Department of Health and Human Services 
OFFICE OF 
 
INSPECTOR GENERAL 
 
 
 
 
 
 
 
 
A S M
RKANSAS  TATE  EDICAID 
 
 
F C U :   
RAUD  ONTROL  NIT   
 
2  013 O R
  NSITE  EVIEW 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
  Stuart Wright  
 
Deputy Inspector General for 
 
Evaluation and Inspections 
 
September 2013 
OEI-06-12-00720   
   
EXECUTIVE SUMMARY:  ARKANSAS STATE MEDICAID FRAUD CONTROL UNIT:                        
2013 ONSITE REVIEW 
OEI-06-12-00720  
 
WHY WE DID THIS STUDY  
The Office of Inspector General (OIG) oversees all Medicaid Fraud Control Units (MFCU or 
Unit) with respect to Federal grant compliance.  As part of this oversight, OIG conducts periodic 
reviews of all Units and prepares public reports based on these reviews.  The reviews describe 
the Units caseloads; assess performance in accordance with the 12 MFCU performance 
standards; identify any opportunities for improvement; and identify any instances of 
noncompliance with laws, regulations, and policy transmittals.  
 
HOW WE DID THIS STUDY  
We based our review on an analysis of data from seven sources:  (1) a review of policies, 
procedures and documentation of the Units operations, staffing, and caseload; (2) a review of 
financial documentation; (3) structured interviews with key stakeholders; (4) a survey of Unit 
staff; (5) structured interviews with the Unit director and supervisors; (6) an onsite review of 
case files; and (7) an onsite review of Unit operations conducted in January 2013.  
 
WHAT WE FOUND  
For fiscal years (FY) 2010 through 2012, the Arkansas Unit obtained 27 criminal convictions 
and 43 civil settlements, and reported recoveries of nearly $42 million.  Our review of 
compliance issues found no evidence of significant noncompliance with applicable laws, 
regulations, or policy transmittals.  However, we identified six instances in which the Unit did 
not fully adhere to performance standards.  Opportunities for improvement in the Units 
adherence to the performance standards include, but are not limited to, establishing policies and 
procedures specific to the Units operations, updating the Units memorandum of understanding 
with the State Medicaid agency to reflect current law, working with the State Medicaid agency to 
ensure an adequate number of referrals from  the State Medicaid agency, including supervisory 
review and approval documentation in case files, ensuring indirect costs are correctly reported, 
and establishing and maintaining an annual training plan.   
 
WHAT WE RECOMMEND 
On the basis of these findings, we recommend specific improvements to ensure that the Arkansas 
Unit fully adheres to each of the performance standards for which we had findings.  The Unit 
concurred with each of our six recommendations.  
 
 
 
 
 
 
     
   
 
TABLE OF CONTENTS 
Objective..................................................................................................................1 

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

Methodology............................................................................................................3 

Findings....................................................................................................................6 

For FYs 2010 through 2012, the Arkansas Unit obtained 27 criminal                               

convictions and 43 civil settlements, and reported recoveries of                                           

nearly $42 million ........................................................................................6 

The Unit did not have policies and procedures specific to its operations ....6 

The Units MOU with the State Medicaid agency had not been                           

updated to reflect current law  ....................................................................7 

Although the Unit worked with the State Medicaid agency, the Unit 

accepted only 10 fraud referrals over our 3-year review period  ..................7 

The Units case files lacked evidence of supervisory review                                     

and approval.................................................................................................8 

The Unit incorrectly reported indirect costs ................................................8 

The Unit did not maintain an annual training plan ......................................9 

The Unit reported beneficial outreach activities..........................................9 
 
Conclusion and Recommendations ........................................................................10 

Appendixes ............................................................................................................12 

A: 	1994 Performance Standards ...............................................................12 

B: 	2012 Performance Standards................................................................16 

C: 	Point Estimates and Confidence Intervals Based on  

Case File Reviews.................................................................................23 

D: Unit Comments ....................................................................................24 

Acknowledgments..................................................................................................28 

     
   
