 
PROVIDER TYPE  Convictions  Recoveries  Judgments  Recoveries 
FraudPhysicians (MD/DO) by Medical Specialty (continued) 
Emergency Medicine  0  $0  7  $187,893 
Family Practice  17  $36,088,772  3  $1,017,947 
Geriatrician  0  $0  0  $0 
Internal Medicine  9  $2,276,677  5  $1,586,744 
Neurologist  4  $2,789,941  3  $644,145 
Obstetrician/Gynecologist  0  $0  1  $33,544 
Ophthalmologist  1  $607,348  0  $0 
Pediatrician  3  $318,979  2  $1,161,188 
Physical Medicine and Rehabilitation  2  $400,200  0  $0 
Psychiatrist  0  $10,000  6  $820,176 
Radiologist  0  $0  0  $0 
Surgeon  4  $790,461  1  $26,114 
Urologist  2  $182,747  1  $47,436 
Other MD/DO  17  $71,568,097  17  $6,645,449 
FraudProgram Related 
Managed Care Organization (MCO)  2  $58,073  2  $12,036,324 
Medicaid Program Administration  0  $0  0  $0 
Other  14  $1,456,048  4  $1,020,345 
Total  1,503  $314,345,099  810  $544,827,273 
         
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  22 
OEI-09-19-00230   
Exhibit C2: Number of open investigations at the end of FY 2018 by provider type and 
case type 
  OPEN INVESTIGATIONS 
PROVIDER TYPE  Criminal  Civil  Total  
Patient Abuse or Neglect 
Assisted Living Facility  221  2  223 
Developmental Disability Facility  135  0  135 
Hospice  8  0  8 
Nondirect Care Staff  144  0  144 
Nurse Aide (CNA or Other)  479  0  479 
Nursing Facilities  1,071  61  1,132 
Nurse (RN, LPN, NP) or Physician Assistant  433  2  435 
Personal Care Aide or Other Home Care Aide  329  0  329 
Other  692  3  695 
FraudFacility-Based Medicaid Providers and ProgramsInpatient and/or 
Residential 
Assisted Living Facility  34  9  43 
Developmental Disability Facility (Residential)  36  6  42 
Hospice   78  42  120 
Hospital  84  244  328 
Inpatient Psychiatric Services for Individuals Under   16  12  28 
Age 21 
Nursing Facility  118  211  329 
Other Inpatient Mental Health Facility  21  40  61 
Other Long-Term Care Facility  16  15  31 
FraudFacility-Based Medicaid Providers and ProgramsOutpatient and/or 
Day Services 
Adult Day Center  76  5  81 
Ambulatory Surgical Center  1  8  9 
Developmental Disability Facility (Nonresidential)  22  5  27 
Dialysis Center  2  50  52 
Mental Health Facility (Nonresidential)  245  39  284 
Substance Abuse Treatment Center  112  36  148 
Other Facility (Nonresidential)  91  43  134 
continued on the next page 
   
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  23 
OEI-09-19-00230   
Number of open investigations at the end of FY 2018 by provider type and case type (continued) 
  OPEN INVESTIGATIONS 
PROVIDER TYPE  Criminal  Civil  Total  
FraudLicensed Practitioners 
Audiologist  3  1  4 
Chiropractor  21  5  26 
Clinical Social Worker  90  4  94 
Dental Hygienist  5  2  7 
Dentist  320  56  376 
Nurse (LPN, RN, or Other Licensed)  528  4  532 
Nurse Practitioner  69  1  70 
Optometrist  21  4  25 
Pharmacist  47  28  75 
Physician Assistant  33  1  34 
Podiatrist  20  8  28 
Psychologist  94  6  100 
Therapist (Non-Mental Health, PT, ST, OT, RT)  80  26  106 
Other Practitioner  138  18  156 
FraudMedical Services 
Ambulance  93  20  113 
Billing Services  28  46  74 
Home Health Agency  652  68  720 
Lab (Clinical)  73  364  437 
Lab (Radiology and Physiology)  12  27  39 
Lab (Other)  34  130  164 
Medical Device Manufacturer  1  584  585 
Pain Management Clinic  55  18  73 
Personal Care Services Agency  263  13  276 
