HHS OIG Risk Alert  March 2018  OEI-05-16-00510 
Reliance on Unverified Patient Lists Creates 
a Vulnerability in Home Health Surveys 
Executive Summary  Home health is a program area 
Key Takeaway 
susceptible to fraud, waste, and abuse.  
Home health surveyors rely on 
To ensure that home health agencies 
lists supplied by HHAs to 
(HHAs) comply with Medicare 
select patients for review, 
standards, Medicare requires them to 
which creates a vulnerability 
undergo onsite surveys conducted by 
because HHAs could conceal 
State survey agencies or accrediting 
fraudulent activity or health 
organizations prior to initial enrollment 
and safety violations by 
and at least once every 36 months 
omitting patients from those 
thereafter.  As part of this process, 
lists.  Some HHA-supplied 
however, surveyors use HHA-supplied 
patient lists we reviewed were, 
lists to select patients for review, 
in fact, missing Medicare 
prompting concern that HHAs could 
beneficiaries, although we do 
manipulate these lists to avoid scrutiny 
not know the reasons for these 
of certain patients. 
omissions. 
 
We found that some HHA-supplied 
patient lists in our review were missing Medicare beneficiaries, allowing 
them to be excluded from surveyor reviews.  We also found that surveyors 
cannot comprehensively verify that HHA-supplied patient lists are complete 
at the time they conduct their surveys.  However, existing data sources may 
be useful tools both for surveyors and the Centers for Medicare & Medicaid 
Services (CMS). 
The Office of Inspector General (OIG) encourages CMS to explore actions to 
mitigate this vulnerability, including using existing data to provide better 
information for surveyors and conducting retrospective reviews. 
 
Background  Medicare Home Health Benefit 
The Medicare home health benefit is available to qualifying homebound 
individuals and covers skilled nursing care, home-based assistance, and   
therapeutic services.1  The goal is to treat illness or injury in the convenience 
of a patients home, which is usually less expensive than doing so at 
a hospital or skilled nursing facility.  In 2016, Medicare covered home health 
care for more than 3.4 million patients, resulting in total payments of 
$18.2 billion to more than 11,000 HHAs.2 
Home Health Fraud Concerns 
Home health has long been recognized by OIG and CMS as a program area 
vulnerable to fraud, waste, and abuse.  OIG home health investigations have 
resulted in more than 350 criminal and civil actions and yielded $975 million 
for fiscal years 20112015.3  Additionally, CMS has imposed moratoria on 
new HHA applications in selected geographic areas since 2013, citing a high 
risk of fraud, waste, and abuse.4  While home health fraud schemes vary in 
nature, OIG investigations commonly find that HHAs are billing for services 
that are not medically necessary and/or not provided.5  For example, in 
April 2016 a Dallas physician and three HHA owners were convicted for their 
participation in a nearly $375 million fraud scheme that included falsifying 
documentation to make it appear as though beneficiaries qualified for 
home health care and that skilled nursing services were provided.6 
Home Health Survey Process 
The home health survey process is an important safeguard to ensure that 
HHAs comply with Medicare standards.  Onsite surveys determine whether 
HHAs services meet minimum health and safety requirements, which are 
detailed in the Medicare Conditions of Participation.7  HHAs may choose 
either to have their surveys conducted by State survey agencies on behalf of 
CMS, orfor a feeby CMS-approved accrediting organizations.8  (In this 
report, we refer to State survey agencies and accrediting organizations as 
surveyors.)  Surveyors conduct a survey prior to an HHAs initial 
enrollment and conduct recertification surveys at least once every 
36 months thereafter.  Home health surveys are unannounced, which 
enables surveyors to observe the conditions and care practices that are 
typically present at the HHA. 
Patient Lists 
When conducting a home health survey, surveyors choose a sample of 
patients to review from patient lists (supplied by the HHA) and information 
compiled prior to the survey.  According to CMSs State Operations Manual, 
surveyors should use HHA-supplied patient lists to help choose a sample of 
patients.9  Surveyors generally ask HHAs to supply patient lists, including the 
following: 
  a roster, which is a list of all active patients at the time of the survey; 
and 
  an admissions list, which is a list of patient admissions prior to the 
survey. 
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To help choose a patient sample, surveyors use these patient lists and 
information they have compiled prior to the survey, such as past complaints 
against the HHA and reports based on Outcome and Assessment 
Information Set (OASIS) data.10  For example, if an OASIS report noted 
a high rate of injury caused by falls or home accidents at an HHA, the 
surveyor might select a patient with such an injury for review.  After 
completion of the survey, surveyors may retain HHA-supplied patient lists, 
but they do not always do so. 
Patient Reviews 
For the patients in the sample, surveyors conduct either record reviews only 
or record reviews with home visits.11  Record reviews involve examining 
documentation related to a patients care.  Surveyors may, for example, 
check whether services provided are consistent with a patients diagnosis 
and plan of care.  Home visits, which bring an additional level of scrutiny, 
involve observing how HHA staff deliver care in the patients home, and 
may include patient interviews.  Prior to a home visit, a HHA staff member 
will typically call the patient for verbal consent.  Surveyors can conduct 
record reviews for inactive as well as active patients, whereas they conduct 
record reviews with home visits for active patients only. 
 
