Department of Health and Human Services 
OFFICE OF 
 
INSPECTOR GENERAL 
 
 
 
 
O  P
VERSIGHT OF  RIVATE 
 
H I
  EALTH  NSURANCE 
 
S
  UBMISSIONS TO THE 
 
H C .  
  EALTH ARE GOV 
 
P F
LAN  INDER
 
 
Daniel R. Levinson  
Inspector General 
 
April 2013 
OEI-03-11-00560   
EXECUTIVE SUMMARY:  OVERSIGHT OF PRIVATE HEALTH INSURANCE 
SUBMISSIONS TO THE HEALTHCARE.GOV PLAN FINDER 
OEI-03-11-00560 
 
WHY WE DID THIS STUDY  
 
The HealthCare.gov Plan Finder is the first comprehensive, online portal that assists consumers in 
comparing their health insurance coverage options.  All private health insurers in the individual and 
small group markets are required to submit information to populate the Plan Finder.  The data 
collection conducted by the Centers for Medicare & Medicaid Services (CMS) to populate the Plan 
Finder represents the first national attempt to identify these insurers and the products and plans they 
offer.  To realize the benefits of expanded consumer information, the data displayed on the Plan Finder 
must be complete and accurate.   
 
HOW WE DID THIS STUDY 
 
We reviewed CMSs policies and procedures, survey responses, and interview responses regarding 
oversight of insurers data submissions.  We selected a purposive sample of 98 small group products 
and 94 individual plans displayed on the Plan Finder for its November 2011 and January 2012 updates, 
respectively.  For each sampled product and plan, we identified aberrant or inconsistent data displayed 
on the Plan Finder and determined whether displayed data were consistent with information provided 
by insurers telephone customer service representatives. 
 
WHAT WE FOUND 
 
Most private insurers reported data to the Plan Finder.  However, gaps exist in CMSs oversight of 
private insurers compliance with Plan Finder reporting requirements.  CMS did not conduct targeted 
followup with insurers that did not report detailed pricing and benefit information.  CMS also has not 
been able to identify the entire population of insurers required to report basic company and product 
information.  In addition, CMS has not asked insurers to certify to the completeness of submitted data 
in accordance with Federal regulation.  CMS implemented numerous strategies to monitor data 
accuracy.  However, the data displayed on the Plan Finder for the sample of products and plans 
contained some inconsistencies that may confuse consumers.  The products and plans displayed were 
not always available for sale or were not always recognized by insurers representatives.  When 
products and plans were available and were recognized, 81 percent of their data displayed on the Plan 
Finder matched the information provided by insurers representatives.   
 
WHAT WE RECOMMEND  
 
Our findings indicate that additional efforts are needed to oversee private insurers compliance with 
reporting requirements for the HealthCare.gov Plan Finder and to ensure that the data displayed on the 
Plan Finder are accurate.  Therefore, we recommend that CMS:  (1) establish and implement 
procedures to identify and pursue private insurers that do not submit required data to the Plan Finder, 
(2) ensure that each private insurers Chief Executive Officer or Chief Financial Officer certifies to the 
completeness of data submitted to the Plan Finder, (3) design and implement additional strategies to 
ensure Plan Finder data accuracy, and (4) validate that products and plans submitted to the Plan Finder 
are available for sale.  CMS generally concurred with our recommendations and is taking steps to 
address them.   
TABLE OF CONTENTS 
 
Objectives ....................................................................................................1 
Background ..................................................................................................1 
Methodology ................................................................................................4 
Findings........................................................................................................8 
Gaps exist in CMSs oversight of private insurers reporting of 
required data to the HealthCare.gov Plan Finder .............................8 
Although CMS implemented numerous measures to oversee  
data accuracy, the data displayed on the Plan Finder contained  
some inconsistencies ......................................................................10 
Not all of the products and plans displayed on the Plan Finder   
were available for sale or were recognized by insurers                
representatives................................................................................14 
Eighty-one percent of product and plan data displayed on the 
Plan Finder matched information provided by insurers      
representatives................................................................................14 
Conclusion and Recommendations ............................................................17 
  Agency Comments and Office of Inspector General Response .....20 
Appendixes ................................................................................................21 
A:  Plan Finder Data Fields Included in Office of Inspector   
General Review of Information Provided by Insurers 
Representatives ..............................................................................21 
B:  Agency Comments ...................................................................22 
Acknowledgments......................................................................................25 
 
     
OBJECTIVES 
1.  To determine the extent to which the Centers for Medicare & Medicaid 
Services (CMS) oversees private health insurers compliance with 
reporting requirements for the HealthCare.gov Plan Finder. 
2.  To determine whether selected data displayed on the HealthCare.gov 
Plan Finder are consistent with other consumer information provided 
by private insurers. 
BACKGROUND  
The health care reforms enacted in 2010 seek to increase informed 
consumer choice by improving Americans access to information about 
available health insurance options.1  Section 1103 of the Affordable Care 
Act (ACA) requires the Secretary of Health and Human Services to 
establish a health insurance Web site portal that presents health insurance 
information in a standardized format and enables comparison of coverage 
options.2, 3  Information on coverage options must include private health 
insurance information, as well as government-administered health 
insurance information, such as Medicaid, the Childrens Health Insurance 
Program, State high risk pools, and the Pre-Existing Condition Insurance 
Plan.  Data collection and maintenance of the Web site portal, the 
HealthCare.gov Plan Finder, is managed by the Center for Consumer 
Information and Insurance Oversight (CCIIO) within CMS.4  
The Plan Finder is the first comprehensive, centralized, online portal that 
assists American consumers in comparing insurance coverage options.  In 
addition, the Plan Finder has the potential to increase the sale of private 
health plans to uninsured individuals and promote market competition to 
improve health coverage choices for all Americans.5  Realizing the benefits 
of expanded consumer information is contingent upon the completeness 
 
1 75 Fed. Reg. 24471 (May 5, 2010). 
2 The Patient Protection and Affordable Care Act (P.L. 111-148) and the Health Care and 
Education Reconciliation Act (P.L. 111-152) are collectively referred to as the Affordable Care 
Act. 
3 As specified in 45 CFR  159.110, health insurance coverage is defined according to  
section 2791(b)(1) of the Public Health Service Act as benefits consisting of medical care  
(provided directly, through insurance or reimbursement, or otherwise and including items and 
services paid for as medical care) under any hospital or medical service policy or certificate, 
hospital or medical service plan contract, or health maintenance organization contract offered 
by a health insurance issuer. 
4 HealthCare.gov is a Federal Web site that contains information about public and private 
health insurance options across the Nation, connects consumers to quality rankings for health 
care providers, and explains the provisions and key features of the ACA. 
5 75 Fed. Reg. 24481 (May 5, 2010). 
 
