U.S. Department of Health and Human Services 
Office of Inspector General 
Medicaid Fraud Control Units 
Fiscal Year 2022 Annual 
Report 
 
Ann Maxwell 
Deputy Inspector General for Evaluation and Inspections 
March 2023, OEI-09-23-00190  U.S. Department of Health and Human Services 
 
Office of Inspector General 
Report in Brief 
March 2023, OEI-09-23-00190 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report  
 
Medicaid Fraud Control Units (MFCUs) investigate and prosecute Medicaid provider fraud and patient abuse or 
neglect.  The Department of Health and Human Services Office of Inspector General (OIG) is the designated Federal 
agency that oversees and annually recertifies and approves Federal funding for each MFCU.  For this report, OIG 
analyzed the annual statistical data on case outcomes (such as convictions; civil settlements and judgments; and 
recoveries) that 53 MFCUs submitted to OIG for fiscal year 2022.  Those MFCUs operated in all 50 States, the District 
of Columbia, Puerto Rico, and the U.S. Virgin Islands.  
   
TABLE OF CONTENTS 
 
 
BACKGROUND ................................................................................................................................................ 1 
CASE OUTCOMES .......................................................................................................................................... 4 
MFCUs reported 1,327 convictions in FY 2022, an increase over the previous 2 years ................................. 4 
MFCUs reported criminal recoveries of $416 million in FY 2022 ............................................................................ 7 
MFCUs reported 553 civil settlements and judgments in FY 2022 ........................................................................ 8 
MFCUs reported civil recoveries of $641 million in FY 2022 .................................................................................... 9 
CONCLUSION ................................................................................................................................................ 11 
APPENDICES .................................................................................................................................................. 12 
Appendix A: Beneficial Practices Described in Office of Inspector General Inspection Reports ............... 12 
Appendix B: Medicaid Fraud Control Unit Case Outcomes and Open Investigations by Provider     
Type and Case Type for Fiscal Year 2022 ....................................................................................................................... 16 
ACKNOWLEDGMENTS AND CONTACT ................................................................................................ 23 
Acknowledgments .................................................................................................................................................................. 23 
Contact ........................................................................................................................................................................................ 23 
ABOUT THE OFFICE OF INSPECTOR GENERAL .................................................................................... 24 
ENDNOTES ................................................................................................................................................... 25 
 
 
   
BACKGROUND 
Medicaid Fraud Control Units (MFCUs or Units) investigate and prosecute Medicaid 
provider fraud and patient abuse or neglect.1  The Social Security Act (SSA) requires 
each State to effectively operate a MFCU, unless the Secretary of Health and Human 
Services (HHS) determines that (1) the operation of a Unit would not be cost-effective 
because minimal Medicaid fraud exists in a particular State; and (2) the State has 
other adequate safeguards to protect enrollees from abuse or neglect.2  In fiscal year 
(FY) 2022, all 50 States, the District of Columbia, Puerto Rico, and the U.S. Virgin 
Islands operated MFCUs.3, 4     
MFCUs are funded jointly by the Federal and State Governments.  Each Unit receives a 
Federal grant award equivalent to 90 percent of total expenditures for new Units and 
75 percent for all other Units.5  In FY 2022, combined Federal and State expenditures 
for the Units totaled approximately $343 million, of which approximately $257 million 
represented Federal funds.6      
As illustrated in Exhibit 1, MFCU cases typically begin as referrals from external 
sources or are generated internally from data mining.7  MFCU staff review referrals of 
possible fraud and patient abuse or neglect to determine the potential for criminal 
prosecution and/or civil action.  If the Unit accepts a referral for investigation, the case 
may result in various possible outcomes.  Criminal prosecutions may result in 
convictions; civil actions may result in civil settlements or judgments.  Both criminal 
prosecutions and civil actions may include the assessment of monetary recoveries.  
The Office of Inspector General (OIG) has the authority to exclude convicted 
individuals and entities from any federally funded health care program on the basis of 
convictions referred from MFCUs.8  In addition to achieving these case outcomes, 
Units may also make programmatic recommendations to their respective State 
Governments to help strengthen program integrity and efforts to fight patient abuse 
or neglect.   
Exhibit 1: The typical life cycle of a MFCU case 
 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report   
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Oversight of the MFCU Program  
Reducing Medicaid fraud is a top priority for OIG, and its role in overseeing MFCUs 
helps achieve that priority.  OIG oversees the MFCU grant program by recertifying 
Units; conducting reviews and inspections (hereinafter referred to as inspections) of 
Units; providing technical assistance to Units; and monitoring key statistical data 
about Unit caseloads and outcomes.9    
Annually, OIG reviews each Units application for recertification; approval of this 
application is necessary for the Unit to receive Federal reimbursement.10  To recertify 
a Unit, OIG performs a desk review to assess the Units compliance with the Federal 
requirements for MFCUs contained in statute, regulations, and OIG policy transmittals.  
OIG also examines the Units adherence to 12 performance standards, such as those 
regarding staffing, maintaining adequate referrals, and cooperating with Federal 
authorities.11   
OIG further assesses a Units performance by conducting inspections of Units that 
may identify findings and lead to OIG making recommendations for improvement.  
During an inspection, OIG also makes observations regarding Unit operations and 
practices, and may identify beneficial practices that could be useful to other Units.  
Finally, OIG provides training and technical assistance to Units, as appropriate.  
OIG also provides ongoing technical assistance and guidance to Units.  These 
activities may include outreach, responding to questions from the Units, providing 
training to Units, and issuing policy transmittals to all Units.  OIG also collects and 
presents statistical data reported by each MFCU annually, such as the numbers of 
open cases, indictments, and convictions and amounts of recoveries.  These data can 
be accessed on the OIG website in two formats: a statistical chart and an interactive 
map. 
Methodology 
For this report, we analyzed information from the FY 2022 Annual Statistical Reports 
that the 53 MFCUs submitted to OIG, the recertification materials that the MFCUs 
submitted to OIG, and OIG exclusions data.   
We aggregated case outcomes across all Units for FY 2022 and for each of the 
preceding 4 yearsFYs 2018 through 2021.  These outcomes include convictions; civil 
settlements and judgments; and recoveries.  We also calculated the return on 
investment (ROI) for MFCUs.12  We identified the provider types with the highest 
numbers of criminal and civil outcomes in FY 2022 and the numbers of exclusions that 
OIG imposed in FY 2022 on individuals and entities as a result of conviction referrals 
from MFCUs.  We also analyzed MFCU drug diversion cases using data for 
FYs 2018 through 2022.  Additionally, we include the beneficial practices described in 
previous Unit inspection reports, as described in Appendix A. 
 