MMeetthhooddoollooggyy   To complete this study, we conducted interviews on the survey process and 
did a retrospective comparison of HHA-supplied patient lists and Medicare 
claims data.  In March 2017, we interviewed five State survey agencies 
(California, Illinois, Florida, Michigan, and Texas), the four CMS regional 
offices associated with those five States, the three CMS-approved 
accrediting organizations, and the CMS central office.  We asked surveyors 
questions about their processes for surveying HHAs and whether they retain 
HHA-supplied patient lists after completing surveys.  Of the eight surveyors 
(five survey agencies and three accrediting organizations) we interviewed, 
only three (survey agencies in California, Florida, and Texas) reported 
retaining HHA-supplied patient lists.  For a selection of high-risk HHAs in 
these States, we collected patient lists (including rosters and admission lists, 
where available) from recertification surveys conducted by survey agencies 
in calendar years 20142016.12  We ended up with patient lists for 28 surveys 
in our review.  Using claims data, we identified the HHAs Medicare 
beneficiaries who were active on the roster date.  We then compared these 
beneficiary names against HHA-supplied rosters to identify any missing 
beneficiaries.  In doing so, we checked additional Medicare data for 
potential explanations as to why active beneficiaries might be absent from 
rosters.  We also determined whether beneficiaries who were missing from 
rosters were absent from available HHA-supplied admissions lists. 
For further details on our methodology, see Appendix A. 
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Limitations 
Our results are based on a selection of HHAs that is not representative, and 
therefore cannot be generalized to the overall population of HHAs.  
Additionally, our results cannot speak to whether beneficiaries were missing 
from rosters as a result of intentional, rather than accidental, omission. 
 
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.   
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ANALYSIS RESULTS 
 
Some HHAs  Nine of the  
Exhibit 1:  Results of Roster Review 
28 HHA-supplied 
Supplied Incomplete   
rosters we reviewed 
Lists, Allowing 
were incomplete.  Each 
Patients To Be  of these nine rosters 
was missing one or 
Excluded From 
more Medicare 
Surveyor Reviews 
beneficiaries who, per 
claims data, were active 
on the roster date.  
Two of the 9 rosters     
were missing 10 or 
more active  19  9 
beneficiaries, including 
Rosters Were  Rosters Were 
1 roster that was 
Complete  Incomplete 
missing more than 
150or nearly 
90 percentof the  Source:  OIG analysis, 2017. 
HHAs active 
beneficiaries. 
Because these nine rosters were incomplete, the missing beneficiaries would 
have been excluded from consideration for record reviews with home visits, 
the higher level of patient review.  To select patients for this level of review, 
surveyors use the HHA-supplied roster of the HHAs active patients.  
Accordingly, any active patients missing from rostersincluding the missing 
Medicare beneficiaries we identifiedwould not be considered for record 
reviews with home visits.13  
For two of the nine rosters, missing beneficiaries 
One HHA was missing over   would have been excluded from consideration for 
150or nearly 90 percentof its  review altogether.  These two rosters were 
active beneficiaries  missing one or more beneficiaries who were also 
absent from HHA-supplied admissions lists.  The 
surveyor would therefore have been unaware that 
those beneficiaries had ever been patients of the HHAs, and accordingly 
would have excluded them from consideration for both levels of  
reviewrecord reviews with home visits and record reviews only.  
Our analysis could not determine the reasons why beneficiaries were 
missing from the rosters we reviewed.  There are many possible reasons 
why patients might be missing from HHA-supplied lists, ranging from 
inadvertent errors to intentional omissions aimed at avoiding surveyor 
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scrutiny.  The likelihood of intentional omissions may be greater for the 
rosters in our review, however, given the high-risk nature of the HHAs we 
selected.  Moreover, omitting patient names from rosters is not the only 
tactic that an HHA might use to avoid surveyor scrutiny of certain  
patientssee the Related Issue box below for more information.14 
 