OBJECTIVE 
To conduct an onsite review of the Arkansas State Medicaid Fraud Control 
Unit (MFCU or Unit). 
BACKGROUND 
The mission of State MFCUs, as established by Federal statute, is to 
investigate and prosecute fraud and patient abuse and neglect by Medicaid 
providers under State law.1  Pursuant to Title XIX of the Social Security 
Act (SSA), each State must maintain a certified Unit unless the Secretary  
of Health and Human Services (HHS) determines that operation of a Unit 
would not be cost-effective because (1) minimal Medicaid fraud exists in  
that State and (2) the State has other, adequate safeguards to protect 
Medicaid beneficiaries from abuse and neglect2.  Currently, 49 States and 
the District of Columbia (States) have created such Units.3,4  In Federal 
fiscal year (FY) 2012, combined Federal and State grant expenditures for 
the Units totaled $217.4 million.5      
To carry out its duties and responsibilities in an effective and efficient 
manner, each Unit must employ an interdisciplinary staff that consists of 
at least an investigator, an auditor, and an attorney.6 Unit staff review 
complaints provided by the State Medicaid agency and other sources and 
determine their potential for criminal prosecution and/or civil action.  In 
FY 2012, the 50 Units collectively reported 1,337 convictions, 823 civil 
settlements or judgments, and recoveries of approximately $2.9 billion.7, 8   
 
1 Social Security Act (SSA)  1903(q).  

2 Ibid.,  1902(a)(61) and  1903(q)(3).  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. 

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  Office of Inspector General (OIG) Medicaid Fraud Control Units.   Accessed at   
              
http://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/index.asp on May 22, 2013.  

5 OIG,  State Medicaid Fraud Control Units  Fiscal Year 2012 Grant Expenditures and 

Statistics. Accessed at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2012-statistical-chart.htm on March  8, 2013. 

6 SSA  1903(q)(6) and  42 CFR   1007.13.  

7 OIG,  State Medicaid Fraud Control Units  Fiscal Year 2012 Grant Expenditures and 

Statistics. Accessed at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2012-statistical-chart.htm on March  8, 2013. 

8 Ibid. Recoveries are defined as the amount  of money that defendants are required to 

pay as a result of a settlement, judgment, or pre-filing settlement in criminal and civil 

cases and may not reflect actual collections.  Recoveries may involve cases that include 
 
participation by other Federal and State agencies. 

Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   1   
   
Units are required to have either Statewide authority to prosecute cases or 
formal procedures to refer suspected criminal violations to an office with 
such authority.9  If the Unit is in a State which does not have an entity with 
statewide authority to criminally prosecute individuals, the Unit must have 
formal procedures approved by OIG to assure that cases are referred to 
State entities with criminal prosecutorial authority and assure that the State 
entities cooperate with the Unit.10  In Arkansas and 43 other States, the 
Units are located within offices of State Attorneys General; in the 
remaining 6 States, the Units are located in other State agencies.11 Each 
Unit must be a single, identifiable entity of State government, distinct 
from the single State Medicaid agency, and must develop a formal 
agreement (i.e., MOU) that describes its relationship with that agency.12   
Oversight of the MFCU Program 
The Secretary of HHS delegated to OIG the authority to annually certify the 
Units and to administer grant awards to reimburse States for a percentage of 
their costs of operating certified Units.13   All Units are currently federally 
funded on a 75-percent matching basis, with the States contributing the 
remaining 25 percent.14  To receive Federal reimbursement, each Unit must 
submit an application to OIG.15  OIG reviews the application and notifies the 
Unit if the application is approved and the Unit is certified.  Approval and 
certification are for a 1-year period; the Unit must be recertified each year 
thereafter.16    
Pursuant to Title XIX of the SSA, States must operate Units that effectively 
carry out their statutory functions and meet program requirements.17 OIG 
developed and issued 12 performance standards to define the criteria it 
applies in assessing whether a Unit is effectively carrying out statutory 
 
9  SSA  1903(q)(1).  
10  SSA  1903(q)(1)(B).  
11  Office of  Inspector General (OIG) Medicaid Fraud Control Units. Accessed at                 
http://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/index.asp on May 22, 2013. 
12 SSA  1903(q)(2);  42 CFR   1007.5 and 1007.9(d).   
13 The portion of funds reimbursed to States by the Federal  Government for its share of  
expenditures for the Federal  Medicaid program, including  the MFCUs, is  called Federal  
Financial Participation  (FFP). 
14 SSA  1903(a)(6)(B).  
15 42  CFR  1007.15(a).  
16 42  CFR  1007.15(b) and (c).  
17 SSA  1902(a)(61). 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   2   
   