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Standards 
We conducted this study in accordance with the Quality Standards for Inspection and 
Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.  
OIG inspections of the MFCUs and this annual report differ from other OIG 
evaluations in that they support OIGs direct administration of the MFCU grant 
program, but they are subject to the same internal quality controls as are other OIG 
evaluations, including internal and external peer review.   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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CASE OUTCOMES 
MFCUs reported 1,327 convictions in FY 2022, an increase over 
the previous 2 years  
Total convictions resulting from MFCU cases continued to increase from the 
FY 2020 level, but remained lower than in FY 2019.  In FY 2022, MFCU cases resulted 
in 946 convictions for fraud and 381 convictions for patient abuse or neglect.  
Exhibit 2 shows the total number of convictions during FYs 2018 through 2022.  
Although the proportion of patient abuse or neglect convictions to fraud convictions 
was similar to that in previous years, the total number of patient abuse or neglect 
convictions also continued to increase from the FY 2020 level.   
Exhibit 2: Convictions both for fraud and for patient abuse or neglect have 
increased since FY 2020. 
 
Source: OIG analysis of Annual Statistical Reports for FYs 2018 through 2022. 
MFCU convictions lead to the exclusion of individuals and entities from participation 
in federally funded health care programs, broadening the impact of those convictions.  
When MFCUs make referrals to OIG regarding convictions for fraud and patient abuse 
or neglect in their respective States, OIG has the authority to exclude those convicted 
individuals and entities from federally funded health care programs.  Through these 
referrals, MFCUs help ensure that individuals and entities convicted in one State are 
excluded from Medicaid programs in other States, as well as from other Federal 
programs related to health care.13 
In FY 2022, OIG imposed a total of 2,332 exclusions on individuals and entities.  MFCU 
cases were responsible for 1,018 (44 percent) of those exclusions.  In addition to these 
1,018 MFCU-generated exclusions, MFCUs participated in joint cases with the OIG 
Office of Investigations that also may have resulted in exclusions. 
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As in previous years, significantly more convictions for fraud 
involved Personal Care Services (PCS) attendants than any other 
provider type 
Compared to other provider types, PCS attendants had the highest number of fraud 
convictions each year during FYs 2018 through 2022.  Exhibit 3 shows the number of 
fraud convictions for PCS attendants, as compared to total fraud convictions, for 
FYs 2018 through 2022. 
Exhibit 3: Fraud convictions involving PCS attendants accounted for a 
significant portion of total fraud convictions during FYs 2018 through 2022. 
 
Source: OIG analysis of Annual Statistical Reports for FYs 2018 through 2022. 
In FY 2022, fraud convictions involving PCS attendants accounted for 412 of the total 
946 fraud convictions (44 percent).  Exhibit 4 shows the provider types with the most 
fraud convictions in FY 2022.   
Exhibit 4: Convictions of PCS attendants for fraud were significantly higher 
than for any other provider type in FY 2022.  
 
* Licensed Practical Nurse (LPN), Registered Nurse (RN), Nurse Practitioner (NP), or Physician Assistant. 
This chart shows the top six provider types based on the number of fraud convictions in FY 2022. 
Source: OIG analysis of FY 2022 Annual Statistical Reports. 
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See Appendix B for detailed statistics, by provider type, on the number of criminal 
convictions; civil settlements or judgments; and recovery amounts, as well as the 
number of open investigations. 
MFCUs reported 171 convictions related to drug diversion cases in 
FY 2022, an increase over the previous 2 years  
MFCU convictions related to drug diversion cases continued to increase from the 
FY 2020 level.  Exhibit 5 shows the number of convictions associated with drug 
diversion cases during FYs 2018 through 2022.  Associated criminal recoveries from 
drug diversion cases totaled $18 million in FY 2022.  Two States, Pennsylvania and 
Kentucky, accounted for 79 percent of this total and those States recovered $9 million 
and $6 million, respectively.  In Medicaid, drug diversion cases generally involve  
(a) the fraudulent billing of Medicaid, or (b) fraudulent activities of Medicaid providers 
involving drugs diverted from legal and medically necessary uses, regardless of 
whether Medicaid itself was billed.  MFCUs may conduct drug diversion investigations 
jointly with other State or Federal agencies, such as OIG or the U.S. Attorneys Office.14  
Exhibit 5: Convictions from drug diversion cases continued to increase in 
FY 2022.  
 
Source: OIG analysis of Annual Statistical Reports for FYs 2018 through 2022. 
In FY 2022, convictions for patient abuse or neglect involved two 
provider types more than any others: nurses aides and nurses or 
physician assistants  
In FY 2022, convictions of nurses aides and of nurses or physician assistants 
accounted for 147 of the total 381 convictions for patient abuse or neglect 
(39 percent).  Exhibit 6 on the next page shows the provider types with the most 
convictions for patient abuse or neglect.  
 