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and accuracy of the private sector health insurance data populating the Plan 
Finder.  Section 1311 of the ACA requires the Secretary to continue to 
operate, maintain, and update the Plan Finder. 
Although the Plan Finder is not a transactional Web site from which 
consumers can purchase private insurance, its formats and tools for 
displaying insurance information can inform State and Federal decisions in 
the development of Affordable Insurance Exchanges.6, 7  The Exchanges 
will serve as competitive marketplaces for consumers to compare and 
purchase health insurance.8  According to HHS, open enrollment in the 
Exchanges will begin on October 1, 2013.  The Congressional Budget 
Office (CBO) estimates that by 2016, 24 million Americans will receive 
health coverage through the Exchanges.9  
The HealthCare.gov Plan Finder 
Today, consumers seeking information about private health insurance 
options are using the Plan Finder as an education tool to find and compare 
health plans.  The Plan Finder was publicly launched on July 1, 2010, and 
had approximately 2 million visitors from July 2010 to July 2011.  As of 
March 2013, it housed information on more than 8,000 private health 
insurance products offered within the small group market and the 
individual market.  The individual market sells health insurance to 
individuals and families seeking coverage, and the small group market sells 
health insurance to small businesses seeking coverage for their 
employees.10  
Private insurers were first required to submit data to the Plan Finder in May 
2010.11  Since that time, CMS has collected updated information from 
private insurers multiple times throughout each year.  From July to 
September 2010, the Plan Finder displayed an initial set of basic 
information on private health insurance companies and their products.  For 
 
6 Ibid. 
7 Each State will have an Exchange that is operated by the State, by the State in 
partnership with the Federal Government, or by the Federal Government. 
8 ACA  1321(c) and 77 Fed. Reg. 18310 (March 27, 2012). 
9 CBO, Estimate of the Effects of the Affordable Care Act on Health Insurance Coverage, 
February 2013.  Accessed at http://www.cbo.gov on March 21, 2013. 
10 45 CFR  159.110 adopts the definitions of the terms individual market and small 
group market found in ACA section 1304(a)(2) and ACA section 1304(a)(3), 
respectively.  The term individual market is defined as the market for health insurance 
coverage offered to individuals other than in connection with a group health plan.  The 
term small group market is defined as the market under which individuals obtain health 
insurance coverage (directly or through an arrangement) on behalf of themselves (and 
their dependents) through a group health plan maintained by a small employer. 
11 45 CFR  159.120(a).  The regulation text includes the term health insurance issuers.  
In this report, we use the term insurers, rather than issuers.  
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purposes of the Plan Finder, products are defined as packages of benefits 
that a private insurer offers that have been reported to State regulators in an 
insurance filing.12,13  Each health insurance product may have multiple plan 
options.  Plans may differ in their premiums, cost-sharing options, types of 
services covered, coverage limitations, and exclusions.  The Plan Finder 
began displaying detailed pricing and benefit information for the individual 
market in October 2010 and for the small group market in November 2011.   
For Plan Finder data collection, storage, and maintenance, CMS contracts 
with an information technology and business process services firm.  
According to CMS, the estimated cost of development, operation, and 
management of the data systems that support the Plan Finder and other 
HealthCare.gov functions was $17.2 million for fiscal year 2012.14     
Federal Requirements for Reporting Private Insurance Data  
Data Submission Requirements.  To populate the Plan Finder, all private 
insurers must submit data that provide consumers with information on 
health insurance coverage options.15  The data submission requirements 
apply to health insurance sold in both the individual and small group 
markets in each of the 50 States and the District of Columbia.  Private 
insurers must submit: 
  Basic health insurance company and product information, including 
enrollment data, geographic availability, and Web site links to provider 
networks.  Insurers submit these data electronically to CMS using the 
Health Insurance Oversight System. 
  Detailed pricing and benefit information on premiums, cost-sharing, 
types of services covered, coverage limitations, and exclusions for each 
health insurance plan.  Insurers submit these data electronically to CMS 
using the Rate and Benefits Information System. 
Insurers must report basic health insurance information prior to reporting 
detailed pricing and benefit information about their products and plans.  
For the individual market, the Plan Finder displays detailed pricing and 
benefit information by health insurance plan.  According to CMS, small 
group market insurers do not generally sell or track pricing and benefit 
 
12 45 CFR  159.110. 
13 States are primarily responsible for oversight of the private health insurance industry.  
State regulators ensure that products comply with State law and do not contain major gaps 
in coverage that might be misunderstood by consumers.  CMS does not have the authority 
to actively solicit State involvement to ensure that products submitted to Plan Finder have 
been reported to State regulators. 
14 These data systems are used to support other CMS efforts related to ACA 
implementation in addition to the HealthCare.gov Plan Finder.  The Plan Finder is one of 
several components of the HealthCare.gov Web site. 
15 45 CFR  159.120. 
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information by plan.  Therefore, in an effort to reduce insurers data 
collection burden, CMS collects and displays detailed pricing and benefit 
information for the small group market by health insurance product.  For a 
product with multiple plan options, the Plan Finder displays the range of 
deductible, out-of-pocket limit, copayment, and co-insurance options 
offered for the plans associated with that small group product. 
In addition to current data submission requirements, future releases of the 
Plan Finder will include performance rating indicators for products and 
plans, such as the percentage of policies rescinded, the percentage of 
claims denied, and the number and disposition of appeals.16  Private 
insurers are not yet required to submit performance rating indicators.   
Data Validation Requirements.  Insurers must verify the data submitted to 
the Plan Finder and make corrections to any errors that are found.17  In 
addition, regulations require that each insurers Chief Executive Officer 
(CEO) or Chief Financial Officer (CFO) electronically certify to the 
completeness and accuracy of all data submitted.18   
Related Studies  
In 2009, an OIG study identified inaccurate drug prices displayed on the 
Web-based Medicare Part D plan comparison tool that Medicare 
beneficiaries use to find, compare, and select Part D prescription drug 
plans.19  In response, CMS modified information that appears to consumers 
regarding the accuracy of the Part D drug cost estimates provided on the 
Web-based tool. 
METHODOLOGY 
Scope 
We examined CMSs oversight of private health insurers compliance with 
Plan Finder reporting requirements and determined whether selected data 
displayed on the Plan Finder were consistent with other consumer 
information provided by private insurers.  We limited our review to health 
insurance data reported by private insurers to the Plan Finderspecifically, 
small group market data that were on display from November 15, 2011, to 
March 1, 2012, and individual market data that were on display from 
January 19, 2012, to April 12, 2012.  CMS identifies an insurer as a 
private health insurance company operating within a State.  For purposes of 
 