functions and meeting program requirements.18  Examples include 
maintaining an adequate caseload through referrals from several sources, 
maintaining an annual training plan for all professional disciplines, and 
establishing policy and procedure manuals to reflect the Units operations.  
See Appendix A for a complete list of the 1994 performance standards used 
for this review and Appendix B for a complete list of the 2012 performance 
standards.  
Arkansas Medicaid Program 
The Arkansas Medicaid program is located within the Arkansas 
Department of Human Services.  The Arkansas Medicaid program works 
with more than 12,000 providers to provide services to over 
700,000 Arkansas Medicaid beneficiaries.  Total Arkansas Medicaid 
program expenditures for FY 2012 were nearly $4.4 billion.19  
Arkansas Unit 
The Arkansas Unit operates within the Arkansas Attorney Generals 
Office, located in the State capital of Little Rock.  The Unit expended a 
total of $2.25 million in combined Federal and State funds for FY 2012.20   
At the time of our January 2013 review, the Unit employed 22 staff 
members including 1 Deputy Attorney General, 5 Assistant Attorney 
Generals, 7 investigators, 3 support staff, 2 nurse investigators, 1 auditor, 
1 case coordinator, and 1 paralegal.  During our 3-year review period, 
59 percent of the Units open cases involved cases of patient abuse and 
neglect, including cases of theft of patient funds.  The remaining 
41 percent of open cases involved fraud. 
Previous Review  
In 2008, OIG published an onsite review of the Arkansas Unit. In that 
review, OIG found no significant issues with Arkansas adherence to the 
performance standards.  
 
18 59 Fed. Reg. 49080 (Sept.  26, 1994).  Accessed at http://oig.hhs.gov/fraud/medicaid-
fraud-control-units-mfcu/files/Performance%20Standards.pdf  on August 15, 2012.  OIG  
published revised performance standards,  effective June 1, 2012.  See 77 FR  32645  
(June 1, 2012)  for the new  performance standards.   Accessed at  
http://oig.hhs.gov/authorities/docs/2012/PerformanceStandardsFinal060112.pdf on  
August 15, 2012.  For  purposes of this review  covering FYs 20102012, we relied  on the 
1994  performance standards unless changes in the performance standards were  
significant for our review  of a particular area.  
19 OIG,  State Medicaid Fraud Control Units  Fiscal Year 2012 Grant Expenditures and 
Statistics. Accessed at  https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2012-statistical-chart.htm on March  8, 2013. 
20 Ibid.  
 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   3   
   
METHODOLOGY 
Our review covered FYs 2010 through 2012.  We based our review on an 
analysis of data from seven sources:  (1) a review of policies and 
procedures and documentation of the Units operations, staffing, and 
caseload; (2) a review of financial documentation; (3) structured 
interviews with key stakeholders; (4) a survey of Unit staff; (5) structured 
interviews with the Units director and supervisors; (6) an onsite review of 
case files that were open in FYs 2010 through 2012; and (7) an onsite 
review of Unit operations.  We analyzed data from all seven sources to 
describe the caseload; assess the performance of the Unit; identify any 
opportunities for improvement; and identify any instances in which the 
Unit did not fully meet the performance standards or was not operating in 
accordance with laws, regulations, and policy transmittals.21 In addition, 
we noted any practices that appeared  to benefit the Unit.  We based these 
observations on statements from Unit staff, data analysis, and our own 
judgment.  We did not independently verify the effectiveness of these 
practices, but included the information because it may be useful to other 
Units in their operations.  We  conducted the onsite review in 
January 2013. 
Data Collection and Analysis 
Unit Documentation Review.  We reviewed policies, procedures, and 
documentation of the Units operations, staffing, and cases, including its 
annual reports, quarterly statistical reports, and responses to recertification 
questionnaires.   
Review of Financial Documentation. We reviewed Unit policies and 
procedures related to budgeting, accounting systems, cash management, 
procurement, property, and personnel.  We obtained the Units claimed 
grant expenditures for FYs 2010 through 2012 so that we could 
(1) reconcile final Financial Status Reports and the supporting 
documentation; (2) purposively select and review transactions within 
categories of direct costs to determine whether costs were allowable; and 
(3) verify that indirect costs were accurately computed using the approved 
indirect cost rate. Finally, we verified that the Unit does not receive 
program income directly from any of its cases.   
Stakeholder Interviews. We conducted structured interviews with key 
stakeholders who were familiar with the Unit operations.  Specifically, we  
interviewed staff from the Arkansas Department of Human Services 
Medicaid Program Integrity Unit (hereafter referred to as the State 
 
21 All relevant  regulations, statutes, and  policy transmittals are available online at 
http://oig.hhs.gov. 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   4   
   