Related Issue:  One HHA may have discharged patients to avoid surveyor scrutiny 
  For one of our selected HHAs, four Medicare beneficiaries were discharged on the roster date, 
but readmitted to the HHA later in the year. 
  The beneficiaries did not have other claims that would explain the break in care, such as being 
admitted to a hospital, a skilled nursing facility, or another HHA between the discharge and 
readmission. 
  These discharges may reflect an intentional effort to avoid surveyor scrutiny of the 
beneficiaries, rather than appropriate decisions made on the basis of clinical condition and 
care needs. 
  In a June 2016 data brief (OEI-05-16-00031), OIG highlighted frequent discharging and 
readmitting of beneficiaries as a common characteristic in home health fraud cases.14 
 
 
Surveyors Cannot  Surveyors are unable to verify that HHA-supplied patient lists are complete, 
creating a vulnerability that could be exploited by unscrupulous HHAs 
Comprehensively 
seeking to avoid scrutiny of certain patients.  In interviews, surveyors and 
Verify Patient Lists, 
CMS both confirmed that patient lists cannot be comprehensively verified at 
but Existing Data  the time of the survey, meaning that surveyors rely on HHAs to provide 
Sources May Be  correct information.  HHAs that wish to avoid scrutiny of certain patients
for example, to conceal fraudulent activity or health and safety  
Useful Tools 
violationscould intentionally omit those patients from the lists they supply 
to surveyors.  While our analysis of patient lists cannot speak to the intent of 
the selected HHAs, the nine rosters that we found to be missing Medicare 
beneficiaries demonstrate that surveyors have received incomplete patient 
lists in past surveys. 
In discussing whether and how HHA-supplied patient lists could be verified, 
surveyors and CMS noted two existing data sources as potentially useful 
tools.  First, surveyors and CMS suggested that HHA-supplied patient lists 
could be checked against reports based on OASIS data.  HHAs are required 
to submit OASIS data for assessments of all Medicare and Medicaid 
beneficiaries, and Medicare will pay home health claims only when a valid 
OASIS submission has been received.15  Second, one surveyor suggested 
that HHA-supplied patient lists could be checked against data from home 
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health claims, and reported having explored the idea of using Medicaid 
claims data in that capacity. 
While neither data source is sufficient to comprehensively verify 
HHA-supplied patient lists at the time of the survey (because of allowable 
delays in data submission), both data sources can still be useful tools for 
surveyors and CMS.  HHAs are allowed to submit both OASIS data and 
home health claims within established timeframes following patient 
assessments and episodes of care, respectively.16, 17  Accordingly, neither 
data source can be expected to reliably reflect all of an HHAs current 
Medicare and Medicaid beneficiaries at a given point (i.e., at the time of the 
survey), because the HHA may not yet have made OASIS or claims 
submissions for beneficiaries admitted recently.  Even with this limitation, 
however, both data sources can still be useful tools.  OASIS data should 
reflect most of an HHAs beneficiaries at the time of the survey (i.e., all those 
except recent admissions), and could thus be used to verify that most, if not 
all, of an HHAs beneficiaries are included on the HHA-supplied patient list.  
Additionally, both OASIS data and claims data could be used to 
comprehensively verify HHA-supplied patient lists retroactively, once all 
submissions have been received from the HHA. 
In the absence of comprehensive verification, some surveyors noted other 
possible ways to limit potential HHA manipulation of patient lists.  
Specifically, one surveyor suggested that monitoring HHA staff as they 
retrieve or compile patient lists during unannounced surveys could 
discourage attempts to omit patients.  Another surveyor suggested that 
direct access to HHAs electronic health records could allow surveyors to 
compile patient lists themselves, thereby lessening the likelihood that HHA 
staff would be able to omit patients. 
 
