Department of Health and Human Services 
OFFICE OF 
 
 
INSPECTOR GENERAL 
 
 
 
 
 
 
 
 
 
A S M F
LASK  A  TATE  EDICAID  RAUD 
 
C U :  
ONTROL  NIT  
 
 
2016 O R  
  NSITE  EVIEW
 
 
 
 
 
 
 
 
 
 
 
 
Suzanne Murrin 
Deputy Inspector General for 
Evaluation and Inspections 
 
September 2017 
OEI-09-16-00430 
 
   
   
ALASKA STATE MEDICAID FRAUD CONTROL UNIT: 2016 ONSITE REVIEW 
OEI-09-16-00430 
WHY WE DID THIS STUDY  
The Office of Inspector General (OIG) administers the Medicaid Fraud Control Unit (MFCU or 
Unit) grant awards, annually recertifies the Units, and oversees the Units performance in 
accordance with the requirements of the grant.  As part of this oversight, OIG conducts periodic 
reviews of all Units and prepares public reports based on these reviews.  These reviews assess 
the Units adherence to the 12 MFCU performance standards and compliance with applicable 
Federal statutes and regulations.  
HOW WE DID THIS STUDY 
We conducted an onsite review of the Alaska Unit in August 2016.  We based our review on an 
analysis of data from seven sources:  (1) policies, procedures, and documentation related to the 
Units operations, staffing, and caseload; (2) financial documentation for fiscal years (FYs) 2013 
through 2015; (3) structured interviews with key stakeholders; (4) a survey of Unit staff; 
(5) structured interviews with the Units management and forensic accountant; (6) a sample of 
files for cases that were open in FYs 2013 through 2015; and (7) observation of Unit operations. 
WHAT WE FOUND 
For FYs 2013 through 2015, the Alaska Unit obtained 80 criminal convictions; 36 civil 
judgments and settlements; and combined criminal and civil recoveries totaling $10.4 million, 
and it increased its combined criminal and non-global civil recoveries each year.  We found 
that the Unit was generally in compliance with applicable laws, regulations, and policy 
transmittals.  In addition, the Unit improved its collaboration with stakeholders.  Further, the 
Unit combated fraud in personal care services (PCS) through investigations of large PCS 
agencies, effective collaboration with stakeholders, and recommendations to Alaskas Medicaid 
agency. 
However, we found two operational areas in which the Unit should improve its adherence to 
performance standards:  the Units case files lacked documentation of periodic supervisory 
reviews, and its training plan did not specify the minimum number of training hours that Unit 
staff were required to complete.  We also found two areas in which the Unit should improve its 
compliance with Federal requirements:  it did not fully secure its paper case files, and it did not 
appropriately remove costs associated with non-Unit activities from its Federal reimbursement 
request.  After our review, the Unit worked with OIG to return these funds. 
WHAT WE RECOMMEND 
We recommend that the Alaska Unit (1) develop and implement procedures to ensure that all 
case files include documentation of periodic supervisory reviews, (2) revise its training plan to 
specify the minimum number of training hours that Unit staff are required to complete, (3) revise 
its policies and procedures manual to include procedures for securing paper case files, and 
(4) develop and implement internal controls to ensure that costs associated with non-Unit 
activities are removed from Federal reimbursement requests.  The Unit concurred with all four 
recommendations.   
 
   
   
TABLE OF CONTENTS 
Objective ......................................................................................................1 
Background ..................................................................................................1 
Methodology ................................................................................................4 
Findings........................................................................................................5 
For FYs 2013 through 2015, the Alaska Unit reported  
80 criminal convictions and 36 civil judgments and settlements ....5 
For FYs 2013 through 2015, the Alaska Unit reported  
recoveries of $10.4 million, and its criminal and nonglobal civil  
recoveries increased each year .........................................................5 
Eighty-eight percent of Unit case files lacked documentation 
of periodic supervisory reviews .......................................................6 
The Units training plan did not specify the minimum number of  
training hours that Unit staff were required to complete .................7 
The Unit did not fully secure its paper case files .............................7 
The Unit did not appropriately remove costs associated with  
non-Unit activities from its Federal reimbursement request ............7 
Other observations .......................................................................................8 
The Unit improved its collaboration with stakeholders ...................8 
The Unit combated fraud in personal care services (PCS)  
through investigations of large PCS agencies, effective  
collaboration with stakeholders, and recommendations to  
Alaskas Medicaid agency ...............................................................8 
Conclusion and Recommendations ............................................................10 
Unit Comments and Office of Inspector General Response ..........12 
Appendixes ................................................................................................13 
A:  2012 Performance Standards ...................................................13 
B:  Alaska MFCU Referrals by Referral Source for FYs 2013 
Through 2015 .................................................................................17 
C:  Investigations Opened and Closed by the Alaska  
MFCU, by Case Type, FYs 2013 Through 2015 ...........................18 
D:  Detailed Methodology .............................................................19 
E:  Point Estimate and 95-Percent Confidence Interval Based  
on Reviews of Case Files ...............................................................23 
F:  Unit Comments .........................................................................24 
Acknowledgments......................................................................................27 
 
   
 