Medicaid agency or the State Medicaid agency Program Integrity Unit); 
the Arkansas Department of Human Services, Office of Long Term Care; 
an HHS OIG investigator who worked closely with the Unit during the 
review period; the United States Attorneys Office; and AdvanceMed, the 
Zone Program Integrity Coordinator that works with the Unit.  These 
interviews focused on the Units interaction with external agencies.  
Unit Staff Survey.  We administered an electronic survey to Unit 
nonmanagerial staff.  Our questions focused on operations, opportunities 
for improvement, and effective practices.   
Unit Director, Supervisor, and Staff Interviews. We conducted structured 
interviews with the Deputy Attorney General (who serves as the Unit 
director), the Assistant Deputy Attorney General, the Chief Investigator, 
the Chief Auditor, and the Chief Deputy Attorney (the supervisor of the 
Unit director). We asked respondents to provide any additional 
information to better illustrate the Units operations, identify opportunities 
for improvement and effective practices, and clarify information we 
obtained from other data sources. 
Case File Review.  We selected a statistically valid, simple random sample 
of 100 case files from the 288 cases open at some point during FYs 2010 
through 2012. We reviewed all 100 of these sampled case files for the 
following issues: documentation of supervisory approval for the opening 
and closing of cases, periodic supervisory reviews, timeliness of case 
development, and the Units processes for monitoring the status and 
outcomes of cases.  From these 100 case files, we selected a further 
random sample of 50 files for a more in-depth review of selected issues, 
such as the timeliness of investigations.  See Appendix C for point 
estimates and corresponding 95-percent confidence intervals.  
Unit Operations Review.  We reviewed the Units operations during our 
onsite visit.  Specifically, we reviewed the process for receiving referrals, 
electronic case management, security of case files, and general functioning 
of the Unit.   
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.   
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   5   
   
FINDINGS 
For FYs 2010 through 2012, the Arkansas Unit 
obtained 27 criminal convictions and 43 civil 
settlements, and reported recoveries of nearly                      
$42 million 
For FYs 2010 through 2012, the Unit filed criminal charges against                 
47 defendants and obtained 27 criminal convictions.  Over half                           
(18 of 27) of these convictions involved patient abuse and neglect 
including theft of patient funds, while the remaining 9 convictions 
involved fraud. Additionally, the Unit obtained just over $639,000 in 
criminal restitution.  See Table 1. 
Table 1: Unit Criminal Charges, Convictions, and Recoveries,                      
FYs 20102012  
 
Criminal Investigations   Charges   Convictions  
 Fraud  15  9 
Patient Abuse and Neglect  32  18 
 
     Total   47  27 
 Criminal Recoveries Obtained   $639,026  
Source:  OIG analysis of Unit  data and quarterly statistical reports, FYs 2010  through 2012, 2013. 
 
The Unit obtained 43 civil settlements, resulting in more than $41 million 
in civil recoveries.  Eighty-seven percent (about $36 million) of these 
settlements were recoveries from global settlements.22 See Table 2. 
Table 2: Unit Civil Recoveries, FYs 20102012  
Total  
Recovery  Type   FY 2010   FY 2011   FY 2012  
Recoveries  
Global  $10,176,871   $10,238,681   $15,400,578   $35,816,130  
State Only    $1,434,742   $23,661   $3,745,347   $5,203,750 
     Total   $11,611,613   $10,262,342   $19,145,925   $41,019,880  
Source:  OIG analysis of Unit  data and quarterly statistical reports, FYs 2010  through 2012, 2013.   
The Unit did not have policies and procedures
specific to its operations 
According to Performance Standard 3, the Unit should establish policies 
and procedures for its operations. The Unit used the Arkansas Office of 
the Attorney General handbook as guidance for administrative policies, 
such as those relating to hiring employees and employee benefits.  
However, at the time of our review, the Unit did not have policies and 
 
22 Global settlements originate from civil false claims cases involving the Federal 
Department of Justice and other State MFCUs. 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   6   
   
procedures specific to its operations such as the investigation and 
prosecution of Medicaid fraud and patient abuse and neglect.  During our 
onsite review, the Unit director indicated that the Unit was in the process 
of creating a MFCU-specific operations manual.  
The Units MOU with the State Medicaid agency had 
not been updated to reflect current law 
According to Performance Standard 10, the Unit should periodically 
review its MOU with the single State Medicaid agency to ensure it reflects 
current law and practice. The Unit last updated its MOU with the State 
Medicaid agency in 2010. However, at the time of our January 2013 
review, the MOU did not include a law that went into effect in 2011.  
Specifically, the MOU did not include language to address 42 CFR 
 455.23, the regulation requiring payment suspension of any provider 
against whom there is a credible allegation of fraud (effective March 25, 
2011).23   The Unit director reported that he had sent the agency language 
regarding this new regulation to incorporate into the existing MOU in the 
months prior to our onsite review. 
Although the Unit worked with the State Medicaid 
agency, the Unit accepted only 10 fraud referrals over 
our 3-year review period 
According to Performance Standard 4, the Unit should take steps to ensure 
that it maintains an adequate workload through referrals from the single 
state agency and other sources.  The State Medicaid agency Program  
Integrity Unit director and the Unit director both reported a working 
relationship that included communication and joint participation on 
healthcare fraud task forces.  The two entities described meeting at least 
monthly to discuss potential fraud referrals from the State Medicaid 
agency to the Unit. Upon discussing a potential referral, the Unit would 
determine whether to take the referrals as a case.  During the 3-year 
review period, the Unit accepted only 10 fraud referrals from the State 
Medicaid agency. Although the performance standard does not specify 
how many referrals constitute an adequate number, both entities agreed 
that 10 was a relatively small number for a 3-year period given the size of 
the State program and the number of participants and providers.   
 