16 45 CFR  159.120(f). 
17 45 CFR  159.120(e). 
18 45 CFR  159.120(g). 
19 OIG, Accuracy of Part D Plans Drug Prices on the Medicare Prescription Drug Plan 
Finder, OEI-03-07-00600, July 2009.   
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our review, if a single company operates in 5 States in both the small group 
and individual markets, we considered it as 10 insurers. 
Data Collection  
Documentation, Survey, and Interview Data.  We obtained current written 
policies and procedures that CMS uses to oversee private insurers 
compliance with Plan Finder reporting requirements.  CMS completed two 
self-administered surveys and responded to in-person interview questions 
regarding private insurers data submissions and CMSs oversight activities 
for the individual and small group markets.   
Source Data Populating the Plan Finder Display. We obtained from CMS 
the source data populating the Plan Finder display for the individual and 
small group markets.  The source data included detailed health insurance 
pricing and benefit information submitted by 545 small group market 
insurers and 310 individual market insurers, for a total of 855 submissions. 
CMS indicated that it expected 1,026 insurers to submit detailed health 
insurance information for the Plan Finder update periods in our review.  
Only 897 insurers actually submitted this detailed information.  However, 
CMS displayed information on the Plan Finder for 855 of these insurers 
because some insurers data submissions did not pass CMSs validation 
process.20      
Data Displayed on the Plan Finder.  From the Plan Finder, we collected 
information for selected data fields for 94 individual plans and 98 small 
group products.  Where possible, this purposive sample included products 
and plans offered by two insurers for each State and the District of 
Columbia in both the individual and small group markets.21, 22  We designed 
our sample to include a greater proportion of insurers with higher levels of 
health insurance market share within each State.  Of the 192 products and 
 
20 For the November 2011 update of the small group market data displayed on the Plan 
Finder, CMS provided a source data file on December 12, 2011.  For the January 2012 
update of the individual market data displayed on the Plan Finder, CMS provided a source 
data file on February 9, 2012. 
21 During the review period, the Plan Finder did not display information for any individual 
market insurers in Rhode Island and displayed information for only one individual market 
insurer in Alabama, Idaho, Minnesota, Montana, New Hampshire, and Vermont, 
respectively.  Therefore, 94 individual market plans were included in our sample.   
22 We initially selected a sample of 102 small group market products.  However, for 
four sampled products, we could not reach a representative during our data collection 
period who was willing and able to answer our questions.  Therefore, our sample included 
98 small group market products.  
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plans in our sample, 122 were offered by insurers with more than 5 percent 
of their States market shares.23   
Information Provided by Insurers Representatives.  For each sampled 
product and plan, we called the insurers customer service telephone 
number and asked to speak with a representative who could answer specific 
questions about products or plans.  If transferred by an operator, we 
considered the person to whom we were transferred to be a customer 
service representative.  We collected information from these 
representatives regarding individual plan and small group product data 
fields displayed on the Plan Finder.  Appendix A provides a list of the Plan 
Finder data fields selected for review.  
Analysis   
We reviewed and summarized CMSs policy and procedure documentation, 
survey responses, and in-person interview responses regarding private 
insurers Plan Finder data submissions and CMSs oversight activities.  
For each product and plan in our sample, we calculated rates of consistency 
between the data displayed on the Plan Finder and the information 
provided by insurers representatives by dividing the number of matching 
data fields by the total number of data fields included in our review.  After 
calculating a consistency rate for each product and plan, we calculated the 
average consistency rate across all products and plans.   
For each data field under review, we calculated the percentage of products 
and plans for which the data values displayed on the Plan Finder matched 
the information provided by insurers representatives.  In some cases, 
insurers representatives did not know the answer to or did not answer one 
or more of the questions asked about sampled products and plans.  We did 
not include missing data values in the denominator when calculating the 
consistency rate for a product or plan or the consistency rate for a data 
field. 
In addition, we determined whether there were aberrant or inconsistent data 
values in selected data fields displayed on the Plan Finder for each product 
and plan in our sample using two different analyses: 
  We compared the data displayed on the Plan Finder to the data 
submitted by insurers to identify any discrepancies.   
 