OBJECTIVE 
To conduct an onsite review of the Alaska State Medicaid Fraud Control 
Unit (MFCU or Unit). 
BACKGROUND 
The mission of MFCUs is to investigate and prosecute Medicaid provider 
fraud and patient abuse or neglect under State law.1  The Social Security 
Act (SSA) requires each State to operate a MFCU, unless the Secretary of 
Health and Human Services determines that operation of a Unit would not 
be cost-effective because minimal Medicaid fraud exists in a particular 
State and the State has other adequate safeguards to protect Medicaid 
beneficiaries from abuse and neglect.2  Currently, 49 States and the 
District of Columbia (States) have MFCUs.3   
Each Unit must employ an interdisciplinary staff that consists of at least an 
investigator, an auditor, and an attorney.4  Unit staff review referrals of 
provider fraud and patient abuse or neglect to determine their potential for 
criminal prosecution and/or civil action.  In fiscal year (FY) 2016, the 
50 Units collectively reported 1,564 convictions; 998 civil settlements or 
judgments; and approximately $1.9 billion in recoveries.5, 6 
Units must meet a number of requirements established by the SSA and 
Federal regulations.  For example, each Unit must: 
  be a single, identifiable entity of State government, distinct from 
the single State Medicaid agency;7 
                        ____________________________________________________________ 
1 Social Security Act (SSA)  1903(q).  Regulations at 42 CFR  1007.11(b)(1) add that 
the Units responsibilities may include reviewing complaints of misappropriation of 
patients private funds in residential health care facilities. 
2 SSA  1902(a)(61).   
3 North Dakota and the territories of American Samoa, Guam, the Northern Mariana 
Islands, Puerto Rico, and the U.S. Virgin Islands have not established Units. 
4 SSA  1903(q)(6); 42 CFR 1007.13. 
5 Office of Inspector General (OIG), MFCU Statistical Data for Fiscal Year 2016, 
Accessed at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2016-statistical-chart.pdf on April 26, 2017. 
6 For the purpose of this report, FY refers to the Federal fiscal year (October 1 through 
September 30). 
7 SSA  1903(q)(2); 42 CFR  1007.5 and 1007.9(a). 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  1 
   
   
  develop a formal agreement, such as a memorandum of 
understanding (MOU), that describes the Units relationship with 
the State Medicaid agency;8 and   
  have either statewide authority to prosecute cases or formal 
procedures to refer suspected criminal violations to an agency with 
such authority.9   
MFCU Funding 
Each MFCU is funded jointly by its State and the Federal government.  
Federal funding for the MFCUs is provided as part of the Federal 
Medicaid appropriation, but it is administered by the Department of 
Health and Human Services (HHS) Office of Inspector General (OIG).10  
Each Unit receives Federal financial participation equivalent to 75 percent 
of its total expenditures, with State funds contributing the remaining 
25 percent.11  In FY 2016, combined Federal and State expenditures for the 
Units totaled $259 million, $194 million of which represented Federal 
funds.12 
Administration and Oversight of the MFCU Program 
The Secretary of HHS delegated to OIG the authority to administer the 
MFCU grant program.13  To receive Federal reimbursement, each Unit 
must submit an initial application to OIG for approval and be recertified 
each year thereafter.    
In annually recertifying the Units, OIG evaluates Unit compliance with 
Federal requirements and adherence to performance standards.  The Federal 
requirements for Units are contained in the SSA, regulations, and policy 
guidance.14  In addition, OIG has published 12 performance standards that it 
uses to assess whether a Unit is effectively performing its responsibilities.15  
The standards address topics such as staffing, maintaining adequate referrals, 
and cooperation with Federal authorities.  Appendix A contains these 
performance standards.  
                        ____________________________________________________________ 
8 42 CFR  1007.9(d).  
9 SSA  1903(q)(1). 
10 SSA  1903(a)(6)(B). 
11 Ibid. 
12 Office of Inspector General (OIG), MFCU Statistical Data for Fiscal Year 2016, 
Accessed at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2016-statistical-chart.pdf on April 26, 2017. 
13 The SSA authorizes the Secretary of HHS to award grants to the Units  
(SSA  1903(a)(6)); the Secretary delegated this authority to the OIG. 
14 On occasion, OIG issues policy transmittals to provide guidance and instructions to 
MFCUs. 
15 77 Fed. Reg. 32645 (June 1, 2012).  
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  2 
   
   
OIG also performs periodic onsite reviews of the Units, such as this review 
of the Alaska MFCU.  During these onsite reviews, OIG evaluates Units 
compliance with laws, regulations, and policies, as well as their adherence to 
the 12 performance standards.  OIG also makes observations about best 
practices, provides recommendations to the Units, and monitors the 
implementation of the recommendations.  These evaluations differ from 
other OIG evaluations in that they support OIGs direct administration of the 
MFCU grant program.  However, these evaluations are subject to the same 
internal quality controls as other OIG evaluations, including internal peer 
review.     
OIG provides additional oversight, including the collection and 
dissemination of performance data, training, and technical assistance.  
Alaska MFCU  
The Alaska Unit is an autonomous entity within the State Attorney 
Generals office (which Alaska calls the Department of Law) and is 
located in Anchorage.  The Unit investigates and prosecutes cases of 
Medicaid fraud and cases of patient abuse or neglect.  At the time of our 
review, the Units staff was composed of a director, who served as the 
chief attorney; one additional attorney; one chief investigator; 
five investigators; one forensic accountant; and one administrative staff 
member.  
The Unit receives most of its referrals from the program integrity unit 
within the States Department of Health and Social Services, which is 
Alaskas Medicaid agency.  The Unit also receives referrals from the 
Division of Senior and Disabilities Services (which oversees Alaskas 
Personal Care Services Program, among other programs), other law 
enforcement agencies, and private citizens.  Appendix B identifies the 
Unit referrals by source for FYs 2013 through 2015.  When the Unit 
receives a referral, the chief investigator conducts a preliminary 
assessment to determine whether the allegation has the potential for full 
investigation and is within the Units grant authority.  If the preliminary 
assessment shows that the allegation meets these criteria, the chief 
investigator assigns an investigator and opens the case.  At the time of our 
review, the director and deputy director served as the Units attorneys and 
prosecuted the Units cases.  Appendix C provides details on opened and 
closed investigations.   
Previous Review 
In 2010, OIG issued a report regarding its previous onsite review of the 
Alaska Unit.  The review found that the Unit adhered to the 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  3 
   