   
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LOOKING AHEAD 
Our review found that some patient lists from the selected HHAs were 
missing Medicare beneficiaries.  Because surveyors cannot comprehensively 
verify that HHA-supplied patient lists are complete at the time of the survey, 
these results highlight an underlying vulnerability in the survey process that 
could be exploited to conceal fraudulent activity or health and safety 
violations.  It is important to note, however, that failing to furnish records or 
other information to surveyors necessary to verify compliance with 
Medicares Conditions of Participation may be grounds for termination from 
the program.18 
While this vulnerability could undermine broader program integrity efforts 
in the area of home health, CMS has opportunities to mitigate the risk that 
the vulnerability poses.  OIG has identified some potential strategies, 
described below, and we encourage CMS to explore the costs and benefits 
of these and other actions to protect Medicare and its beneficiaries.1920 
 
Potential Strategies To Mitigate Risk 
  Create new OASIS-based reports or adapt existing reports for 
surveyors 
For example, CMS could develop new OASIS-based reports (or 
adapt existing reports) that match the parameters of 
HHA-supplied patient lists, and could make those reports 
available to surveyors at the time of the survey.19  While such 
reports would be limited by the absence of some recently 
admitted patients, they would represent an improvement over 
relying on HHA-supplied patient lists alone. 
  Conduct retrospective reviews using claims data 
Additionally, CMS could conduct retrospective reviews of patient 
lists using OASIS data or Medicare and Medicaid claims data, 
similar to what we did in this study, to test for completeness.  
Such reviews could, for instance, identify HHAs to be investigated 
or approached with a higher level of scrutiny at the next survey.  
To facilitate these reviews, CMS would first need to ensure that 
surveyors retain HHA-supplied patient lists after completing their 
surveys. 
 
 
 
 
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Potential Strategies To Mitigate Risk (Continued) 
  Direct surveyors to monitor HHA staff as they retrieve patient lists 
CMS could also consider directing surveyors to proactively 
monitor HHA staff as they generate or retrieve patient lists.  
CMSs State Operations Manual currently advises that if surveyors 
have suspicions or concerns about a given HHA, they should 
directly obtain patient consent for home visits, rather than rely on 
HHA staff to do so, as is the standard practice.20  CMS could add 
similar language with respect to monitoring how HHAs generate 
or retrieve patient lists. 
  Direct surveyors to confirm that patient lists include a subset of 
active patients 
Finally, CMS could consider directing surveyors to interview 
a randomly selected nurse or aide working for the HHA, so that 
the surveyor can obtain information about all patients whom that 
individual is currently treating.  The surveyor could then check 
those patients against HHA-supplied patient lists to ensure that 
none are missing.  CMS staff presented this strategy to OIG as 
one that it may explore.  While the approach would not 
comprehensively verify HHA-supplied patient lists, we agree that 
it would provide greater assurance that the lists are complete. 
 