23 In measurement of health insurance market competition, 5 percent is considered a threshold 
signaling that an insurer controls sufficient market share to form provider networks and 
achieve brand awareness for growth in the future.  Kaiser Family Foundation, How 
Competitive are State Insurance Markets?, October 2011.  Accessed at 
http://www.kff.org/healthreform/upload/8242.pdf on September 5, 2012.  
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  We compared the data displayed on the Plan Finder across products and 
plans to check for extremely high or low values in specific data fields.  
We also reviewed the Plan Finder display for each product and plan in 
our sample to identify logical inconsistencies between the values of 
related data fields.  For example, if a plans data fields for drug 
coverage indicated that the plan did not cover drugs, but a drug 
formulary list was included on the plans display, we would consider 
this to be an inconsistency between values of related data fields.       
Limitations 
Although we used randomization where possible to minimize bias in our 
selection of product and plans, our purposive sample of 192 products and 
plans is not representative of all products and plans on the Plan Finder 
display.  We also did not validate the information provided by insurers 
customer service representatives.  Finally, to minimize respondent burden 
for insurers telephone representatives, we did not include all data fields for 
individual plans and small group products displayed on the Plan Finder in 
our review.       
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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FINDINGS 
Gaps exist in CMSs oversight of private insurers 
reporting of required data to the HealthCare.gov Plan 
Finder 
Thirteen percent of private health insurers that CMS expected to report data 
did not submit pricing and benefit data to the HealthCare.gov Plan Finder 
in November 2011 and January 2012.  CMS did not conduct targeted 
followup with these insurers.  In addition, CMS has not required insurers to 
meet the stipulation in the Federal regulation that insurers CEOs or CFOs 
certify to the completeness of all submitted data.  With respect to oversight 
of insurers compliance with reporting basic company and product 
information to the Department of Health and Human Services (HHS), CMS 
has not been able to identify the entire population of private insurers 
required to report.24 
Thirteen percent of private insurers did not submit pricing and 
benefit data to the Plan Finder  
Of the 1,026 insurers that CMS expected would report specific pricing and 
benefit information for the individual and small group markets, 129, or 
13 percent, did not submit these data.  These 1,026 insurers had submitted 
basic health insurance information to the Plan Finder in the past and, 
therefore, were expected to submit detailed pricing and benefit information.  
Without submitting pricing and benefit data, an insurer cannot be displayed 
on the Plan Finder.  Therefore, during our review periods, there were 
129 private insurers with potential health insurance offerings that were not 
on the Plan Finder.  As shown in Table 1, the percentage of insurers that did 
not submit these detailed data was greater among insurers from the 
individual market (21 percent) than that from the small group market 
(7 percent). 
 
Table 1:  Private Insurers Compliance With Requirement To Report Specific Pricing 
and Benefit Information to the HealthCare.gov Plan Finder 
 
Number of Insurers   Number of Insurers   Percentage of Insurers  
Health Insurance 
Expected To Report   That Did Not Report   That Did Not Report  
Market 
Pricing and Benefit Data   Pricing and Benefit Data   Pricing and Benefit Data  
Individual Market,  
395  84  21% 
January 2012 Update 
Small Group Market, 
631  45  7% 
November 2011 Update 
Totals   1,026  129  13% 
 Source:  Office of Inspector General (OIG) survey of CMS/CCIIO staff, 2012. 
 
 
24 45 CFR  159.100, 159.110, and 159.120.  
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CMS did not conduct targeted followup with private insurers 
that did not submit pricing and benefit information to the Plan 
Finder 
CMS did not conduct targeted followup with 128 of the 129 private health 
insurers that did not report pricing and benefit information for their 
products and plans.  For the small group market, CMS contacted one 
insurer for failing to submit pricing and benefit information.  This insurer 
indicated that the employee responsible for reporting data to the Plan 
Finder had been replaced, which led to confusion among staff about 
data-reporting responsibilities.  The insurer indicated that it would report 
its pricing and benefit information in the next Plan Finder data collection 
period.  For the individual market, CMS did not conduct targeted followup 
with any insurers that did not submit pricing and benefit information for 
the January 2012 display period. 
CMS has not required insurers to certify to the completeness of 
the data they submit to the Plan Finder  
Each insurers CEO or CFO must certify to the completeness and accuracy 
of all data submitted to HHS for display on the Plan Finder.25  However, 
CMS has not required CEOs or CFOs to certify to the completeness of the 
data submitted since the launch of the Plan Finder in July 2010.  For all 
Plan Finder data collection periods from July 2010 through January 2012, 
insurers were required to certify only to the accuracy of the data submitted 
as a condition of displaying the data on the Web site.26   
According to CMS, its decision not to require insurers to certify to data 
completeness stems from the specification that insurers must submit 
information onat a minimumall plans that are open for enrollment and 
represent 1 percent or more of the insurers total enrollment within a ZIP 
Code.  According to CMS, most private health insurers do not track 
enrollment at the plan level and therefore feel they are unable to certify 
with certainty that they have submitted all of the plans that represent 
1 percent or more of their total enrollment in a given ZIP Code.   
   
 
25 45 CFR  159.120(g). 
26 HHS, Revised Language for CEO/CFO Attestation of CMP [Content Management 
Portal] Data, September 22, 2010.  Accessed at 
http://cciio.cms.gov/resources/files/notice_revised.pdf on November 18, 2011. 
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CMS has not been able to identify the entire population of 
insurers that are required to report basic health insurance 
information to the Plan Finder  
CMS has not been able to identify the entire population of private insurers 
subject to the reporting requirement and therefore cannot oversee insurers 
compliance with the requirement to report basic health insurance company 
and product information to HHS.  For the November 2011 and January 
2012 Plan Finder updates, CMS did not have a mandatory standard process 
to identify the insurers that may be required to report basic health insurance 
data to the Plan Finder.   
According to CMS, there is no existing reference that it can use to identify 
the total population of insurers required to report to the Plan Finder.  In 
addition, ambiguity in the insurance market and across States surrounding 
the definition of a health insurance product makes it difficult for CMS to 
construct such a reference.  However, CMS has made prior attempts to 
identify insurers subject to Plan Finder reporting requirements using data 
collected by organizations such as the National Association of Insurance 
Commissioners, Americas Health Insurance Plans, and the Blue Cross and 
Blue Shield Association.  
CMS expects that the introduction of other Federal efforts to collect private 
health insurance informationincluding data collections for reviews of 
insurance rate increases, medical loss ratios, Health Plan Identifiers, and 
the Affordable Insurance Exchangesmay improve CMSs ability to 
identify the population of health insurers across the Nation.27 
Although CMS implemented numerous measures to 
oversee data accuracy, the data displayed on the Plan 
Finder contained some inconsistencies 
During the data collection periods for the November 2011 and 
January 2012 Plan Finder updates, CMS incorporated data quality checks 
into the data-reporting process for private insurers.  CMS held insurers 
accountable for not resolving identified data quality problems by 
suppressing their health insurance product and plan information from 
display on the Plan Finder.  Despite these oversight efforts, the data 
displayed on the Plan Finder for our sample of 192 products and plans 
 