 
23 42 CFR 455.23.  Accessed  at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/45523.asp on  February 28, 2013.   
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   7   
   
The Units case files lacked evidence of supervisory 
review and approval 
According to Performance Standard 6, the Unit should have a continuous 
case flow and cases should be completed in a reasonable time.  
Performance Standard 6 further specifies that Unit supervisors should 
approve the opening and closing of cases, conduct periodic case reviews, 
and note their reviews in the case file.  Our review of 100 case files found 
that case files often lacked documentation that a supervisor reviewed the 
case file and occasionally lacked documentation that a supervisor 
approved the opening of the case. See Appendix C for point estimates and 
corresponding 95-percent confidence intervals. 
Documentation of supervisory reviews. Supervisors should periodically 
conduct case reviews and note their reviews in the case files.  Sixty-four 
percent of case files did not contain documentation indicating any 
supervisory reviews. Of these case files, 17 percent may not have 
received a supervisory review because they were open less than 90 days.  
However, 83 percent of case files were open for longer than 90 days and 
did not contain evidence of a supervisory review.  The Unit director noted 
that investigators and attorneys email weekly case updates to their 
supervisors, which has served as the Units process for supervisory review  
of case files.  However, these weekly emails did not include a supervisory 
review of the case files and were not documented in the case files. 
Thirty-six percent of case files that contained evidence of a supervisory 
review. Most of these case files (92 percent) contained evidence of one 
supervisory review, and 8 percent contained evidence of more than one 
supervisory review of the case. 
Documentation of supervisory approval. Supervisors should approve the 
opening and closing of investigative cases.  Fourteen percent of the case 
files lacked documentation indicating supervisory approval to open the 
case. Four percent of case files lacked documentation indicating 
supervisory approval to close the case. 
The Unit incorrectly reported indirect costs 
According to Performance Standard 11, the Unit director should exercise 
proper fiscal control over the unit resources, such as maintaining an 
equipment inventory and applying accepted accounting principles in its 
control of Unit funding. We found that the Unit incorrectly reported 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   8   
   
indirect costs.24 Aside from cost reporting, we did not identify any 
deficiencies with internal controls related to accounting; budgeting; 
personnel; procurement; and property and equipment.   
The Unit did not maintain an annual training plan 
According to Performance Standard 12, the Unit should maintain an 
annual training plan for all professional disciplines.  Specifically, the Unit 
should have a training plan that includes a minimum number of training 
hours and the Unit should make funds available for training.  The Unit 
should also ensure that professional staff meet continuing education 
standards and that the training supports the Units mission.  Although Unit 
staff regularly attended training paid for by the Unit, such as courses 
covering medical records laws in Arkansas and the National Association 
of Medicaid Fraud Control Units annual training, the Unit did not have a 
training plan and did not track Unit staff attainment of continuing 
education hours.25   
The Unit reported beneficial outreach activities 
The Unit engaged in outreach activities that built relationships with 
stakeholders and aided in the mission of the Unit.  For example, the Unit 
director reported that veteran Unit staff were often asked to lead training 
relevant to Unit work, such as a training session by Unit investigators 
conducted for the Office of Long Term Care.  The Office of Long Term  
Care representative reported that Unit investigators trained nursing home 
surveyors on topics such as how to interview beneficiaries and how to 
develop a potential referral.    
 
24 2 CFR  255  Appendix E, (B)(2) states that the indirect cost rate is a device for  
determining in  a reasonable manner the proportion of indirect costs each program should  
bear.  It is the ratio (expressed as a percentage) of the indirect costs to  a direct cost base.  
25 Although  we reviewed training records,  we did not evaluate the staffs professional  
qualifications.  Rather, we applied the performance standards to evaluate whether the 
Unit maintained a formal training  plan  for each  professional discipline and assessed 
training  opportunities specific to  Unit operations.  We recognize that attorneys, 
investigators, and auditors receive professional and law enforcement training, and that the 
lack of an annual training  plan does not suggest that professional staff are unqualified.  
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   9   
   