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Exhibit 6: In FY 2022, convictions of nurses aides and of nurses or physician 
assistants for patient abuse and neglect were significantly higher than for 
any other provider types.  
 
*Certified Nurse Assistant or other. 
** LPN, RN, NP, or Physician Assistant. 
This chart shows the top five provider types based on the number of convictions for patient abuse and neglect in 
FY 2022. 
Source: OIG analysis of FY 2022 Annual Statistical Reports. 
MFCUs reported criminal recoveries of $416 million in FY 2022   
Although MFCU criminal recoveries decreased in FY 2022, they remained significantly 
higher than the totals reported during FYs 2018 through 2020 (see Exhibit 7).  MFCU 
criminal recoveries decreased from $857 million in FY 2021 to $416 million in FY 2022.  
The large criminal recovery amounts in FY 2021 were primarily the result of cases 
prosecuted by MFCUs in Virginia and Texas.  These two MFCUs reported a combined 
$714 million in criminal recoveries, 83 percent of the total reported criminal recoveries 
in FY 2021.   
Exhibit 7: Criminal recoveries varied during FYs 2018 through 2022. 
 
Source: OIG analysis of Annual Statistical Reports for FYs 2018 through 2022. 
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One case that significantly contributed to the total criminal recoveries in FY 2022 
involved an investigation by the Texas MFCU.  In that case, the MFCU investigated a 
Chief Executive Officer of a hospice facility for defrauding the Medicare and Medicaid 
programs.15  Among other actions, the defendant billed Medicare and Medicaid for 
hospice services that were (1) not provided, (2) not directed by a medical professional, 
and (3) provided to patients not eligible for hospice care.  In addition, the defendant 
used blank, pre-signed controlled substance prescriptions to distribute drugs without 
physician input.  The case involved co-defendants, some of whom pleaded guilty, and 
others who were found guilty at trial.  The total combined restitution ordered to be 
paid by four of the defendants totaled about $82 million and each was sentenced to 
at least 5 years in Federal prison.   
MFCUs reported 553 civil settlements and judgments in FY 2022 
The total number of civil settlements and judgments reported by MFCUs decreased in 
FY 2022, as did the total number of civil settlements and judgments associated with 
pharmaceutical manufacturers.  As shown in Exhibit 8, during FY 2021 to FY 2022, civil 
settlements and judgments involving pharmaceutical manufacturers decreased at a 
significantly higher rate (63 percent) compared to the decrease in the total number of 
civil settlements and judgments (23 percent).   
Exhibit 8: The total number of civil settlements and judgments decreased in 
FY 2022, as did the total attributed to pharmaceutical manufacturers.    
 
Source: OIG analysis of Annual Statistical Reports for FYs 2018 through 2022. 
 
Despite the significant decrease in civil settlements and judgments involving 
pharmaceutical manufacturers, this provider type continued to account for more civil 
settlements and judgments than any other provider type.  Following pharmaceutical 
manufacturers, medical device manufactures and retail and institutional wholesale 
pharmacies had the next highest number of civil settlements and judgments (see 
Exhibit 9). 
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Exhibit 9: Pharmaceutical manufacturers had the highest number of civil 
settlements and judgments in FY 2022. 
 
This chart shows the top five provider types based on the number of civil settlements and judgments in FY 2022. 
Source: OIG analysis of FY 2022 Annual Statistical Reports. 
MFCUs reported civil recoveries of $641 million in FY 2022 
Civil recoveries continued a 3-year decrease.  As shown in Exhibit 10, civil recoveries 
were substantially higher in FY 2019 relative to other years.  In FY 2019, two global 
cases accounted for a significant portion of the civil recoveries and totaled more than 
$1.3 billion.  
Exhibit 10: Total civil recovery amounts decreased over the last 3 years.    
 
Source: OIG analysis of Annual Statistical Reports for FYs 2018 through 2022. 
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In FY 2022, $395 million (62 percent) of the 
Types of Civil Cases 
$641 million in civil recoveries derived from 
A global case involves both the 
nonglobal cases.  The remaining $246 million 
(38 percent) derived from global cases.16    Federal Government and a group 
of States and is coordinated by 
In one global case that was resolved in FY 2022,  the National Association of 
all 50 States, Washington D.C., and Puerto Rico  Medicaid Fraud Control Units.  
partnered with Federal agencies to pursue 
A nonglobal case is conducted by 
allegations that a pharmaceutical manufacturer 
a Unitindividually or with other 
knowingly underpaid Medicaid drug rebates.  As 
law enforcement partnersand is 
a result of the investigation, the pharmaceutical 
not coordinated by the National 
manufacturer agreed to pay a total of 
Association of Medicaid Fraud 
$234 million.17  
Control Units. 
 
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CONCLUSION 
MFCUs play a vital role in holding wrongdoers accountable for Medicaid provider 
fraud and protecting patients from abuse or neglect.  Medicaid, as a Federal-State 
partnership that provides health insurance for over 80 million individuals, requires 
skilled and effective oversight from both the Federal and State governments.  MFCUs, 
which report to, or work closely with, the State Attorney General, and which receive 
funding and oversight from OIG, are uniquely positioned to investigate and prosecute 
provider fraud and patient abuse or neglect in coordination with Federal and State 
law enforcement and oversight agencies.   
This report outlines the criminal and civil outcomes achieved by MFCUs in FY 2022, 
including total recoveries of $1.1 billion with an ROI of $3.08 for every $1 spent.  
Notably in FY 2022, MFCUs continued to achieve increased criminal outcomes after 
encountering pandemic-related challenges that we described in the FY 2020 and 
FY 2021 MFCU annual reports.   
As in past MFCU annual reports, OIG has identified beneficial practices implemented 
by the MFCUs, included in Appendix A, which other MFCUs may want to consider for 
adoption.   
OIG annually recognizes the efforts of one MFCU with the Inspector Generals Award 
for Excellence in Fighting Fraud, Waste, and Abuse.  In 2023, the Utah MFCU received 
this award for achieving strong case outcomes and maintaining outstanding 
partnerships with OIGs Office of Investigations and other Federal and State partners, 
as well as managed care entities. 
 