27 A medical loss ratio is the percentage of insurance premiums that an insurer spends on 
health care services and activities to improve health care quality.  The ACA generally 
requires that insurers spend 80 percent or 85 percent of insurance premiums on health care 
services and quality improvement.  HHS, Health Insurance Basics:  Your Insurance 
Company & Costs of Coverage.  Accessed at http://companyprofiles.healthcare.gov/ on 
March 21, 2013. 
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contained aberrant or inconsistent values that may be confusing or 
misleading to consumers.28    
CMS employed multiple strategies to monitor data accuracy 
and held insurers accountable by suppressing data from the 
Plan Finder display   
To oversee data accuracy during the review period, CMS:  
  conducted training sessions, held weekly user group calls, and made 
staff available to help insurers understand how to submit accurate data; 
  embedded quality checks into the data entry templates that insurers 
used to submit their data; 
  applied to all submitted data templates an automated system validation 
process that conducted quality checks and checked that each insurer 
submitted all necessary data; 
  required that insurers review and verify the accuracy of submitted 
information;29  
  conducted post-submission quality checks of four data fields to 
determine whether the data values appeared as expected; 
  tested the Web site links for the brochures, drug formularies, and 
provider networks submitted by insurers to determine whether the links 
were functional, direct, and accurate; 
  maintained communication channels through the Web site, email, and 
telephone through which consumers, insurers, and State insurance 
regulators could inform CMS of potential data errors on the Plan 
Finder; and 
  made the review of insurers product information available to States 
Departments of Insurance through an online data system. 
During the review period, CMS suppressed submitted private health 
insurance data from the Plan Finder display for the following reasons: 
  One insurer did not pass the automated system validations applied to 
submitted data templates.  This insurers data did not progress through 
the data submission process and therefore were suppressed from the 
Plan Finder display. 
 
28 The sample of 192 products and plans was selected from source data files provided by 
CMS.  As described on page 5 of the methodology, the files contained detailed pricing and 
benefit information for 855 insurers displayed on the Plan Finder during our review period 
(545 small group market insurers and 310 individual market insurers).  
29 If the insurer identified errors in the submitted data, CMS instructed the insurer to 
resubmit and reverify the data. 
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  CMS suppressed 41 insurers data from the Plan Finder display because 
the insurers did not verify the accuracy of submitted data.  Of these 
insurers, 40 operated in the small group market.       
  CMS did not display at least 1 link for each of 108 insurers that failed 
testing on the Plan Finder Web site, but posted a note stating that 
insufficient link information was provided.   
  CMS received two reports, both initiated by State regulators, about 
potential errors in the small group market data displayed on the Plan 
Finder.  One of these reports led to CMSs suppression of one insurers 
data from the Plan Finder display. 
Despite CMSs efforts to oversee data accuracy, 
inconsistencies appeared in the Plan Finder displays reviewed 
The Plan Finder included aberrant and inconsistent information that may 
confuse consumers and undermine the Plan Finders utility as a consumer 
education tool.  In the sample of products and plans, aberrant or 
inconsistent data values were associated with 3 data fields on the Plan 
Finder displays for the small group market and with 13 data fields on the 
displays for the individual market.  One or more of these inconsistencies 
were reflected on the Plan Finder displays for 127, or two-thirds, of the 
192 products and plans reviewed.  
  For 89 individual plans, insurers reported to CMS that limitations and 
exceptions may apply to at least 1 of 9 benefits that are displayed for 
each individual market plan on the Plan Finder.30  However, for these 
89 plans, the corresponding Plan Finder displays indicated that 1 or 
more of these 9 benefits were Included Benefits with no limitations 
or exceptions.31  This systematic inconsistency between the data that 
insurers submitted to CMS and the data actually displayed on the Plan 
Finder can be misleading to consumers.  For example, a consumer 
viewing the Plan Finder display for one of these plans may think that 
the plan fully covers home health care services when the data that the 
insurer submitted to CMS indicate that this benefit may be restricted in 
some way.    
  For 36 small group products and 17 individual plans, the names of the 
products and plans that appeared on the Plan Finder display did not 
 
30 The data fields for the nine benefits were:  Dental Checkup for Children, Durable 
Medical Equipment, Eyeglasses for Children, Habilitation, Home Health Care, Hospice, 
Inpatient Rehabilitation, Outpatient Rehabilitation, and Routine Eye Care for Children. 
31 Each of these benefits is listed on the Plan Finder display in one of four mutually 
exclusive coverage categories:  Included Benefits, Excluded Benefits, Limited 
Benefits, or Benefits Available for Purchase at Additional Cost. 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)  12 
   
   
match the names on the insurers brochures that were linked to the 
display.32  For some small group products, the entire product name on 
the Plan Finder display did not appear in the brochure.  If consumers 
cannot identify a product or plan in the insurers brochure on the basis 
of the name displayed on the Plan Finder, they may be confused as to 
whether the product or plan is actually offered by the insurer.   
  Seven individual plans had a null value (either $0.00 or No 
Maximum) displayed in the data field for In-Network Out-of-Pocket 
Limit, but had specific elements listed as contributing to the 
out-of-pocket limit in the data field for In-Network Out-of-Pocket 
Limit Elements.33  It is unclear why these elements would be listed for a 
plan without an out-of-pocket limit.   
  For four individual plans, all of their drug coverage data fields (Generic 
Drugs, Preferred Brand Drugs, and Specialty Drugs) on the Plan Finder 
display indicated that drugs were Not Covered by the plan.  
However, these plans had drug formulary Web site links posted on their 
displays.  It is confusing when a plan that appears to lack drug coverage 
has a link to a list of covered drugs. 
  Three products and plans had extremely low values ($2,250, $2,500, 
$4,000) displayed in their Annual Maximum Benefit data field.  An 
Annual Maximum Benefit of $4,000 conveys that the plan pays only 
$4,000 for all in-network health care services provided to an enrollee in 
a year.  If this value is inaccurate, it may be misleading to consumers.  
When other products and plans had an Annual Maximum Benefit listed, 
the data values ranged from $25,000 to $7,500,000.       
  Two small group products in our sample had extremely low values 
($1.50, $2, $3, $4, $5) displayed in the data field for Annual 
Out-of-Pocket Maximum Options.  A value of $5 conveys the unlikely 
scenario that the consumer will pay a maximum amount of $5 for all 
covered in-network health services during the year.  When other small 
group products in our sample had values listed in this data field, the 
values ranged from $200 to $25,000. 
 