   
12 performance standards and complied with all applicable Federal rules 
and regulations that govern the grant.  
METHODOLOGY 
We conducted the onsite review in August 2016.  We based our review on 
an analysis of data from seven sources:  (1) policies, procedures, and 
documentation related to the Units operations, staffing, and caseload; 
(2) financial documentation for FYs 2013 through 2015; (3) structured 
interviews with key stakeholders; (4) a survey of Unit staff; (5) structured 
interviews with the Units management and forensic accountant; 
(6) a sample of files for cases that were open in FYs 2013 through 2015; 
and (7) observation of Unit operations.  Appendix D provides details of 
our methodology.   
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 
For FYs 2013 through 2015, the Alaska Unit reported 
80 criminal convictions and 36 civil judgments and 
settlements  
Exhibit 1 illustrates the Units annual criminal convictions and civil 
judgments and settlements during FYs 2013 through 2015.  Of the Units 
80 convictions over the 3-year period, 78 involved provider fraud and 
2 involved patient abuse or neglect.  Of the Units 36 civil judgments and 
settlements, 26 were a result of global16 cases, and 10 were a result of 
nonglobal cases that the Unit directly investigated.  Most of the Units 
convictions over the 3 years (71 of the 80) involved personal care services 
(PCS) fraud.   
Exhibit 1:  Alaska MFCU Criminal Convictions and Civil Judgments and 
Settlements, FYs 2013 through 2015 
3-Year 
Case Outcomes  FY 2013  FY 2014  FY 2015 
Total 
Criminal Convictions  19  43  18  80 
Civil Judgments and Settlements  10  18  8  36 
Source:  OIG review of Unit-submitted quarterly and annual statistical reports, 2017. 
For FYs 2013 through 2015, the Alaska Unit reported 
recoveries of $10.4 million, and its criminal and 
nonglobal civil recoveries increased each year 
For FYs 2013 through 2015, the Unit reported combined criminal and civil 
recoveries totaling $10.4 million.  Global cases accounted for $7.5 million 
of the $10.4 million in total recoveries.   
During this period, the Units combined criminal and nonglobal civil 
recoveries increased sharply, from approximately $58,000 in FY 2013 to 
$2.2 million in FY 2015.  According to the Unit, the large amount of 
nonglobal civil recoveries in FY 2015 was a result of a single case against 
a PCS agency for falsifying medical records. 
 
                        ____________________________________________________________ 
16 Global cases are civil False Claims Act cases that are litigated in Federal courts by 
the U.S. Department of Justice and involve a group of MFCUs.  The National 
Association of Medicaid Fraud Control Units facilitates the settlement of global cases on 
behalf of the States.  
 
 
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Of the approximately $2.9 million in combined criminal and nonglobal 
civil recoveries, $1.2 million were from criminal cases and $1.7 million 
were from civil cases.    Exhibit 2 illustrates the Units annual recoveries 
and expenditures for FYs 2013 through 2015.     
Exhibit 2:  Alaska MFCU-Reported Recoveries and Total Expenditures, 
by Year, FYs 2013 through 2015 
  FY 2013  FY 2014  FY 2015  3-Year Total 
Total Civil and Criminal Recoveries  $1,097,442   $6,956,831   $2,298,122   $10,352,395  
     Global Civil Recoveries  $1,039,836   $6,400,763   $60,099   $7,500,698  
     Nonglobal Civil Recoveries  $200   $35,481   $1,628,023   $1,663,704  
     Criminal Recoveries  $57,406   $520,587   $610,000   $1,187,993  
Total Expenditures  $1,156,792   $1,105,990   $1,279,525   $3,542,307  
    
Source:  OIG review of the Unit-submitted quarterly and annual statistical reports, 2017. 
Eighty-eight percent of Unit case files lacked 
documentation of periodic supervisory reviews   
Eighty-eight percent of the Units case files that were open for at least 
6 months lacked documentation of periodic supervisory reviews.17  
Performance Standards 5(b) and 7(a) state that supervisors should 
periodically review the progress of cases, consistent with Unit policies and 
procedures, to ensure that each stage of an investigation and prosecution is 
completed in an appropriate timeframe, and note in the case file that the 
reviews take place.  Both Unit management and investigators reported that 
supervisors periodically review cases.  However, the Unit did not have a 
practice of noting such reviews in the case files, nor did it have written 
procedures for supervisors to do so.  Unit management stated that, as 
theirs is a small Unit, managers and investigators work closely with one 
another to investigate cases and prepare them for prosecution.  According 
to Unit management, this provides an opportunity to informally review 
cases and give feedback. 
                        ____________________________________________________________ 
17 We performed this analysis on the 58 cases in our sample that were open for at least 
6 months; cases open for a shorter time may not warrant supervisory review.  Appendix E 
contains the point estimate and 95-percent confidence interval for this estimate, derived 
from our review of case files. 
 
 
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The Units training plan did not specify the minimum 
number of training hours that Unit staff were required 
to complete      
The Units training plan did not specify the annual minimum number of 
training hours that staff from each professional discipline were required to 
complete.  According to Performance Standard 12(a), the Unit should have 
a training plan that includes an annual minimum number of training hours 
that is at least as stringent as required for professional certification.  
Although the Units training plan did not specify the minimum number of 
hours, Unit management reported that staff did participate in various 
MFCU-related trainings on topics such as identifying fraudulent identity 
documents; preservation and collection of digital evidence; and coding on 
claims for durable medical equipment. 
The Unit did not fully secure its paper case files  
During the onsite review, OIG observed that the Unit stored paper case 
files in unlocked offices and file cabinets.  Federal regulations require 
Units to safeguard the privacy rights of all individuals and provide 
safeguards to prevent the misuse of information under the Units 
control.18  This includes safeguarding potentially sensitive personally 
identifiable information about witnesses, victims, suspects, and 
informants.  Unit management explained that although individuals must 
use a coded access card to enter the Units general office area, janitorial 
staff routinely accessed the Units office during nonbusiness hours when 
Unit staff were not presentmeaning that non-Unit staff had unsupervised 
access to the paper case files.  The Unit had a policy related to case file 
security, but it did not specify how and where to securely store paper files.    
The Unit did not appropriately remove costs 
associated with non-Unit activities from its Federal 
reimbursement request  
During FY 2015, a Unit staff member performed activities that were not 
related to the Unit, and the Unit did not remove the appropriate portion of 
the staff members salary from the MFCU grant reimbursement request.  
Federal regulations state that a Unit may request Federal reimbursement 
only for costs attributable to the establishment and operation of the Unit.19  
Although OIG guidance permits Unit staff to engage in temporary 
                        ____________________________________________________________ 
18 42 CFR  1007.11(f). 
19 42 CFR  1007.19(d). 
 