 
 
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APPENDICES 
Appendix A: Beneficial Practices Described in Office of Inspector 
General Inspection Reports   
This appendix summarizes MFCU practices that OIG has highlighted as beneficial to Unit operations, 
which other Units may wish to consider adopting in their States.    
 All of OIGs MFCU reports are available at https://oig.hhs.gov/reports-and-
publications/oei/m.asp#mfcu.      
A Unit takes steps to maintain an adequate volume and quality of referrals 
STANDARD 4  
from the State Medicaid agency and other sources. 
Kansas  Supplementing reviews of referrals of patient abuse or neglect and 
OEI-12-18-00210  enhancing referral coordination: The Units nurse investigator reviewed 
July 2019  complaints about patient abuse or neglect that had been previously closed by 
the States survey and certification agency to determine whether the complaints 
warranted further investigation.  In addition, the nurse investigator arranged for 
the Unit to receive complaints of patient abuse or neglect at the same time the 
States survey and certification agency sent the complaints to local law 
enforcement agencies.  After reviewing the complaints, the nurse investigator 
contacted local law enforcement agencies.  If those agencies did not plan to 
take any action on the complaints, the Units Special Agent in Charge reviewed 
the complaints to determine whether to open a formal investigation.       
Louisiana  Hiring an outreach coordinator to promote the Units mission among its 
OEI-12-20-00650  stakeholders: The outreach coordinators responsibilities were to promote the 
August 2021  Units mission among nursing homes, rehabilitation facilities, local law 
enforcement agencies, and other State agencies.  The outreach coordinator was 
responsible for (1) developing training regarding the Units mission and 
presenting that training to Unit stakeholders; (2) coordinating with the Louisiana 
Department of Justice on press releases; and (3) acting as a liaison to receive 
referrals from stakeholders.   
Montana  Participating in an Elder Abuse Task Force to provide training to law 
OEI-12-19-00170  enforcement and first responders: To encourage referrals, the Unit regularly 
March 2020  trained cadets at the Montana Law Enforcement Academy and trained other law 
enforcement and first responder personnel through its participation in the 
Montana Elder Abuse Task Force.  The training focused on the Units mission 
and how the Unit can assist with crimes that law enforcement personnel and 
first responders may encounter.   
  continued on the next page 
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Beneficial Practices Described in Office of Inspector General 
Inspection Reports 
A Unit takes steps to maintain an adequate volume and quality of referrals 
STANDARD 4  
from the State Medicaid agency and other sources.  
New York  Establishing data analytics working groups to improve the Units ability to 
OEI-12-17-00340  data mine to find potential cases: The Unit established data analytics working 
September 2018  groups to provide guidance, training, and an assessment of the Units data 
mining efforts.  The groups include the Data Analytics Tool group, the Data 
Sources group, the Fraud and Abuse group, and the Governance group.   
Ohio  Establishing a program integrity group composed of personnel from other 
OEI-07-14-00290  Medicaid program integrity entities: To improve the quantity and quality of 
April 2015  referrals, the Unit established the Ohio Program Integrity Group, which 
combines the knowledge and resources of all of the State agencies that are 
responsible for Medicaid program integrity.  In addition, the Unit spearheaded 
the Managed Care Program Integrity Group, which meets quarterly. 
South Carolina  Notifying referral sources of the Units decision whether to open formal 
OEI-12-20-00610  investigations of incoming referrals: Through secure electronic channels, the 
September 2021  Unit communicated with the State Medicaid agency and other referral sources 
regarding the Units decision to accept or decline referrals.  In response, State 
officials lauded the responsiveness of the Units communications.  The Unit 
followed a similar practice, where appropriate, regarding referrals received from 
private citizens.   
A Unit takes steps to maintain a continuous case flow and to complete 
STANDARD 5 
cases in an appropriate timeframe based on the complexity of the cases.  
Arkansas  Designating staff as subject matter experts: The Unit director designated Unit 
OEI-12-19-00450  investigators as subject matter experts on specific, common provider types for 
September 2020  efficient assignment and improved investigation of cases. 
New York  Developing a strategic plan to optimize and prioritize resources: The Unit 
OEI-12-17-00340  developed a written strategic plan to help Unit staff make informed decisions 
September 2018  regarding the optimal use of resources.  The plan provides guidance to 
prioritize certain types of investigations, such as criminal investigations that are 
related to systematic patient abuse and neglect; fraud allegations against 
managed care companies; and fraud investigations of large providers.  The plan 
also establishes a priority for false claims investigations with higher potential for 
monetary recoveries or risk of patient harm. 
  continued on the next page 
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Beneficial Practices Described in Office of Inspector General 
Inspection Reports 
A Unit cooperates with OIG and other Federal agencies in the 
STANDARD 8 
investigation and prosecution of Medicaid and other health care fraud. 
California  Co-locating Unit and OIG staff to facilitate referrals and communication: 
OEI-09-15-00070  Unit investigators have workstations at an OIG field officethis facilitated the 
February 2016  mutual referral of cases and improved communication and cooperation with 
OIG on joint cases. 
Florida  Co-locating Unit and OIG staff to improve cooperation on joint cases: Unit 
OEI-07-15-00340  staff have workstations at an OIG field officethis improved communication 
June 2016  and cooperation with OIG on joint cases, including fraud cases generated 
through the U.S. Department of Justice Medicare Strike Force. 
Idaho   Monitoring media sources to report convictions of providers to OIG: The 
OEI-12-18-00320  Units legal secretary monitored media sources for convictions in patient abuse 
August 2019  and neglect cases.  Although the convictions were a result of investigations by 
local authorities and not the Unit, the legal secretary obtained the conviction 
information, and after the Unit Directors review and approval, the legal 
secretary submitted the police reports and court documents to OIG.  As a result 
of those efforts, OIG has excluded individuals from federally funded health 
programs. 
 