   
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APPENDIX A:  Detailed Methodology 
State Selection 
We selected five States using the results of our June 2016 data brief and 
data from CMSs Certification and Survey Provider Enhanced Reporting 
(CASPER) system.  We started with the 562 HHAs from the data brief that 
were outliers with regard to 2 or more characteristics commonly found in 
OIG home health fraud investigations; we consider these HHAs to be high 
risk.21  We used data from CMSs CASPER system to determine which of 
these 562 HHAs had received a recertification survey during calendar years 
(CYs) 20142016.22  Finally, we grouped these HHAs by State, and 
purposively selected the five States with the greatest number of identified 
HHAs (Texas, Michigan, Florida, California, and Illinois).  Please see a 
summary of this information in Exhibit 2. 
Exhibit 2:  Selected States With the Most High-Risk HHAs  
High-Risk HHAs With Recertification 
Surveys in CYs 20142016 
CMS 
State 
Surveyed by  Surveyed by 
Region 
State survey  accrediting  Total 
agencies  organizations 
Texas  6  172  52  224 
Michigan  5  19  39  58 
Florida  4  9  32  41 
California  9  7  14  21 
Illinois  5  16  0  16 
Source:  OIG analysis of results from June 2016 data brief and data from CMSs CASPER system. 
Interviews 
We interviewed the survey agencies for the five selected States, the four 
associated CMS regional offices, the three accrediting organizations 
approved by CMS to survey HHAs, and the CMS central office.  In the 
interviews, we inquired about surveyors survey processes, focusing on 
whether and how they use HHA-supplied patient lists to identify HHA 
patients for review.  We inquired about any tools or processes that the 
surveyors or CMS use to independently verify the accuracy of HHA-supplied 
patient lists.  As part of the interviews, we also determined whether each 
surveyor retains HHA-supplied patient lists after completing surveys.  None 
of the accrediting organizations and only three of the five State survey 
agencies (Florida, Texas, and California) reported retaining patient lists. 
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Patient List Comparison 
We requested patient lists from completed HHA recertification surveys, 
ultimately including patient lists for 28 distinct surveys in our review.  We 
selected 30 recertification surveys of high-risk HHAs that were conducted by 
the survey agencies in Texas, Florida, and Californiathe survey agencies 
that reported retaining HHA-supplied patient listsin calendar years  
20142016.  Specifically, we selected 18 of the 172 surveys in Texas, 7 of the 
9 surveys in Florida, and 5 of the 7 surveys in California (see Exhibit 2).23  We 
also invited each survey agency to submit patient lists from up to five 
additional recertification surveys for HHAs that it considered to be high risk, 
and we received patient lists for nine additional surveys in total.  We 
excluded three surveys from our review because they did not meet our 
criteria, and we excluded an additional eight surveys because we did not 
receive a roster.24 
We then compared Medicare claims data to HHA-supplied rosters for the 
28 surveys to identify missing Medicare patients.  Using Medicare claims 
data, we identified HHA beneficiaries who were active on the roster date.  
We then checked whether those active beneficiaries appeared on the 
rosters.  For active beneficiaries who did not appear on the rosters, we 
checked additional Medicare data for several potential explanations for their 
absence:  having been admitted to or discharged from the HHA on the 
roster date; having been an inpatient in a hospital or skilled nursing facility 
on the roster date; or having died on the roster date.  If an active 
beneficiary who did not appear on the roster did not fit into any of these 
categories, we considered him or her to be missing.  We also checked 
admissions lists, where available, to see if beneficiaries who were missing 
from rosters were absent from these documents as well.   
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ACKNOWLEDGMENTS 
Adam Freeman served as the team leader for this study, and  
Lauren Anderson served as the lead analyst.  Office of Evaluation and 
Inspections staff who provided support include Joe Chiarenzelli,  
Althea Hosein, and Christine Moritz. 
This report was prepared under the direction of Thomas Komaniecki, 
Regional Inspector General for Evaluation and Inspections in the Chicago 
regional office, and Laura Kordish, Deputy Regional Inspector General.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