 
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non-Unit activities, the Unit must document and maintain records of the 
time spent on these activities, and exclude the time from the Units 
requests for reimbursement.20  In this case, the Unit staff member provided 
three non-Unit related trainings and performed legal duties for the District 
Attorneys Office.  The Unit documented and maintained records of the 
time spent on non-Unit activities.  However, the Unit did not exclude 
50.5 hours (equaling a Federal share of $3,174) from its reimbursement 
request for the staff members salary.  After our review, the Unit worked 
with OIG to return these funds. 
Other observation:  The Unit improved its 
collaboration with stakeholders 
All Unit stakeholders reported that communication and/or collaboration 
with the Unit substantially improved during FYs 2013 through 2015, 
following the appointment of a new director in October 2012.21  HHS OIG, 
for example, noted that the frequency of communication with the Unit 
changed from sporadic, quarterly meetings in FY 2013 to almost weekly 
communication a year later.  Further, HHS OIG reported that the number 
of joint cases with the Unit increased from 3 cases in FY 2012 to 10 cases 
in FY 2015.  Other Unit stakeholders (representatives from the Alaska 
Medicaid Program Integrity Division, Alaska Adult Protective Services, 
Alaska Senior and Disabilities Services, the United States Attorneys 
Office, and the Federal Bureau of Investigation) also attributed 
improvements in collaboration to the Unit directors efforts.   
Other observation:  The Unit combated PCS fraud 
through investigations of large PCS agencies, 
effective collaboration with stakeholders, and 
recommendations to Alaskas Medicaid agency  
During our review period, the Unit investigated and prosecuted two large 
PCS agencies.  The Units Medicaid fraud charges against one of these 
agencies resulted in a plea agreement stipulating that the agency could no 
longer bill Medicaid and must pay a fine of $300,000 and restitution of 
                        ____________________________________________________________ 
20 OIG, OIG State Fraud Policy Transmittal Number 2014-1.  Accessed at 
https://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/policy_transmittals/ 
State%20Fraud%20Policy%20Transmittal%20No%20%202014-1.pdf on April 5, 2017. 
21 After our onsite review in August 2016, the Unit director was promoted to another 
position in the Alaska Attorney Generals office and a new director was appointed to the 
MFCU. 
 
 
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$1.2 million.  The Unit also successfully prosecuted PCS agency owners 
and employees, including numerous PCS attendants.   
In conducting its PCS investigations, the Unit effectively collaborated 
with Federal and State partners, including the Department of Homeland 
Securitys Immigration and Customs Enforcement (ICE).22  For example, 
ICE provided the Unit with access to travel records of PCS attendants or 
service recipients who were traveling outside the United States.  Using 
these travel records and PCS attendant timesheets, the Unit demonstrated 
that attendants could not have provided the services billed to Medicaid 
because the PCS attendant or the recipient was outside the United States 
on the days in question.    
On the basis of its PCS investigations, the Unit also made 
recommendations for program integrity improvements to Alaskas 
Medicaid agency.  As one example, the Unit recommended that the 
Medicaid agency require that timesheets for PCS attendants be uniform to 
include dates of service, start and end times, and the type of service 
provided.  Unit management reported that the Unit continues to work with 
the Medicaid agency to implement recommended improvements.   
 
                        ____________________________________________________________ 
22 The Unit also collaborated with Alaskas Medicaid agency, Alaskas Department of 
Law, the Federal Bureau of Investigation, and HHS OIG during its PCS investigations. 
 
 
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CONCLUSION AND RECOMMENDATIONS 
For FYs 2013 through 2015, the Alaska Unit obtained 80 criminal 
convictions; 36 civil judgments and settlements; and combined criminal 
and civil recoveries totaling $10.4 million, and it increased its combined 
criminal and nonglobal civil recoveries each year.  We found that the 
Alaska Unit was generally in compliance with applicable laws, 
regulations, and policy transmittals.  During our review, we noted that the 
Unit improved its collaboration with stakeholders under new leadership, 
and combated PCS fraud through investigations of large PCS agencies, 
effective collaboration with stakeholders, and recommendations for 
program integrity improvements to Alaskas Medicaid agency.    
However, we found two operational areas in which the Alaska Unit should 
improve its adherence to performance standards:  the Units case files 
lacked documentation of periodic supervisory reviews, and its training 
plan did not specify the minimum number of training hours that Unit staff 
were required to complete.  We also found two areas in which the Unit 
should improve its compliance with Federal requirements:  it did not fully 
secure its paper case files, and it did not appropriately remove costs 
associated with non-Unit activities from its Federal reimbursement 
request.   
We recommend that the Alaska Unit:   
Develop and implement procedures to ensure that all case 
files include documentation of periodic supervisory reviews 
The Unit should develop and implement written supervisory review 
procedures that, at a minimum, include documenting the name of the 
supervisor and date of review in all case files.  The Unit should document 
the new procedures in its policies and procedures manual. 
Revise its training plan to specify the minimum number of 
training hours that Unit staff are required to complete  
The Unit should revise its training plan to specify the annual minimum 
number of training hours that staff from each professional discipline need 
to complete and continue to provide MFCU-related training for its staff.   
Revise its policies and procedures manual to include 
procedures for securing paper case files 
The Unit should revise its existing policies and procedures manual to 
specify how and where to securely store paper files.  The Unit should 
develop and implement procedures to ensure that all paper case files and 
any associated personally identifiable information are secured from access 
 