A Unit makes statutory or programmatic recommendations, when 
STANDARD 9 
warranted, to the State government.   
Minnesota   Developing legislation to protect Medicaid enrollees from abuse: The Unit 
OEI-06-13-00200  helped develop legislation to protect Medicaid enrollees by strengthening 
March 2014  background checks for individuals who serve as guardians and conservators of 
Medicaid enrollees. 
Washington  Using information from a case closure form to make program integrity 
OEI-09-16-00010  recommendations to State agencies: The Unit used a case closure form to 
September 2016  make numerous program integrity recommendations to State agencies and 
tracked the responses to these recommendations in a database. 
  continued on the next page 
   
 
 
 
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Beneficial Practices Described in Office of Inspector General 
Inspection Reports 
STANDARD 12   A Unit conducts training that aids in the mission of the Unit. 
Kentucky  Implementing a mentoring program to develop Unit attorneys: The Unit 
OEI-06-17-00030  created an executive advisor position to help Unit attorneys develop litigation 
September 2017  skills.  The executive advisor also mentored new attorneys and served as a 
co-chair on Unit prosecutions. 
Louisiana  Sponsoring combined training events with a neighboring Unit: The Unit and 
OEI-12-20-00650  a neighboring Unit alternated hosting a combined training for employees of 
August 2021  both Units.  Training events included case studies, statistical trends, and 
roundtable discussions. 
Maryland  Developing an internal boot camp to train new staff: The Unit developed an 
OEI-07-16-00140  internal boot camp training program that helped new staff develop a full 
September 2016  understanding of the Units work.  Experienced MFCU staff gave 1- to 2-hour 
lectures on topics such as civil and criminal investigation procedures; 
interviewing techniques; and understanding medical codes.   
Missouri  Creating in-house training videos: The Units Chief Auditor created in-house 
OEI-12-18-00490  training videos for Unit investigators and attorneys.  The videos contained 
January 2020  step-by-step tutorials for creating and using investigative and trial tools. 
New York  Using a moot-court approach for training attorneys: The Unit used 
OEI-12-17-00340  moot-court training to train Unit attorneys.  This training helped the Unit 
September 2018  attorneys practice opening arguments to prepare for trial. 
Beneficial practices not relating directly to a specific performance 
OTHER  
standard. 
South Dakota  Having providers teach their peers about implications of Medicaid fraud: 
OEI-07-16-00170  The Unit used providers who had previously been investigated for Medicaid 
September 2016  fraud to educate their peers.  These providers gave presentations alongside 
Unit staff at training conferencesthis helped to highlight Medicaid billing 
issues and the implications of Medicaid fraud. 
Virginia  Using specialty software to better analyze, maintain, and share 
OEI-07-15-00290  documentary evidence: The Unit used specialty software designed to read the 
August 2016  text in a document, analyze it for keywords, and systematically code it 
according to criteria established by an analyst.  This improved the Units abilities 
to process and track evidence collected during investigations and to share that 
evidence with Federal and State partners working on joint cases. 
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Appendix B: Medicaid Fraud Control Unit Case Outcomes and 
Open Investigations by Provider Type and Case Type for Fiscal 
Year 2022 
Exhibit B1: Number of convictions; settlements and judgments; and recoveries by provider type and 
case type 
  CRIMINAL  CIVIL 
Settlements 
Amount of  and  Amount of 
PROVIDER TYPE  Convictions  Recoveries  Judgments  Recoveries 
Patient Abuse or Neglect 
Assisted Living Facility  16  $264,782  0  $0 
Developmental Disability Facility  39  $41,562  1  $300,000 
(Residential) 
Hospice  1  $792  0  $0 
Nondirect Care Staff  6  $127,120  0  $0 
Nurses Aide (Certified Nurse Assistant  74  $55,158  0  $0 
or Other) 
Nurse (LPN, RN, or NP) or Physician  73  $127,400  0  $0 
Assistant  
Nursing Facility  39  $209,438  14  $412,669 
Personal Care Aide or Other Home  43  $155,146  2  $0 
Care Aide 
Other  90  $4,781,278  2  $554,250 
FraudFacility-Based Medicaid Providers and ProgramsInpatient and/or Residential 
Assisted Living Facility  1  $258  1  $2,575 
Developmental Disability Facility  3  $37,447  3  $1,350,000 
(Residential)  
Hospice   9  $84,210,632  0  $0 
Hospital  2  $2,022,305  15  $14,312,030 
Inpatient Psychiatric Services for  0  $0  0  $0 
Individuals Under Age 21 
Nursing Facility  8  $9,448  33  $2,181,860 
Other Inpatient Mental Health Facility  1  $15,496  0  $0 
Other Long-Term Care Facility  0  $0  0  $0 
continued on the next page 
 