 
32 We considered a product or plan name on a brochure as matching the name on the Plan 
Finder display if parts of the displayed name appeared anywhere in the brochure.  For 
example, if part of the displayed name was 1500/30 and cost-sharing information in the 
brochure included a $1,500 deductible with 30-percent coinsurance, then we considered 
the names to match. 
33 The In-Network Out-of-Pocket Limit is the maximum amount a patient pays for  
in-network covered health services in a year.  Generally, this includes the deductible, 
coinsurance, and copayments.  The elements included in the out-of-pocket limit vary from 
plan to plan.  
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Not all of the products and plans displayed on the 
Plan Finder were available for sale or were recognized 
by insurers representatives  
 
For 26 of 192 products and plans (14 percent), either the insurers customer 
service representatives stated that the health insurance products or plans 
were not available for sale (14 products or plans) or the representatives 
could not identify the products on the basis of the name displayed on the 
Plan Finder (12 products).   
 
Insurers representatives stated that 14 small group products or individual 
plans were not available for sale.  Of these, 13 were not available at the 
time of the calls or were not offered in the States or counties that we 
referred to during the calls.  For one individual plan, the representative 
indicated that the plan was available only to consumers withdrawing from 
group coverage and therefore was not available to all individuals 
purchasing private insurance.  Insurers representatives could not identify 
an additional 12 small group products on the basis of the product names 
that we provided from the Plan Finder display.  For example, one 
representative said, There are 10 different [products]none of them say 
Consumer Choice on them.  Another representative indicated that the 
product name we gave her was for a portfolio and there were multiple 
products within the portfolio that each included a set of plan options.  She 
said that she could not answer our questions unless we chose a specific 
product from the portfolio. 
We could not compare the data displayed on the Plan Finder to the 
information provided by insurers representatives for the 26 products and 
plans that were not available or could not be identified.  Therefore, our data 
comparisons were limited to the remaining 166 products and plans that 
were available for sale and recognized by representatives.    
Eighty-one percent of product and plan data displayed 
on the Plan Finder matched information provided by 
insurers representatives 
On average, products and plans in our sample had 81 percent of the data 
displayed on the Plan Finder match the information provided by insurers 
representatives.  We compared information displayed on the Plan Finder to 
information provided by insurers representatives for 18 data values for 
individual plans and 30 data values for small group products.34  To 
 
34 In some cases, insurers customer service representatives did not know the answer to or did 
not answer one or more of the questions asked about products and plans in our review.  
Specifically, insurers representatives did not know the answer to 5 percent of questions and 
did not answer 1 percent of questions. 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)  14 
   
   
illustrate, if 14 of 18 individual plan data values matched the plan 
information provided by insurers representatives, we calculated a 
78-percent consistency rate for the plan.35  The rates of matching data 
ranged from a 45-percent consistency rate for one small group product to a 
100-percent consistency rate for seven products and plans.  Overall, small 
group products had lower rates of consistency than did individual market 
plans.  Table 2 specifies the distribution of consistency rates for the 
products and plans in our sample. 
Table 2:  Consistency of HealthCare.gov Plan Finder Display With Information Provided by 
Private Insurers Representatives 
Number (%) of  Number (%) of  Number (%) of  Number (%) of  Average 
Products and  Products and  Products and  Products and  Consistency 
Health Insurance Market  Plans With a  Plans With a  Plans With a  Plans With a  Rate Per 
Consistency Rate  Consistency  Consistency Rate  Consistency Rate  Product and 
of Less Than 75%   Rate of 7589%  of 9099%  of 100%  Plan 
Individual Market,  
January 2012 Update  9 (10%)  48 (56%)  23 (27%)  6 (7%)  86% 
(86 plans) 
Small Group Market, 
November 2011 Update  38 (48%)  29 (36%)  12 (15%)  1 (1%)  76% 
(80 products) 
Totals  
47 (28%)  77 (46%)  35 (21%)  7 (4%)  81% 
(166 products and plans) 
Source:  OIG analysis comparing consumer information provided on calls to insurers telephone customer service representatives to the data 
displayed on the HealthCare.gov Plan Finder Web site, 2012. 
 
For 47 of 166 products and plans (28 percent), less than three-quarters of 
their displayed data matched the information provided by insurers 
customer service representatives.  Small group market products accounted 
for 38 of the 47.  It is important to note that these small group market data 
reflect CMSs first collection of detailed pricing and benefit information 
from small group market insurers.  In contrast, individual market insurers 
have been reporting detailed plan data to the Plan Finder since September 
2010. 
For certain fields on the Plan Finder display, data values were 
less likely to match information provided by insurers 
representatives 
Across small group products and individual plans, certain benefit data 
fields displayed on the Plan Finder were less consistent with information 
provided by insurers representatives.  For example, only 39 percent of 
individual plans had data in the Plan Finders data field for Home Health 
Care that matched the home health care benefit information provided by 
 
35 We did not include missing data values in the denominator when calculating the consistency 
rate.  For example, if the representative did not know the answer to 1 of the 18 questions 
regarding an individual plan and 14 of the remaining 17 data values matched, we calculated an 
82 percent (14/17) consistency rate. 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)  15 
   
   
insurers representatives.  This low consistency rate may be attributed to 
the systematic inconsistency described earlier, i.e., insurers reported 
information to CMS about limitations and exceptions for home health care 
coverage that was not reflected in the health insurance plan data displayed 
on the Plan Finder.  
For six of the seven benefit data fields that displayed small group products 
range of cost-sharing options, less than 75 percent of products had Plan 
Finder data values that matched the information provided by insurers 
representatives.36  Insurers were instructed to summarize information about 
their products to enter it into the Plan Finder templates.  Lower consistency 
rates for the range of cost-sharing options data fields on the Plan Finder 
display may reflect challenges that insurers faced when summarizing 
pricing and benefit information as a set of product options.  Alternatively, 
the lower consistency rates for these data fields may reflect challenges that 
insurers representatives faced when recalling and presenting the minimum 
and maximum values of a range of product options. 
   