 
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by non-Unit staff.  At a minimum, the Unit should store its paper case files 
and other documentation containing personally identifiable information in 
locked offices or file cabinets to prevent access by janitorial staff during 
nonbusiness hours.   
Develop and implement internal controls to ensure that costs 
associated with non-Unit activities are removed from Federal 
reimbursement requests 
The Unit should develop and implement internal controls to ensure that it 
removes costs not related to the establishment or operations of the Unit 
from its MFCU grant reimbursement requests.  The Unit should document 
the new internal controls in its policies and procedures manual. 
 
 
   
 
 
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UNIT COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
The Alaska Unit concurred with all four of our recommendations.  OIG 
anticipates that the Units planned actions, when completed, will 
implement our recommendations. 
Regarding our first recommendation (for the Unit to develop and 
implement procedures to ensure that all case files include documentation 
of periodic supervisory reviews), the Unit stated that it has implemented a 
process for quarterly supervisory reviews and that appropriate notations 
will be made in each case file. 
Regarding our second recommendation (for it to revise the training plan to 
specify the minimum number of training hours that Unit staff are required 
to complete), the Unit stated that it plans to update its training plan by the 
end of 2017 and that it is working on ways to improve the availability of 
training opportunities.   
Regarding our third recommendation (for it to develop and implement 
procedures for securing paper case files), the Unit stated that any file 
containing personally identifiable information will be kept in locked 
offices or stored in locked filing cabinets.  Further, the Unit reported that 
since the time of the onsite review, the Unit has moved to a new suite 
where attorneys and investigators have locking office doors.  The Unit 
said that it will attempt to obtain locking file cabinets in the immediate 
future for the general office area.     
Regarding our fourth recommendation (for it to develop and implement 
internal controls to ensure that costs associated with non-Unit activities are 
removed from Federal reimbursement requests), the Unit stated that it will 
document any time spent on non-Unit activities and deduct the associated 
costs from the grant.   
The full text of the Units comments is provided in Appendix F. 
 
 
 
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APPENDIX A 
2012 Performance Standards23  
1.  A UNIT CONFORMS WITH ALL APPLICABLE STATUTES, REGULATIONS, AND POLICY DIRECTIVES, 
INCLUDING: 
A.  Section 1903(q) of the Social Security Act,  containing the basic requirements for operation of a MFCU; 
B.  Regulations for operation of a MFCU contained in 42 CFR part 1007; 
C.  Grant administration requirements at 45 CFR part 92 and Federal cost principles at 2 CFR part 225; 
D.  OIG policy transmittals as maintained on the OIG Web site; and  
E.  Terms and conditions of the notice of the grant award. 
2.  A UNIT MAINTAINS REASONABLE STAFF LEVELS AND OFFICE LOCATIONS IN RELATION TO THE 
STATES MEDICAID PROGRAM EXPENDITURES AND IN ACCORDANCE WITH STAFFING 
ALLOCATIONS APPROVED IN ITS BUDGET.   
A.  The Unit employs the number of staff that is included in the Units budget estimate as approved by OIG. 
B.  The Unit employs a total number of professional staff that is commensurate with the States total Medicaid 
program expenditures and that enables the Unit to effectively investigate and prosecute (or refer for 
prosecution) an appropriate volume of case referrals and workload for both Medicaid fraud and patient abuse 
and neglect. 
C.  The Unit employs an appropriate mix and number of attorneys, auditors, investigators, and other 
professional staff that is both commensurate with the States total Medicaid program expenditures and that 
allows the Unit to effectively investigate and prosecute (or refer for prosecution) an appropriate volume of case 
referrals and workload for both Medicaid fraud and patient abuse and neglect. 
D.  The Unit employs a number of support staff in relation to its overall size that allows the Unit to operate 
effectively. 
E.  To the extent that a Unit maintains multiple office locations, such locations are distributed throughout the 
State, and are adequately staffed, commensurate with the volume of case referrals and workload for each 
location. 
3. A UNIT ESTABLISHES WRITTEN POLICIES AND PROCEDURES FOR ITS OPERATIONS AND 
ENSURES THAT STAFF ARE FAMILIAR WITH, AND ADHERE TO, POLICIES AND PROCEDURES.   
A.  The Unit has written guidelines or manuals that contain current policies and procedures, consistent with 
these performance standards, for the investigation and (for those Units with prosecutorial authority) prosecution 
of Medicaid fraud and patient abuse and neglect.  
B.  The Unit adheres to current policies and procedures in its operations. 
C.  Procedures include a process for referring cases, when appropriate, to Federal and State agencies.  
Referrals to State agencies, including the State Medicaid agency, should identify whether further investigation 
or other administrative action is warranted, such as the collection of overpayments or suspension of payments. 
D.  Written guidelines and manuals are readily available to all Unit staff, either online or in hard copy. 
E.  Policies and procedures address training standards for Unit employees. 
4. A UNIT TAKES STEPS TO MAINTAIN AN ADEQUATE VOLUME AND QUALITY OF REFERRALS FROM 
THE STATE MEDICAID AGENCY AND OTHER SOURCES.   
A.  The Unit takes steps, such as the development of operational protocols, to ensure that the State Medicaid 
agency, managed care organizations, and other agencies refer to the Unit all suspected provider fraud cases.  
Consistent with 42 CFR 1007.9(g), the Unit provides timely written notice to the State Medicaid agency when 
referred cases are accepted or declined for investigation. 
Continued on page 14 
                        ____________________________________________________________ 
23 77 Fed. Reg. 32645, June 1, 2012. 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  13 
   