CONCLUSION AND RECOMMENDATIONS 
For FYs 2010 through 2012, the Arkansas Unit obtained 27 criminal 
convictions and 43 civil settlements, and reported recoveries of nearly     
$42 million.  Unit staff and stakeholders reported beneficial outreach 
activities.  
Our review of compliance issues found no evidence of significant 
noncompliance with applicable laws or regulations.  However, we 
identified six instances in which the Unit did not fully adhere to 
Performance Standards.  We recommend that the Arkansas Unit:  
Establish Policies and Procedures Specific To Unit Operations 
The Units policies and procedures should include provisions relating to 
Unit organization, statutory authorities, investigative and litigation 
processes. The policies and procedures should also include case 
management processes such as periodic supervisory review of case files.  
Update Its MOU With The State Medicaid Agency 
The Unit should update its MOU with the State Medicaid agency to reflect 
current law. Specifically, the entities should add language to address                    
42 CFR  455.23, the regulation that allows for suspending provider 
payments based on a credible allegation of fraud. 
Work With The State Medicaid Agency To Ensure An Adequate  
Number of Referrals from the State Medicaid Agency 
Given that the Unit received only 10 fraud referrals from the State 
Medicaid agency over a 3-year period, the Unit should work with the State 
Medicaid agency to ensure it receives an adequate number of referrals.   
Ensure That All Case Files Contain Evidence of Supervisory  
Approvals and Reviews 
Unit supervisors should approve the opening and closing of all cases, 
review all cases periodically, and document these activities in the case 
files.  
Ensure Indirect Costs Are Correctly Reported 
The Unit should work with its parent agency, the Arkansas Attorney 
Generals Office, to ensure indirect costs are correctly reported.  
Establish an Annual Training Plan   
The Unit should establish an annual training plan consistent with the terms 
in the performance standard.  The training plan should include a minimum 
number of hours training requirement for all professional disciplines and a 
system to ensure professional staff meet continuing education standards.   
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   10   
   
UNIT COMMENTS AND OFFICE OF INSPECTOR GENERAL  
RESPONSE 
The Unit concurred with all of our six recommendations. 
Regarding our first recommendation, the Unit stated that it has drafted a 
MFCU-specific policies and procedures handbook that outlines Medicaid 
fraud investigations, criminal prosecutions, abuse and neglect 
investigations, and litigation or settlements. The Unit indicated the 
handbook would be completed soon. 
Regarding our second recommendation, the Unit stated that it has updated 
its MOU with the State Medicaid agency and included language that 
addressed 42 CFR  455.23, a regulation that became effective in 
March 2011 and allows for suspending provider payments based on a 
credible allegation of fraud. The Unit noted that although the prior MOU 
did not contain language specific to 42 CFR  455.23, both parties of the 
MOU had been operating under the new regulation since it became 
effective. 
Regarding our third recommendation, the Unit stated that it has begun to 
redouble its efforts to ensure that the State agency refers meritorious cases 
to the Unit. The Unit also noted that  since our onsite review, the Arkansas 
legislature created the Office of the Medicaid Inspector General, with 
which the Unit will pursue referrals.  
Regarding our fourth recommendation, the Unit stated that it will develop  
an intake form or checklist to ensure that supervisory approval of the 
opening of cases is documented in the case file.  Additionally, the Unit 
developed a form, to be kept in the case file, to ensure that all cases have a 
supervisory review every 90 days. 
Regarding our fifth recommendation, the Unit stated that it met with OIG 
grantee oversight representatives to clarify reporting procedures and 
attended a Web seminar on indirect costs.  
Regarding our sixth recommendation, the Unit stated that the Unit director 
is establishing a formal written plan that will be included in the                     
MFCU-specific handbook of policies and procedures.  
The full text of the Units comments is provided in Appendix D.  We did 
not make any changes to the report based on the Units comments.  
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   11   
   
APPENDIX A 
1994 Performance Standards  
[59 Fed. Reg. 49080, Sept. 26, 1994] 
1. 	A Unit will be in conformance with all applicable statutes, 
regulations and policy transmittals.  In meeting this standard, the 
Unit must meet, but is not limited to, the following requirements:  
a. 	  The Unit professional staff must consist of permanent employees 
working full-time on Medicaid fraud and patient abuse matters. 
b. 	  The Unit must be separate and distinct from the single State 
Medicaid agency. 
c. 	  The Unit must have prosecutorial authority or an approved formal 
procedure for referring cases to a prosecutor. 
d. 	  The Unit must submit annual reports, with appropriate 

certifications, on a timely basis. 
 