     
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Exhibit B1: Number of convictions; settlements and judgments; and recoveries by provider type and 
case type (continued) 
  CRIMINAL  CIVIL 
Settlements 
Amount of  and  Amount of 
PROVIDER TYPE  Convictions  Recoveries  Judgments  Recoveries 
FraudFacility-Based Medicaid Providers and ProgramsOutpatient and/or Day Services 
Adult Day Center  1  $1,799,673  3  $687,038 
Ambulatory Surgical Center   0  $0  1  $200,000 
Developmental Disability Facility  4  $1,088,305  4  $365,865 
(Nonresidential)  
Dialysis Center   0  $0  0  $0 
Mental Health Facility (Nonresidential)   27  $16,641,719  12  $30,616,202 
Substance Abuse Treatment Center   6  $6,745,046  7  $6,379,578 
Other Facility (Nonresidential)   6  $36,315  6  $30,439,207 
FraudLicensed Practitioners 
Audiologist   0  $0  0  $0 
Chiropractor   3  $53,191  3  $189,465 
Clinical Social Worker   5  $766,777  3  $130,776 
Dental Hygienist   3  $7,131  2  $667,319 
Dentist   7  $1,714,597  10  $5,587,265 
Nurse (LPN, RN, or Other Licensed)  67  $1,732,990  1  $989 
Nurse Practitioner   16  $171,265  3  $126,665 
Optometrist   2  $859,610  4  $993,343 
Pharmacist   7  $2,359,411  1  $10,000 
Physician Assistant   5  $575,411  0  $0 
Podiatrist   1  $4,937  0  $0 
Psychologist   8  $1,496,870  7  $1,071,374 
Therapist (Non-Mental Health,  7  $1,192,346  1  $3,092 
Physical Therapist (PT), Speech 
Therapist (ST), Occupational Therapist 
(OT), or Radiation Therapist (RT)) 
Other Practitioner  12  $917,685  4  $205,916 
FraudMedical Services 
Ambulance   5  $1,103,467  2  $382,938 
Billing Services  4  $272  0  $0 
continued on the next page 
 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report   
OEI-09-23-00190  Appendix B | 17    
Exhibit B1: Number of convictions; settlements and judgments; and recoveries by provider type and 
case type (continued) 
  CRIMINAL  CIVIL 
Settlements 
Amount of  and  Amount of 
PROVIDER TYPE  Convictions  Recoveries  Judgments  Recoveries 
FraudMedical Services (continued) 
Home Health Agency   31  $69,131,435  27  $18,001,631 
Lab (Clinical)  3  $123,952  35  $16,185,292 
Lab (Radiology and Physiology)   2  $1,246,877  1  $5,631 
Lab (Other)  1  $40,000  9  $1,598,710 
Medical Device Manufacturer   0  $0  54  $10,055,268 
Pain Management Clinic   2  $877,691  4  $1,081,168 
Personal Care Services Agency  31  $38,204,270  2  $184,857 
Pharmaceutical Manufacturer   0  $0  95  $253,806,011 
Pharmacy (Hospital)   0  $0  0  $0 
Pharmacy (Institutional Wholesale)   4  $3,446,704  24  $4,028,132 
Pharmacy (Retail)   19  $4,937,818  30  $78,602,932 
Supplier of Durable Medical  17  $43,110,892  18  $2,628,742 
Equipment, Prosthetics, Orthotics, and 
Supplies (DMEPOS) 
Transportation (Nonemergency)  22  $4,733,527  6  $824,741 
Other  5  $351,517  8  $3,886,663 
FraudOther Individual Providers 
Emergency Medical Technician or  0  $0  0  $0 
Paramedic 
Nurses Aide (CNA or Other)  19  $242,302  0  $0 
Optician   1  $74,084  1  $9,230 
Personal Care Services Attendant   412  $7,639,555  22  $198,625 
Pharmacy Technician   1  $2,189  0  $0 
Unlicensed Counselor (Mental Health)   20  $5,945,499  0  $0 
Unlicensed Therapist (Non-Mental  1  $10,452  0  $0 
Health) 
Other  54  $24,679,580  3  $262,450 
continued on the next page 
 
 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report   
OEI-09-23-00190  Appendix B | 18    
Exhibit B1: Number of convictions; settlements and judgments; and recoveries by provider type and 
case type (continued)  
  CRIMINAL  CIVIL 
Settlements 
Amount of  and  Amount of 
PROVIDER TYPE  Convictions  Recoveries  Judgments  Recoveries 
FraudPhysicians (Doctor of Medicine (MD) /Doctor of Osteopathic Medicine (DO)) by Medical 
Specialty 
Allergist/Immunologist  0  $0  0  $0 
Cardiologist  0  $0  1  $184,314 
Emergency Medicine  1  $25  1  $14,982,081 
Family Practice   11  $11,332,998  12  $2,420,432 
Geriatrician   0  $0  0  $0 
Internal Medicine   12  $3,597,292  9  $1,777,643 
Neurologist   1  $310,799  0  $0 
Obstetrician/Gynecologist   0  $0  3  $639,221 
Ophthalmologist   2  $1,025  0  $0 
Pediatrician   3  $23,336  4  $1,496,761 
Physical Medicine and Rehabilitation   1  $214,367  1  $9,617,679 
Psychiatrist   2  $1,620,191  2  $349,159 
Radiologist   0  $0  1  $76,230 
Surgeon   2  $8,368  7  $13,392,111 
Urologist   2  $20,400  0  $0 
Other Doctor of Medicine  16  $59,090,801  15  $4,738,596 
(MD)/Doctor of Osteopathic Medicine 
(DO)  
FraudProgram-Related 
Managed Care Organization (MCO)   1  $100  8  $89,612,479 
Medicaid Program Administration   8  $5,000  0  $0 
Other  19  $3,304,754  5  $13,646,658 
TOTAL  1,327  $415,653,075  553  $641,463,864 
Note: Criminal and civil recovery amounts do not add up to the totals shown because of rounding. 
 