 
36 These six data fields were:  Available In-Network Deductibles, Available  
Out-of-Network Deductibles, Annual Out-of-Pocket Maximum Options, Range of  
In-Network Copay Options, Range of In-Network Coinsurance Options, and Range of  
Out-of-Network Coinsurance Options.   
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)  16 
   
   
CONCLUSION AND RECOMMENDATIONS 
Private insurers offering health insurance in the individual and small group 
markets must submit data to populate the HealthCare.gov Plan Finder.  The 
data collection conducted by CMS/CCIIO to populate the Plan Finder 
represents the first national attempt to identify these insurers and the 
products and plans they offer.  For American consumers to obtain the 
maximum benefit from the Plan Finder, the private health insurance data 
displayed there must be complete and accurate. 
In November 2011 and January 2012, CMS did not ensure that private 
health insurers reported all required data to HHS.  However, CMS 
implemented numerous measures to ensure the accuracy of reported data 
and suppressed data from the Plan Finder when quality checks identified 
problems. Despite these efforts, our review of the data displayed on the Plan 
Finder for 192 selected products and plans found that some aberrant and 
inconsistent data values appeared on the Web site.  These inconsistencies 
may be confusing or misleading to consumers using the Plan Finder to seek 
information about the private health insurance products and plans available 
to them.   
Our comparison of data displayed on the Plan Finder to data provided by 
insurers representatives was designed to identify inconsistencies between 
two sources of health insurance information.  This comparison revealed that 
some health insurance products and plans displayed on the Plan Finder were 
not available for sale or were not recognized by insurers representatives.   
When products and plans were available and were recognized, an average of 
81 percent of the data displayed on the Plan Finder matched the information 
provided by insurers representatives.  For a smaller number of products and 
plans in our purposive sample, less than three-quarters of their Plan Finder 
data matched the information provided by insurers representatives.  Small 
group market products accounted for most of these inconsistencies.  The 
data reviewed from the small group market represent CMSs inaugural 
collection of detailed pricing and benefit information for this insurance 
market. 
Our findings indicate that additional efforts are needed to oversee private 
health insurers compliance with reporting requirements for the Plan Finder 
and to ensure that the data displayed on the Plan Finder are accurate. 
 
   
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Therefore, we recommend that CMS: 
Establish and Implement Procedures To Identify and Pursue 
Private Insurers That Do Not Submit Required Data to the Plan 
Finder 
CMS should establish and implement a standard process to identify private 
health insurers that are required to report basic health insurance company 
and product data to HHS.  After doing so, CMS should systematically 
contact insurers that have not submitted basic health insurance information 
for display on the Plan Finder.  CMS has taken initial steps toward this end 
by seeking a contractor to evaluate Plan Finder data with a specific goal of 
determining whether the insurers that have reported data to the Plan Finder 
reflect the entirety of insurers subject to the requirements.  In addition, CMS 
should establish and implement procedures to conduct targeted followup 
with private health insurers that did not submit pricing and benefit 
information during each data collection period.  If these steps do not 
improve compliance, CMS should consider seeking additional authority to 
impose penalties on insurers that do not submit required data. 
Ensure That Each Private Insurers CEO or CFO Certifies to the 
Completeness of Data Submitted for the Plan Finder  
Since July 2010, insurers have been required to certify to the accuracy of the 
data submitted to the Plan Finder.  CMS should implement the requirement 
in 45 CFR  159.120(g) that insurers CEOs or CFOs certify to the 
completeness of the submitted data as a condition of displaying the data on 
the Plan Finder.  As part of this, CMS may want to consider revising the 
current specification of completenessthat insurers must submit 
information onat a minimumall plans that are open for enrollment and 
represent 1 percent or more of the insurers total enrollment within a ZIP 
Code.  One option is to devise a specification of completeness that aligns 
with how private insurers track enrollment. 
Design and Implement Additional Strategies To Ensure Plan 
Finder Data Accuracy  
CMS incorporates insurer training and data quality checks into the Plan 
Finder data submission process to prevent and correct data errors.  However, 
our review indicates that CMS should perform additional data quality 
checks to prevent aberrant or inconsistent values from being displayed on 
the Plan Finder that may be confusing or misleading to consumers.  In 
designing additional strategies, CMS should begin by addressing the 
inconsistencies described in this report.  For example, CMS should check 
that data submitted by insurers on limitations or exceptions to plan benefits 
are reflected on the Plan Finder.  CMS may consider incorporating specific 
instructions in its data entry guidance to private insurers about submitting 
product and plan names for the Plan Finder that appear on brochures and are 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)  18 
   
   
recognizable to insurers customer service representatives.  CMS could also 
instruct insurers to submit data on the range of cost-sharing options for 
small group products that are the same as those outlined in materials used 
by their customer service representatives to sell insurance to small 
employers.  
Validate That Products and Plans Submitted to the Plan Finder 
Are Available for Sale  
Our review indicates that not all private health insurance products and plans 
that appeared on the Plan Finder were available for sale.  CMS is awarding 
a contract for a Plan Finder data evaluation.  One of the goals of this 
contract is to use data from outside sources to produce a report on insurers 
accuracy of reporting.  At a minimum, CMS should focus the contractors 
efforts on using data from outside sources to ensure that products and plans 
that are submitted to the Plan Finder are available for sale. 
   