   
 
B.  The Unit provides periodic feedback to the State Medicaid agency and other referral sources on the 
adequacy of both the volume and quality of its referrals. 
C.  The Unit provides timely information to the State Medicaid or other agency when the Medicaid or other 
agency requests information on the status of MFCU investigations, including when the Medicaid agency 
requests quarterly certification pursuant to 42 CFR 455.23(d)(3)(ii). 
D.  For those States in which the Unit has original jurisdiction to investigate or prosecute patient abuse and 
neglect cases, the Unit takes steps, such as the development of operational protocols, to ensure that pertinent 
agencies refer such cases to the Unit, consistent with patient confidentiality and consent.  Pertinent agencies 
vary by State but may include licensing and certification agencies, the State Long Term Care Ombudsman, and 
adult protective services offices.  
E.  The Unit provides timely information, when requested, to those agencies identified in (D) above regarding 
the status of referrals. 
F.  The Unit takes steps, through public outreach or other means, to encourage the public to refer cases to the 
Unit. 
5. A UNIT TAKES STEPS TO MAINTAIN A CONTINUOUS CASE FLOW AND TO COMPLETE CASES IN AN 
APPROPRIATE TIMEFRAME BASED ON THE COMPLEXITY OF THE CASES. 
A.  Each stage of an investigation and prosecution is completed in an appropriate timeframe. 
B.  Supervisors approve the opening and closing of all investigations and review the progress of cases and take 
action as necessary to ensure that each stage of an investigation and prosecution is completed in an 
appropriate timeframe. 
C.  Delays to investigations and prosecutions are limited to situations imposed by resource constraints or other 
exigencies.   
6.  A UNITS CASE MIX, AS PRACTICABLE, COVERS ALL SIGNIFICANT PROVIDER TYPES AND 
INCLUDES A BALANCE OF FRAUD AND, WHERE APPROPRIATE, PATIENT ABUSE AND NEGLECT 
CASES.   
A.  The Unit seeks to have a mix of cases from all significant provider types in the State. 
B.  For those States that rely substantially on managed care entities for the provision of Medicaid services, the 
Unit includes a commensurate number of managed care cases in its mix of cases.  
D.  As part of its case mix, the Unit maintains a balance of fraud and patient abuse and neglect cases for those 
States in which the Unit has original jurisdiction to investigate or prosecute patient abuse and neglect cases. 
C.  The Unit seeks to allocate resources among provider types based on levels of Medicaid expenditures or 
other risk factors.  Special Unit initiatives may focus on specific provider types. 
E.  As part of its case mix, the Unit seeks to maintain, consistent with its legal authorities, a balance of criminal 
and civil fraud cases. 
7.  A UNIT MAINTAINS CASE FILES IN AN EFFECTIVE MANNER AND DEVELOPS A CASE 
MANAGEMENT SYSTEM THAT ALLOWS EFFICIENT ACCESS TO CASE INFORMATION AND OTHER 
PERFORMANCE DATA.   
A.  Reviews by supervisors are conducted periodically, consistent with MFCU policies and procedures, and are 
noted in the case file. 
B.  Case files include all relevant facts and information and justify the opening and closing of the cases. 
C.  Significant documents, such as charging documents and settlement agreements, are included in the file.  
D.  Interview summaries are written promptly, as defined by the Units policies and procedures. 
E.  The Unit has an information management system that manages and tracks case information from initiation to 
resolution. 
F. The Unit has an information management system that allows for the monitoring and reporting of case 
information, including the following:  
1. The number of cases opened and closed and the reason that cases are closed. 
Continued on page 15 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  14 
   
   
 
2.  The length of time taken to determine whether to open a case referred by the State Medicaid agency or other 
referring source. 
3.  The number, age, and types of cases in the Units inventory/docket 
4.  The number of referrals received by the Unit and the number of referrals by the Unit to other agencies. 
5.  The number of cases criminally prosecuted by the Unit or referred to others for prosecution, the number of 
individuals or entities charged, and the number of pending prosecutions. 
6.  The number of criminal convictions and the number of civil judgments. 
7.  The dollar amount of overpayments identified. 
8.  The dollar amount of fines, penalties, and restitution ordered in a criminal case and the dollar amount of 
recoveries and the types of relief obtained through civil judgments or prefiling settlements. 
8.  A UNIT COOPERATES WITH OIG AND OTHER FEDERAL AGENCIES IN THE INVESTIGATION AND 
PROSECUTION OF MEDICAID AND OTHER HEALTH CARE FRAUD.   
A.   The Unit communicates on a regular basis with OIG and other Federal agencies investigating or 
prosecuting health care fraud in the State. 
B.  The Unit cooperates and, as appropriate, coordinates with OIGs Office of Investigations and other Federal 
agencies on cases being pursued jointly, cases involving the same suspects or allegations, and cases that have 
been referred to the Unit by OIG or another Federal agency.  
C.  The Unit makes available, to the extent authorized by law and upon request by Federal investigators and 
prosecutors, all information in its possession concerning provider fraud or fraud in the administration of the 
Medicaid program. 
D.  For cases that require the granting of extended jurisdiction to investigate Medicare or other Federal health 
care fraud, the Unit seeks permission from OIG or other relevant agencies under procedures as set by those 
agencies.  
E.  For cases that have civil fraud potential, the Unit investigates and prosecutes such cases under State 
authority or refers such cases to OIG or the U.S. Department of Justice. 
F.  The Unit transmits to OIG, for purposes of program exclusions under section 1128 of the Social Security Act, 
all pertinent information on MFCU convictions within 30 days of sentencing, including charging documents, plea 
agreements, and sentencing orders. 
G.  The Unit reports qualifying cases to the Healthcare Integrity & Protection Databank, the National Practitioner 
Data Bank, or successor data bases. 
9. A UNIT MAKES STATUTORY OR PROGRAMMATIC RECOMMENDATIONS, WHEN WARRANTED, TO 
THE STATE GOVERNMENT.   
A.  The Unit, when warranted and appropriate, makes statutory recommendations to the State legislature to 
improve the operation of the Unit, including amendments to the enforcement provisions of the State code. 
B.  The Unit, when warranted and appropriate, makes other regulatory or administrative recommendations 
regarding program integrity issues to the State Medicaid agency and to other agencies responsible for Medicaid 
operations or funding.  The Unit monitors actions taken by the State legislature and the State Medicaid or other 
agencies in response to recommendations.  
10. A UNIT PERIODICALLY REVIEWS ITS MEMORANDUM OF UNDERSTANDING (MOU) WITH THE 
STATE MEDICAID AGENCY TO ENSURE THAT IT REFLECTS CURRENT PRACTICE, POLICY, AND 
LEGAL REQUIREMENTS.   
A.  The MFCU documents that it has reviewed the MOU at least every 5 years, and has renegotiated the MOU 
as necessary, to ensure that it reflects current practice, policy, and legal requirements. 
B.  The MOU meets current Federal legal requirements as contained in law or regulation, including 42 CFR  
455.21, Cooperation with State Medicaid fraud control units, and 42 CFR  455.23, Suspension of payments 
in cases of fraud. 
Continued on page 16 
 