e. 	  The Unit must submit quarterly reports on a timely basis. 
f. 	  The Unit must comply with the Americans with Disabilities Act, 
the Equal Employment opportunity requirements, the Drug Free 
workplace requirements, Federal lobbying restrictions, and other 
such rules that are made conditions of the grant. 
2. 	A Unit should maintain staff levels in accordance with staffing 
allocations approved in its budget. In meeting this standard, the 
following performance indicators will be considered: 
a. 	  Does the Unit employ the number of staff that was included in the 
Unit's budget as approved by the OIG? 
b. 	  Does the Unit employ the number of attorneys, auditors, and 
investigators that were approved in the Unit's budget? 
c. 	  Does the Unit employ a reasonable size of professional staff in 
relation to the State's total Medicaid program expenditures?   
d. 	  Are the Unit office locations established on a rational basis and are 
such locations appropriately staffed? 
3. 	A Unit should establish policies and procedures for its operations, 
and maintain appropriate systems for case management and case 
tracking.  In meeting this standard, the following performance 
indicators will be considered: 
a. 	  Does the Unit have policy and procedure manuals? 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   12   
   
b. 	  Is an adequate, computerized case management and tracking 
system in place? 
4. 	A Unit should take steps to ensure that it maintains an adequate 
workload through referrals from the single State agency and other 
sources.  In meeting this standard, the following performance 
indicators will be considered:  
a. 	  Does the Unit work with the single State Medicaid agency to 
ensure adequate fraud referrals? 
b. 	  Does the Unit work with other agencies to encourage fraud 

referrals? 

c. 	  Does the Unit generate any of its own fraud cases? 
d. 	  Does the Unit ensure that adequate referrals of patient abuse 
complaints are received from all sources? 
5. 	A Units case mix, when possibl e, should cover all significant 
provider types. In meeting this standard, the following performance 
indicators will be considered:  
a. 	  Does the Unit seek to have a mix of cases among all types of 
providers in the State? 
b. 	  Does the Unit seek to have a mix of Medicaid fraud and Medicaid 
patient abuse cases? 
c. 	  Does the Unit seek to have a mix of cases that reflect the 

proportion of Medicaid expenditures for particular provider 

groups? 

d. 	  Are there any special Unit initiatives targeting specific provider 
types that affect case mix? 
e. 	  Does the Unit consider civil and administrative remedies when  
appropriate? 
6. 	A Unit should have a continuous case flow, and cases should be 
completed in a reasonable time. In meeting this standard, the 
following performance indicators will be considered:  
a. 	  Is each stage of an investigation and prosecution completed in an 
appropriate time frame?  
b. 	  Are supervisors approving the opening and closing of 

investigations?
   
c. 	  Are supervisory reviews conducted periodically and noted in the 
case file? 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   13   
   
7. A Unit should have a process for monitoring the outcome of cases.  
In meeting this standard, the following performance indicators will be 
considered:  
a. 	  The number, age, and type of cases in inventory. 
b. 	  The number of referrals to other agencies for prosecution. 
c. 	  The number of arrests and indictments. 
d. 	  The number of convictions. 
e. 	  The amount of overpayments identified. 
f. 	  The amount of fines and restitution ordered. 
g. 	  The amount of civil recoveries. 
h. 	  The numbers of administrative sanctions imposed. 
8. 	A Unit will cooperate with the OIG and other Federal agencies, 
whenever appropriate and consistent with its mission, in the 
investigation and prosecution of health care fraud.  In meeting this 
standard, the following performance indicators will be considered: 
a. 	  Does the Unit communicate effectively with the OIG and other 
Federal agencies in investigating or prosecuting health care fraud 
in their State? 
b. 	  Does the Unit provide OIG regional management, and other 
Federal agencies, where appropriate, with timely information 
concerning significant actions in all cases being pursued by the 
Unit? 
c. 	  Does the Unit have an effective procedure for referring cases,  
when appropriate, to Federal agencies for investigation and other 
action?  
d. 	  Does the Unit transmit to the OIG, for purposes of program  
exclusions under section 1128 of the Social Security Act, reports 
of convictions, and copies of Judgment and Sentence or other 
acceptable documentation within 30 days or other reasonable time 
period? 
9. 	A Unit should make statutor y or programmatic recommendations, 
when necessary, to the State government. In meeting this standard, 
the following performance indicators will be considered:  
a. 	  Does the Unit recommend amendments to the enforcement 
provisions of the State's statutes when necessary and appropriate to 
do so? 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   14   
   