To obtain additional information concerning this report or to obtain copies, 
contact the Office of Public Affairs at Public.Affairs@oig.hhs.gov.
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ENDNOTES 
1 Social Security Act,  1812(a)(3), 1814(a)(2)(C), 1832(a)(2)(A), 1835(a)(2)(A) and 1861(m). 
2 OIG analysis of Medicare claims data, 2017. 
3 This total includes investigative receivables due to HHS as well as non-HHS investigative receivables (e.g., amounts 
due to State Medicaid programs and private health care programs). 
4 83 Fed. Reg. 41474151 (January 30, 2018). 
5 OIG, Alert: Improper Arrangements and Conduct Involving Home Health Agencies and Physicians (June 2016).  
Accessed at https://oig.hhs.gov/compliance/alerts/guidance/HHA_%20Alert2016.pdf on November 22, 2016. 
6 Department of Justice, Dallas Doctor and Three Dallas-Area Home Health Agency Owners Convicted for Running 
Large-Scale, Sophisticated Health Care Fraud Scheme (April 13, 2016).  Accessed at https://www.justice.gov/usao-
ndtx/pr/dallas-doctor-and-three-dallas-area-home-health-agency-owners-convicted-rusnning-large on 
August 15, 2017. 
7 See 42 CFR pt. 488, subpt. I and 42 CFR pt. 484. 
8 CMS, State Operations Manual, ch. 2, ch. 10, and Appendix B, issued with Survey & Certification Memorandum 
14-4-HHA (May 2014).  Accessed at https://www.cms.gov/Medicare/Provider-Enrollment-and-
Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-14-14.pdf on November 9, 2016.  The 
three accrediting organizations approved by CMS to survey HHAs are the Joint Commission, the Community Health 
Accreditation Program, and the Accreditation Commission for Health Care, Inc. 
9 CMS, State Operations Manual, Appendix B (May 2014), pp. 1923. 
10 OASIS is a group of data elements that cover a comprehensive assessment for a home care patient and form the 
basis for measuring patient outcomes (CMS, OASIS Background.  Accessed at https://www.cms.gov/Medicare/Quality-
Initiatives-Patient-Assessment-Instruments/OASIS/Background.html on September 28, 2017).  Although OASIS data 
submissions are required only for Medicare and Medicaid patients, any HHA patient is eligible to be included in a 
surveyors patient review (CMS, State Operations Manual, Appendix B (May 2014), p. 19). 
11 Surveyors conduct record reviews only for half of the patients in the sample, and conduct record reviews with home 
visits for the other half of patients in the sample.  See CMS, State Operations Manual, Appendix B (May 2014), p. 22. 
12 Surveyors provided us with additional types of HHA-supplied documents, including discharge lists, visit schedules, 
and complaint logs, which we did not include in our review. 
13 It is possible that missing beneficiaries might have been considered for review if surveyors identified them through 
other means, such as inclusion on an OASIS report. 
14 OIG, Nationwide Analysis of Common Characteristics in OIG Home Health Fraud Cases, OEI-05-16-00031, June 2016. 
15 See 42 CFR  484.20(a) and 484.210(e). 
16 OASIS data may be submitted up to 30 days after the assessment is completed.  See 42 CFR  484.20(a). 
17 Medicare pays for home health services on the basis of 60-day episodes of care.  Claims may be submitted up to 
one year after the end of an episode of care.  See CMS, Medicare Claims Processing Manual, ch. 1,  70. 
18 CMS may terminate provider agreements for refusal to permit access by CMS (or on behalf of CMS) to fiscal or 
other records as necessary for verification of information furnished as a basis for payment under Medicare, or for 
refusal to permit copying of any records or other information by CMS (or on behalf of CMS) as necessary to 
determine or verify compliance with participation requirements.  See 42 CFR  489.53(a)(5) and 489.53(a)(13). 
19 An OASIS-based HHA Roster report is currently available, but its parameters do not match the State Operations 
Manuals parameters for the HHA-supplied roster.  Use of this report is also not required for surveyors. 
20 CMS, State Operations Manual, Appendix B (May 2014), p. 27. 
21 OIG, Nationwide Analysis of Common Characteristics in OIG Home Health Fraud Cases, OEI-05-16-00031, June 2016. 
22 We chose this 3-year timeframe because recertification surveys are required every 36 months for HHAs. 
23 We purposively chose the number of surveys to select for each State, but randomly selected the specific HHAs 
within each State. 
24 Surveys that did not meet our criteria were conducted by accrediting organizations even though CASPER data had 
indicated that they were conducted by State survey agencies. 
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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.