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AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
CMS generally concurred with all of OIGs recommendations and has 
begun to implement changes to address them.  CMS stated that it believes 
that regulations and standards proposed for 2014 will help simplify the 
reporting process for health insurers and increase the reliability of Plan 
Finder information.   
CMS concurred with our first recommendation, that it establish and 
implement procedures to identify and pursue private insurers that do not 
submit required data to the Plan Finder.  CMS stated that it had identified 
three lists of Health Insurance Issuers that may need to report additional 
data under the HealthCare.gov regulation and that it would begin sending 
targeted memos and conducting followup with these issuers in January 
2013.  In addition, CMS noted that it is compiling lists of issuers required 
to report to the Plan Finder from other sources and will begin to contact 
these issuers in the first quarter of 2013. 
CMS concurred with our second recommendation, that it ensure that each 
private insurers CEO or CFO certifies to the completeness of data 
submitted to the Plan Finder.  CMS stated that it is working to integrate 
Corporate Officer attestations associated with various ACA reporting 
requirements.  CMS noted that it expects to implement the fuller attestation 
requirement in the second quarter of 2013. 
CMS concurred with our third recommendation, that it design and 
implement additional strategies to ensure Plan Finder data accuracy.  CMS 
stated that it hired a contractor in 2012 to review the quality of Plan Finder 
data and provide quarterly reports that will enable CMS to contact issuers 
regarding aberrant data.  In addition, CMS noted that it conducts weekly 
calls to address questions from issuers on reporting data accurately.  CMS 
stated that it believes that changes to its data collection to reflect the 
Summary of Benefits and Coverage (a standard document that insurers are 
required to provide to consumers) will improve communication and 
presentation of information on the Plan Finder. 
CMS concurred with our fourth recommendation, with caveats, that it 
validate that products and plans submitted to the Plan Finder are available 
for sale.  CMS stated that its data quality contractor will evaluate whether 
the information reported to the Plan Finder is accurate.  In addition, CMS 
noted that it will encourage the display of marketing names for health 
insurance plans and products to decrease confusion as consumers 
communicate with sales representatives. 
The full text of CMS's comments is provided in Appendix B.
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APPENDIX A 
Plan Finder Data Fields Included in Office of Inspector General 
Review of Information Provided by Insurers Representatives 
We collected information from insurers customer service representatives 
for 18 of the 55 data fields for individual plans and 23 of the 63 data fields 
for small group products displayed on the Plan Finder.  We included seven 
small group data fields that each displayed a range of cost-sharing options.  
For these data fields, we collected information on the minimum and 
maximum of the range and considered the minimum and maximum as two 
distinct data values.  Therefore, for the 23 selected Plan Finder data fields 
for small group products, we collected 30 data values from representatives.  
Table A-1 outlines the Plan Finder data fields included in our review. 
Table A-1:  Plan Finder Data Fields Included in Office of Inspector General 
(OIG) Review of Information Provided by Insurers Representatives  
Name of Data Field Reviewed,  Name of Data Field Reviewed, 
Small Group Market,   Individual Market,  
November 2011 Update  January 2012 Update 
Product Name  Plan Name 
Available In-Network Deductibles1   Deductible (Individual) 
Available Out-of-Network Deductibles1   In-Network Out-of-Pocket Limit (Individual) 
Annual Out-of-Pocket Maximum Options1  In-Network Out-of-Pocket Limit Elements 
Health Savings Account Eligibility  Health Savings Account Eligibility 
Annual In-Network Maximum Benefit  Annual Maximum Benefit (Individual) 
Doctor Choice  Doctor Choice 
Enrollment of Same-Sex Partners  Primary Care Physician Office Visit 
Enrollment of Domestic Partners  Specialty Physician Office Visit 
Range of In-Network Copay Options1   Inpatient Hospital Services 
Range of Out-of-Network Copay Options1  Emergency Room Services 
Range of In-Network Coinsurance Options1  Generic Drugs 
Range of Out-of-Network Coinsurance Options1  Mental Health Coverage (Outpatient) 
Specialist Visit  Prenatal and Postnatal Care 
Emergency Room   Home Health Care 
Generic Drugs  Hearing Aid 
Mental [Health,] Inpatient  Long Term Care 
Prenatal and Postnatal Care  Chiropractic 
Home Health Care   
Hearing Aid   
Long Term Care   
Acupuncture   
Bariatric Surgery   
 
Source:  OIG telephone calls to insurers customer service representatives based on data displayed on the 
HealthCare.gov Plan Finder Web site, 2012. 
 
1 For this small group product data field, we collected data on the minimum and maximum of the range and 
considered the minimum and maximum as two distinct data values in our analysis.   
 
 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)    21 
  APPENDIX 8 
Agency Comments 
("'Jf-	
DEPARTMENT OF HEALTH & HUMAN SERVICES  Centers tor Medicare & Medicaid Services 
Administrator 
Washington, DC 20201 
DATE:  JAN  1 ~ 2013 
TO: 	 Daniel R. Levinson 

Inspector General 

FROM: 	 Marilyn Tavenner 

Acting Administrator 

SUBJECT: 	 Otlice of Inspector General (OIG) Draft Report: "Oversight of Pri vate Health 
Insurance Submissions to the Healthcare.gov Plan Finder"--(OEI-03-11-00560) 
The Centers for Medicare and Medicaid Services (CMS) would like to thank OIG for the 
opportunity to review and comment on the OIG Draft Report referenced above. 
The evaluation report issued by OIG identifies several areas where CMS can improve the 
accuracy and completeness ofour data collection to support HeahhCare.gov . CMS generally 
concurs with each of the OIG recommendations and has begun implementation of changes that 
we believe will meet the recommendations. CMS believes that the overall assessment overstates 
the problems with the website by underappreciating the degree to which the current insurance 
market operdtes in non-standard ways.  Current regulation allows issuers to assign a single name 
to a complex set ofoptions which make it difficult to confirm specifics on the website. CMS 
does reach out to issuers when errors are reported to us, and these are often the result of 
misinformation or misidentification by customer service representatives rather than errors in 
reporting. We believe that regulations and standards currently under review and proposed for 
2014 will help simplify this process, and increase the reliability of information . 
OIG Recommendation 
The 010 recommends CMS establish and implement procedures to identify and pursue private 
insurers who do not submit required data for the Plan Finder. 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)  22   
   
   
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)  23 
   
   
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)  24 
   
ACKNOWLEDGMENTS 
This report was prepared under the direction of Robert A. Vito, Regional 
Inspector General for Evaluation and Inspections in the Philadelphia 
regional office, and Linda M. Ragone, Deputy Regional Inspector General.   
Amy Sernyak served as the team leader for this study.  Other Office of 
Evaluation and Inspections staff from the Philadelphia regional office who 
conducted this study include Joanna Bisgaier and Conswelia McCourt.  
Central office staff who provided support include Heather Barton, 
Althea Hosein, Meghan Kearns, and Christine Moritz.  
 
 
 
 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560)    25 
   
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.