 
 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  15 
   
   
 
C.  The MOU is consistent with current Federal and State policy, including any policies issued by OIG or the 
Centers for Medicare & Medicaid Services (CMS). 
D.  Consistent with Performance Standard 4, the MOU establishes a process to ensure the receipt of an 
adequate volume and quality of referrals to the Unit from the State Medicaid agency. 
E.  The MOU incorporates by reference the CMS Performance Standard for Referrals of Suspected Fraud from 
a State Agency to a Medicaid Fraud Control Unit. 
11. A UNIT EXERCISES PROPER FISCAL CONTROL OVER UNIT RESOURCES.   
A.  The Unit promptly submits to OIG its preliminary budget estimates, proposed budget, and Federal financial 
expenditure reports.   
B.  The Unit maintains an equipment inventory that is updated regularly to reflect all property under the Units 
control. 
C.  The Unit maintains an effective time and attendance system and personnel activity records. 
D.  The Unit applies generally accepted accounting principles in its control of Unit funding. 
E.  The Unit employs a financial system in compliance with the standards for financial management systems 
contained in 45 CFR 92.20. 
12. A UNIT CONDUCTS TRAINING THAT AIDS IN THE MISSION OF THE UNIT.   
A.  The Unit maintains a training plan for each professional discipline that includes an annual minimum number 
of training hours and that is at least as stringent as required for professional certification.  
B.  The Unit ensures that professional staff comply with their training plans and maintain records of their staffs 
compliance. 
C.  Professional certifications are maintained for all staff, including those that fulfill continuing education 
requirements. 
D.  The Unit participates in MFCU-related training, including training offered by OIG and other MFCUs, as such 
training is available and as funding permits. 
E.  The Unit participates in cross-training with the fraud detection staff of the State Medicaid agency.  As part of 
such training, Unit staff provide training on the elements of successful fraud referrals and receive training on the 
role and responsibilities of the State Medicaid agency.  
 
 
 
 
 
 
 
 
 
 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  16 
   
   
APPENDIX B 
Alaska MFCU Referrals by Referral Source for FYs 2013 
Through 2015 
   
FY 2013  FY 2014  FY 2015 
Abuse/   Abuse/   Abuse/  
Referral Source  Fraud  Fraud  Fraud  Total 
Neglect1  Neglect  Neglect 
Medicaid Agency  
84  4  0  0  60  0  148 
SUR/S2 or OMIG3 
Medicaid Agency  
93  6  15  0  7  0  121 
Other 
Private Citizen  87  1  18  3  7  2  118 
Law Enforcement  84  10  10  1  2  0  107 
State Agencies  
60  8  21  1  1  0  91 
Other 
Adult Protective 
26  23  3  18  2  2  74 
Services 
Provider  32  1  15  0  11  0  59 
HHS OIG  3  0  15  0  1  0  19 
Prosecutor  1  0  5  0  0  0  6 
Ombudsman  1  0  1  2  0  0  4 
Anonymous4  N/A   N/A    N/A    N/A    4  0  4 
State Survey and 
Certification  3  0  0  0  0  0  3 
Agency 
Licensing Board  0  2  1  0  0  0  3 
MFCU Hotline5  1  1  0  0  N/A    N/A    2 
   Total  475  56  104  25  95  4  759 
 
   Annual Total  531  129  99 
Source:  OIG analysis of Unit Quarterly and Annual Statistical Reports, 2017. 
1 The category of referrals of abuse and neglect includes referrals of misappropriation of patient funds. 
2 SURS = Surveillance and Utilization Review Subsystem. 
3 OMIG = Office of the Medicaid Inspector General. 
4 The referral source Anonymous was not a category reported on the FY 2013 and FY 2014 Quarterly Statistical 
Reports. 
5 The referral source MFCU hotline was not a category reported on the FY 2015 Annual Statistical Report. 
 