b. 	  Does the Unit provide program recommendations to single State 
agency when appropriate? 
c. 	  Does the Unit monitor actions taken by State legislature or State 
Medicaid agency in response to recommendations? 
10. 	A Unit should periodica lly review its memorandum of 
understanding (MOU) with the single State Medicaid agency and 
seek amendments, as necessary, to ensure it reflects current law  
and practice.  In meeting this standard, the following performance 
indicators will be considered:  
a. 	  Is the MOU more than 5 years old? 
b.	   Does the MOU meet Federal legal requirements? 
c. 	  Does the MOU address cross-training with the fraud detection staff  
of the State Medicaid agency? 
d.	   Does the MOU address the Units responsibility to make program  
recommendations to the Medicaid agency and monitor actions  
taken by the Medicaid agency concerning those recommendations? 
11. 	The Unit director should exercise proper fiscal control over the 
Unit resources.  In meeting this standard, the following performance 
indicators will be considered:  
a. 	  Does the Unit director receive on a timely basis copies of all fiscal 
and administrative reports concerning Unit expenditures from the 
State parent agency? 
b.	   Does the Unit maintain an equipment inventory?  
c. 	  Does the Unit apply generally accepted accounting principles in its 
control of Unit funding? 
12. 	A Unit should maintain an annual training plan for all 
professional disciplines.  In meeting this standard, the following 
performance indicators will be considered:  
a. 	  Does the Unit have a training plan in place and funds available to 
fully implement the plan? 
b. 	  Does the Unit have a minimum number of hours training 
requirement for each professional discipline, and does the staff 
comply with the requirement? 
c. 	  Are continuing education standards met for professional staff? 
d. 	  Does the training undertaken by staff aid to the mission of the 
Unit?   
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   15   
   
APPENDIX B 
2012 Performance Standards  
[77 Fed. Reg. 32645, June 1, 2012] 
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. 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   16   
   
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.  
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, 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   17   
   
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 practicabl e, 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. 
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. 
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.  
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. 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   18   
   
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. 
4. 	  The number of referrals received by the Unit and the 
number of referrals by the Unit to other agencies. 
5. 	  The dollar amount of overpayments identified. 
6. 	  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. 
7. 	  The number of criminal convictions and the number of civil 
judgments. 
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. 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   19   
   
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 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   20   
   
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. 
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. 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   21   
   
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. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   22   
   
APPENDIX C 
Point Estimates and Confidence Intervals Based on Case File 
Reviews 
95-Percent  
Confidence 
Sample  Point 
Estimate Characteristic   Interval  
Size  Estimate  
Lower  Upper  
Cases in which reviewers did not find evidence that the supervisor approved opening case  100  14.0%   7.9%   22.4%  
Cases in which reviewers did not find evidence that the supervisor approved closing case  67  4.5%   0.9%   12.5%  
Cases not containing documentation indicating at least one supervisory review   100  64.0%   53.8%   73.4% 
     Open for less than 90 days   64  17.2%   8.9%   28.7% 
     Open for longer than 90 days  64  82.8%   71.3%   91.1%  
Cases not containing documentation indicating at least one periodic supervisory review  100  36.0%   26.6%   46.2% 
     Contained only one supervisory review  36  91.7%   77.5%   98.3% 
     Contained more than one supervisory review  36  8.3%   1.8%   22.5%  
Source:  Office of  Inspector General analysis of Medicaid  Fraud Control Unit  case files, 2013. 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   23   
   
APPENDIX D 
Unit Comments 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   24   
   
 
 
 
 
 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   25   
   
 
 
 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   26  Conclusion: 
The Arkansas Medicaid Fraud Control Unit appreciates the efforts of HHS-OIG and 
especially  appreciates  the  opportunity to  continue  with our most effective processes  and 
procedures,  and  to  improve  in  others.  We  concur  with  your  recommendations  and  will 
implement necessary changes as set forth above in a manner consistent with the mission and 
goals of the Unit. 
Sincerely, 
Jeanette L. Hamilton 
Deputy Attorney General 
4 
Arkansas State Medicaid Fraud Control Unit: 2013 Onsite Review (OEI-06-12-00720)  27   
   
ACKNOWLEDGMENTS 
This report was prepared under the direction of Kevin Golladay, Regional 
Inspector General for Evaluation and Inspections in the Dallas regional 
office; Blaine Collins, Deputy Regional Inspector General; and                           
Ruth Ann Dorrill, Deputy Regional Inspector General.    
Lyndsay Patty served as the Team Leader for this study.  Other Office of 
Evaluation and Inspections staff who conducted the study include          
Ben Gaddis. Office of Investigations staff who provided support include 
Kory Inkhen and Jason Weinstock.  Central office staff who provided 
support include Susan Burbach, Kevin Farber, Christine Moritz, 
Richard Stern, and Sherri Weinstein.   
 
Arkansas State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-12-00720)   28   
Office of Inspector General
http://oig.hhs.gov  
 
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 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 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 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.