Pharmaceutical Manufacturer  150  3,046  3,196 
Pharmacy (Hospital)  1  3  4 
Pharmacy (Institutional Wholesale)  14  200  214 
Pharmacy (Retail)  217  553  770 
Transportation (Nonemergency)  207  10  217 
Suppliers of Durable Medical Equipment, Prosthetics,  170  548  718 
Orthotics, and Supplies (DMEPOS) 
continued on the next page 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  24 
OEI-09-19-00230   
Number of open investigations at the end of FY 2018 by provider type and case type (continued) 
  OPEN INVESTIGATIONS 
PROVIDER TYPE  Criminal  Civil  Total  
FraudMedical Services (continued) 
Other   85  208  293 
FraudOther Individual Providers 
Emergency Medical Technician or Paramedic  2  0  2 
Nurse Aide (CNA or Other)  54  0  54 
Optician  3  4  7 
Personal Care Services Attendant  1,810  11  1,821 
Pharmacy Technician  13  0  13 
Unlicensed Counselor (Mental Health)  96  7  103 
Unlicensed Therapist (Non-Mental Health)  3  0  3 
Other  359  34  393 
FraudPhysicians (MD/DO) by Medical Specialty 
Allergist/Immunologist  8  2  10 
Cardiologist  18  16  34 
Emergency Medicine  12  11  23 
Family Practice  251  15  266 
Geriatrician  2  0  2 
Internal Medicine  167  20  187 
Neurologist  37  2  39 
Obstetrician/Gynecologist  26  8  34 
Ophthalmologist  16  9  25 
Pediatrician  50  3  53 
Physical Medicine and Rehabilitation  26  14  40 
Psychiatrist  85  8  93 
Radiologist  7  6  13 
Surgeon  24  6  30 
Urologist  1  1  2 
Other MD/DO  340  89  429 
continued on the next page 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  25 
OEI-09-19-00230   
Number of open investigations at the end of FY 2018 by provider type and case type (continued) 
  OPEN INVESTIGATIONS 
PROVIDER TYPE  Criminal  Civil  Total  
FraudProgram Related 
Managed Care Organization (MCO)  16  53  69 
Medicaid Program Administration  16  10  26 
Other  72  119  191 
TOTAL  11,502  7,283  18,785 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  26 
OEI-09-19-00230   
ENDNOTES 
1 Social Security Act  1903(q)(3)-(4).  Regulations at 42 CFR  1007.11(b)(1) add that a Units responsibilities may 
include reviewing complaints of misappropriation of patients private funds in residential health care facilities.  Unit 
investigations of patient abuse and neglect are limited to incidents occurring in: (1) health care facilities that receive 
Medicaid payments, or (2) board and care facilities, which are residential settings that receive payment on behalf of 
two or more unrelated adults who reside in the facility and for whom nursing care services or a substantial amount of 
personal care services are provided.  SSA  1903(q)(4). 
2 SSA  1902(a)(61). 
3 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 this authority to OIG.  Also see 42 CFR 
 1007.15.  North Dakota and the territories of American Samoa, Guam, and the Northern Marianas Islands have not 
established Units. 
4 SSA  1903(a)(6).  Units receive 90 percent Federal reimbursement for their first 3 years of operation.   
5 OIG analysis of FY 2018 MFCU Annual Statistical Reports. 
6 SSA  1903(q)(2); 42 CFR  1007.9(a). 
7 SSA  1903(q)(6); 42 CFR  1007.13. 
8 42 CFR  1007.9(d). 
9 SSA  1903(q)(1). 
10 42 CFR  1007.20.  To conduct data mining, MFCUs must receive preapproval from OIG.   
11 SSA  1128(a), 42 USC  1320a-7.  See also OIG Exclusions Background Information.  Accessed at 
http://oig.hhs.gov/exclusions/background.asp on February 7, 2019. 