 
 
 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report   
OEI-09-23-00190  Appendix B | 19    
Exhibit B2: Number of open investigations at the end of FY 2022 by provider type and case type 
  OPEN INVESTIGATIONS 
PROVIDER TYPE    Criminal  Civil  Total 
Patient Abuse or Neglect 
Assisted Living Facility  250  12  262 
Developmental Disability Facility (Residential)  245  7  252 
Hospice   8  0  8 
Nondirect Care Staff  123  0  123 
Nurses Aide (CNA or Other)  316  1  317 
Nurse (RN, LPN, or NP) or Physician Assistant   305  1  306 
Nursing Facility   945  80  1,025 
Personal Care Aide or Other Home Care Aide   307  6  313 
Other  660  9  669 
FraudFacility-Based Medicaid Providers and ProgramsInpatient and/or Residential 
Assisted Living Facility  34  19  53 
Developmental Disability Facility (Residential)  39  11  50 
Hospice  57  45  102 
Hospital   59  189  248 
Inpatient Psychiatric Services for Individuals Under  5  11  16 
Age 21  
Nursing Facility  128  183  311 
Other Inpatient Mental Health Facility  24  25  49 
Other Long-Term Care Facility  15  16  31 
FraudFacility-Based Medicaid Providers and ProgramsOutpatient and/or Day Services 
Adult Day Center   73  7  80 
Ambulatory Surgical Center   2  16  18 
Developmental Disability Facility (Nonresidential)   29  10  39 
Dialysis Center   0  33  33 
Mental Health Facility (Nonresidential)   396  78  474 
Substance Abuse Treatment Center   163  70  233 
Other Facility (Nonresidential)   65  66  131 
continued on the next page 
 
 
 
 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report   
OEI-09-23-00190  Appendix B | 20    
Exhibit B2: Number of open investigations at the end of FY 2022 by provider type and case type 
(continued) 
  OPEN INVESTIGATIONS 
PROVIDER TYPE    Criminal  Civil  Total 
FraudLicensed Practitioners 
Audiologist   5  3  8 
Chiropractor   22  4  26 
Clinical Social Worker   77  3  80 
Dental Hygienist   0  1  1 
Dentist   241  49  290 
Nurse (LPN, RN, or Other Licensed)  503  7  510 
Nurse Practitioner   77  10  87 
Optometrist   17  6  23 
Pharmacist   58  23  81 
Physician Assistant   26  0  26 
Podiatrist   25  13  38 
Psychologist   72  13  85 
Therapist (Non-Mental Health, PT, ST, OT, or RT)  98  26  124 
Other Practitioner   78  16  94 
FraudMedical Services 
Ambulance   36  41  77 
Billing Services   50  84  134 
Home Health Agency   525  80  605 
Lab (Clinical)   131  550  681 
Lab (Radiology and Physiology)   16  55  71 
Lab (Other)  42  162  204 
Medical Device Manufacturer   2  724  726 
Pain Management Clinic   47  20  67 
Personal Care Services Agency   190  10  200 
Pharmaceutical Manufacturer   78  1,893  1,971 
Pharmacy (Hospital)   23  3  26 
Pharmacy (Institutional Wholesale)   9  175  184 
Pharmacy (Retail)   293  871  1,164 
Supplier of Durable Medical Equipment, Prosthetics,  159  593  752 
Orthotics, and Supplies (DMEPOS) 
Transportation (Nonemergency)  254  26  280 
Other  72  309  381 
continued on the next page 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report   
OEI-09-23-00190  Appendix B | 21    
Exhibit B2: Number of open investigations at the end of FY 2022 by provider type and case type 
(continued) 
  OPEN INVESTIGATIONS 
PROVIDER TYPE    Criminal  Civil  Total 
FraudOther Individual Providers 
Emergency Medical Technician or Paramedic   0  1  1 
Nurses Aide (CNA or Other)  75  0  75 
Optician   2  1  3 
Personal Care Services Attendant   1,621  20  1,641 
Pharmacy Technician   19  0  19 
Unlicensed Counselor (Mental Health)   59  0  59 
Unlicensed Therapist (Non-Mental Health)   8  3  11 
Other  391  43  434 
FraudPhysicians (MD/DO) by Medical Specialty 
Allergist/Immunologist   7  2  9 
Cardiologist   15  16  31 
Emergency Medicine   23  28  51 
Family Practice   228  38  266 
Geriatrician   3  1  4 
Internal Medicine   130  28  158 
Neurologist   16  5  21 
Obstetrician/Gynecologist  27  5  32 
Ophthalmologist   14  14  28 
Pediatrician   44  13  57 
Physical Medicine and Rehabilitation   20  6  26 
Psychiatrist   67  16  83 
Radiologist   6  23  29 
Surgeon   33  17  50 
Urologist   4  3  7 
Other MD/DO  164  89  253 
FraudProgram-Related 
Managed Care Organization (MCO)  10  62  72 
Medicaid Program Administration   9  13  22 
Other  135  90  225 
TOTAL  10,604  7,202  17,806 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report   
OEI-09-23-00190  Appendix B | 22    
ACKNOWLEDGMENTS AND CONTACT 
Acknowledgments 
Christina Lester served as the team leader for this study, and Linda Min served as the 
lead analyst.  Office of Evaluation and Inspections (OEI) staff who provided support 
include Susan Burbach, Robert Gibbons, Petra Nealy, and Keith Peters. 
We would also like to acknowledge the contributions of other Office of Inspector 
General (OIG) staff, including Alexis Crowley, Lonie Kim, Jessica Swanstrom, and  
Sara Swisher. 
This report was prepared under the direction of Blaine Collins, Regional Inspector 
General for Evaluation and Inspections in the San Francisco regional office, and 
Michael Henry, Deputy Regional Inspectors General, in consultation with  
Richard Stern, Director of the Medicaid Fraud Policy and Oversight Division. 
Contact 
To obtain additional information concerning this report, contact the Office of Public 
Affairs at Public.Affairs@oig.hhs.gov.  OIG reports and other information can be found 
on the OIG website at oig.hhs.gov. 
Office of Inspector General 
U.S. Department of Health and Human Services 
330 Independence Avenue, SW 
Washington, DC 20201 
 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report   
OEI-09-23-00190  Acknowledgments and Contact | 23    
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 enrollees 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: 
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 audits help reduce waste, abuse, and mismanagement and promote economy 
and efficiency throughout HHS. 
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. 
The Office of Investigations (OI) conducts criminal, civil, and administrative 
investigations of fraud and misconduct related to HHS programs, operations, and 
enrollees.  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. 
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.
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report   
OEI-09-23-00190  About OIG | 24    
ENDNOTES 
 
1 Social Security Act (SSA)  1903(q)(3)(4).  Regulations at 42 CFR  1007.11(b)(1) add that a Units responsibilities may include 
reviewing complaints of misappropriation of patients private funds in residential health care facilities.  Units may investigate 
patient abuse and neglect incidents occurring in (1) health care facilities that receive Medicaid payments; and (2) board and 
care facilities, which are residential settings that receive payments on behalf of two or more unrelated adults who reside in the 
facility and receive nursing care services or a substantial amount of personal care services (PCS).  SSA  1903(q)(4).  As of 
December 27, 2020, MFCUs may also receive Federal financial participation to investigate and prosecute abuse or neglect of 
Medicaid enrollees in a noninstitutional or other setting.  Consolidated Appropriations Act, 2021, P.L. No. 116-260, 
Division CC  207. 
2 SSA  1902(a)(61). 
3 The SSA authorizes the Secretary of HHS to award grants (SSA  1903(a)(6)) and to certify and annually recertify Units 
(SSA  1903(q)).  The Secretary delegated this authority to OIG.  See also 42 CFR  1007.15.  Units must meet several 
requirements established by the SSA and Federal regulations.  For example, each Unit must (1) be a single, identifiable entity of 
State Government, separate and distinct from the State Medicaid agency (SSA  1903(q)(2); 42 CFR  1007.5(a) and 1007.9(a)); 
(2) employ an interdisciplinary staff that consists of at least an investigator, an auditor, and an attorney (SSA  1903(q)(6); 
42 CFR  1007.13); (3) develop a formal agreement, such as a memorandum of understanding, describing the Units 
relationship with the State Medicaid agency (42 CFR  1007.9(d)); and (4) have either statewide authority to prosecute cases or 
formal procedures to refer suspected criminal violations to an agency with such authority (SSA  1903(q)(1); 42 CFR  1007.7).  
4 The territories of American Samoa, Guam, and the Northern Mariana Islands have not established Units.  Puerto Rico and the 
U.S. Virgin Islands received certification to operate in FY 2019 and North Dakota received certification to operate in FY 2020.  
 
5 SSA  1903(a)(6).  For a Units first 3 years of operation, the Federal Government contributes 90 percent of funding and the 
State contributes 10 percent.  Thereafter, the Federal Government contributes 75 percent and the State contributes 25 percent. 
 
6 OIGs analysis of MFCU Annual Statistical Reports for FY 2022.  
 
7 42 CFR  1007.20.  MFCUs must receive approval from OIG to conduct data mining.  As of January 2023, 22 MFCUs were 
approved for data mining.  OIG, Data Mining Applications, https://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/data-
mining.asp.  Accessed on January 17, 2023.  
 
8 SSA  1128; 42 U.S.C.  1320a-7.  See also OIG, Background Information, https://oig.hhs.gov/exclusions/background.asp.  
Accessed on March 6, 2023.  
 
9 OIG provides information on MFCU operations and outcomes but does not direct or encourage MFCUs to investigate or 
prosecute a specific number of cases.  MFCU investigators and prosecutors should apply professional judgment and discretion 
in determining what criminal and civil cases to pursue. 
 
10 42 CFR  1007.15. 
 
11 MFCU performance standards are published at 77 Fed. Reg. 32645 (June 1, 2012).  
   
12 To calculate the ROI for MFCUs, we first calculated the total recoveries by adding the $416 million in criminal case recoveries 
to the $641 million in civil case recoveries.  We then divided the $1.1 billion in total recoveries by the total MFCU grant 
expenditures of $343 million, resulting in the overall ROI of $3.08 for every $1 spent. 
 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report  
OEI-09-23-00190  Endnotes | 25    
 
13 OIG, LEIE Downloadable Databases, https://oig.hhs.gov/exclusions/exclusions_list.asp.  Accessed on January 3, 2023.  The list 
of OIG-excluded individuals or entities can be found on the OIG website.   
14 MFCUs may receive Federal financial participation for investigating Medicaid providers for alleged fraudulent activities 
related to drug diversion regardless of whether the Medicaid program was billed.  OIG, State Fraud Policy Transmittal 2020-3, 
MFCU Authority to Receive Federal Funding to Investigate and Prosecute Diversion and Misuse of Pharmaceuticals, 
October 28, 2020.  This transmittal describes the situations in which Units may receive Federal financial participation to 
investigate and prosecute drug diversion cases.  
 
15 U.S. Attorneys Office Northern District of Texas, Novus Hospice CEO Sentenced to 13+ Years for Healthcare Fraud, 
https://www.justice.gov/usao-ndtx/pr/novus-hospice-ceo-sentenced-13-years-healthcare-fraud.  Accessed on 
January 26, 2023. 
 
16 To calculate the percentages for civil global and nonglobal recoveries, we used the total civil recoveries of  
$641,463,864 and rounded the dollar value to the nearest tenth.   
 
17 Wisconsin Department of Justice, Wisconsin Department of Justice Announces Mallinckrodt to Pay $230 Million Agreement in 
Underpayment of Medicaid Drug Rebates Lawsuit.  https://www.doj.state.wi.us/news-releases/wisconsin-department-justice-
announces-mallinckrodt-pay-230-million-agreement.  Accessed on January 26, 2023. 
Medicaid Fraud Control Units Fiscal Year 2022 Annual Report  
OEI-09-23-00190  Endnotes | 26