12 42 CFR  1007.15. 
13 MFCU performance standards are published at 77 Fed. Reg. 32645 (June 1, 2012).   
14 To calculate the ROI for MFCUs, we first calculated the total recoveries by adding the  
$314 million in criminal case recoveries to $545 million in civil case recoveries.  We then divided the $859 million in 
total recoveries by the total MFCU grant expenditures of $294 million, resulting in the overall ROI of $2.92. 
15 One large $268 million-dollar case was prosecuted in FY 2017 that accounted for about 39 percent of all criminal 
recoveries in FY 2017.  This case came from the Texas MFCU, which prosecuted the case involving a doctor and other 
codefendants who defrauded Medicaid and Medicare by improperly recruiting individuals and falsifying medical 
documents. 
16 Middle District of Florida, U.S. Attorneys Office, Two Behavioral Health Clinic Operators Sentenced To Prison In 
Healthcare Fraud Conspiracy.  Accessed at https://www.justice.gov/usao-mdfl/pr/two-behavioral-health-clinic-
operators-sentenced-prison-health-care-fraud-conspiracy on February 7, 2019. 
17 To calculate the percentages for civil global and nonglobal recoveries, we used the total civil recoveries of  
$544,827,273 million. 
18 U.S. Department of Justice, Dental Management Company Benevis and Its Affiliated Kool Smiles Dental Clinics to Pay 
$23.9 Million to Settle False Claims Act Allegations Relating to Medically Unnecessary Pediatric Dental Services.  
Accessed at https://www.justice.gov/opa/pr/dental-management-company-benevis-and-its-affiliated-kool-smiles-
dental-clinics-pay-239 on February 7, 2019. 
19 State of Alaska, Department of Law, The ARC of Anchorage to Pay Nearly $2.3 Million Dollars to Settle Medicaid False 
Claims Act Allegations.  Accessed at http://law.alaska.gov/press/releases/2018/042418-MFCU.html on  
February 21, 2019. 
20 Since publication of Medicaid Fraud Control Units Fiscal Year 2017 Annual Report, we have amended the indictment 
rates for FYs 2015-2017 to reflect the most current data as revised by the Units. 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  27 
OEI-09-19-00230   
ACKNOWLEDGMENTS 
Christina Lester served as the team leader for this study, and Kira Evsanaa 
served as the lead analyst.  Office of Evaluation and Inspections staff who 
provided support include Susan Burbach, Jordan Clementi, Matt DeFraga, 
Kevin Farber, and Keith Peters.  
We would also like to acknowledge the contributions of other Office of 
Inspector General staff, including, Alexis Crowley, Lonie Kim,  
Christine Moritz, and Jessica Swanstrom.   
This report was prepared under the direction of Blaine Collins, Regional 
Inspector General for Evaluation and Inspections in the San Francisco 
regional office, and Abby Amoroso and Michael Henry, Deputy Regional 
Inspectors General; and in consultation with Richard Stern, Director of the 
Medicaid Fraud Policy and Oversight Division.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
To obtain additional information concerning this report or to obtain copies, 
contact the Office of Public Affairs at Public.Affairs@oig.hhs.gov.
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report  28 
OEI-09-19-00230   
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: 
Office of Audit  The Office of Audit Services (OAS) provides auditing services for HHS, either 
by conducting audits with its own audit resources or by overseeing audit 
Services 
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  The Office of Evaluation and Inspections (OEI) conducts national evaluations 
to provide HHS, Congress, and the public with timely, useful, and reliable 
and Inspections 
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  The Office of Investigations (OI) conducts criminal, civil, and administrative 
investigations of fraud and misconduct related to HHS programs, 
Investigations 
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. 
Office of Counsel to  The Office of Counsel to the Inspector General (OCIG) provides general 
legal services to OIG, rendering advice and opinions on HHS programs and 
the Inspector 
operations and providing all legal support for OIGs internal operations.  
General 
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. 
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report   
OEI-09-19-00230