 
 
 
 
 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  17 
   
   
APPENDIX C 
Investigations Opened and Closed by the Alaska MFCU, by 
Case Type, FYs 2013 through 2015 
 
  Annual    
Case Type  FY 2013  FY 2014  FY 2015  3-Year Total 
Average* 
Opened  566  129  145  840  280 
Provider Fraud  472  108  144  724  241 
Patient Abuse and 
94  21  1  116  39 
Neglect 
Closed  437  179  171  787  262 
Provider Fraud  348  149  164  661  220 
Patient Abuse and 
89  30  7  126  42 
Neglect 
Source:   OIG analysis of Unit Quarterly and Annual Statistical Reports, 2016. 
*Averages in this column are rounded. 
 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  18 
   
   
APPENDIX D 
Detailed Methodology 
We used data collected from the seven sources below to describe the 
caseload and assess the performance of the Alaska MFCU. 
Data Collection 
Review of Unit Documentation.  Prior to the onsite visit, we analyzed 
information regarding the Units investigation of Medicaid cases, 
including information about the number of referrals the Unit received; the 
number of investigations the Unit opened and closed; the outcomes of 
those investigations; and the Units case mix.  We also collected and 
analyzed information about the number of cases that the Unit referred for 
prosecution and the outcomes of those prosecutions.   
We gathered this information from several sources, including the Units 
quarterly statistical reports, its annual reports, its recertification 
questionnaire, and its policy and procedures manuals.  We requested any 
additional data or clarification from the Unit as necessary. 
Review of Unit Financial Documentation.  We reviewed Unit financial 
documentation to identify any issues involving internal controls or the use 
of resources.  Prior to the onsite review, we reviewed the Units financial 
policies and procedures; its response to an internal control questionnaire; 
and documents (such as financial status reports) related to MFCU grants. 
We reviewed four purposive samples to assess the Units internal control 
of fiscal resources.  All four samples were limited to the review period of 
FYs 2013 through 2015.  The four samples included the following: 
1.  To assess the Units expenditures, we selected a purposive sample 
of 24 items from the Units 733 expenditure transactions.  We 
selected routine and nonroutine transactions representing a variety 
of budget categories and payment amounts.  
2.  To assess the Units travel expenditures, we selected a purposive 
sample of 24 items from the Units 130 travel transactions.  We 
selected a variety of travel expenditure categories related to both 
in-State and out-of-State travel, such as hotel stays, airfare, and 
conference expenses.   
3.  To assess employees time and efforti.e., their work hours 
spent on various MFCU taskswe selected a sample of three pay 
periods, one from each fiscal year.  We then requested and 
reviewed documentation (e.g., timecard records) to support the 
time and effort of the MFCU staff during the selected pay periods. 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  19 
   
   
4.  We also reviewed a purposive sample of the Units supply 
inventory. Specifically, we selected and verified a purposive 
sample of 20 items from the current inventory list of 42 items 
maintained in the Units office.   
Interviews With Key Stakeholders.  In July 2016, we interviewed eight 
individual stakeholders from six agencies who were familiar with MFCU 
operations.  Specifically, we interviewed one program integrity director 
from the State Medicaid agency; two managers from the Alaska Office of 
Senior and Disabilities Services; one Assistant U.S. Attorney; the 
Supervising Assistant Alaska Attorney General24; two FBI agents based in 
Alaska; and one OIG Special Agent in Charge.  We focused these 
interviews on the Units relationship and interaction with OIG and other 
Federal and State authorities, and opportunities for improvement.  We 
used the information collected from these interviews to develop 
subsequent interview questions for Unit management. 
Survey of Unit Staff.  In July 2016, we conducted an online survey of the  
seven staff members within the professional disciplines (i.e., investigators, 
forensic accountant and attorney) and support staff.  We received 
responses from all seven staff members.  Our questions focused on 
operations of the Unit, opportunities for improvement, and practices that 
contributed to the effectiveness and efficiency of Unit operations and/or 
performance.  The survey also sought information about the Units 
compliance with applicable laws and regulations. 
Onsite Interviews with Unit Management and Forensic Accountant.  We 
conducted structured interviews with the MFCUs director, chief 
investigator, and forensic accountant in August 2016.  We asked these 
individuals to provide information related to (1) the Units operations; 
(2) Unit practices that contributed to the effectiveness and efficiency of 
Unit operations and/or performance; (3) opportunities for the Unit to 
improve its operations and/or performance; and (4) clarification regarding 
information obtained from other data sources. 
Onsite Review of Case Files.  We requested that the Unit provide us with a 
list of cases that were open at any point during FYs 2013 through 2015.  
The Unit provided a list of 543 cases that were open during FYs 2013 
through 2015.25  For each of these 543 cases, the Unit provided data, 
including the current status of each case; whether each case was criminal, 
civil, or global; and the date on which each case was opened.  From this 
                        ____________________________________________________________ 
24 The Supervising Assistant Attorney General supervises the MFCU director. 
25 This figure includes some cases opened before FY 2013 that remained open at some 
point during FYs 2013 through 2015.   
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  20 
   
   
list of cases, we excluded 14 cases that were categorized as global,  
114 cases that the Unit chose not to pursue after an initial screening, and  
8 cases that were still being screened at the time of our review.  The 
remaining number of case files was 407. 
From the 407 remaining case files, we selected a simple random sample of 
100 cases for review.  To assess the Units processes for monitoring the 
status and outcomes of cases, we reviewed documentation in the case files 
and case file tracking system that was associated with the sample of cases.  
From this initial sample of 100 case files, we selected a simple random 
sample of 50 files for a qualitative review of selected issues, such as case 
development.  While onsite, we consulted MFCU staff to address any 
apparent issues with individual case files, such as missing documentation.   
We did not review five of the sampled cases because they were ineligible 
to be a part of our review for various reasons.  Two case files were 
duplicate files of other cases in our sample; one was a global case; one 
was closed prior to our review period; and one was not a full case, but 
rather a data pull to help another agencys investigation.  After excluding 
these ineligible cases, we reviewed 95 sampled case files.  Of the 95 case 
files, 79 cases were closed and 58 had been open for more than 180 days.  
Considering that there were 5 ineligible cases in the 100-case sample, it is 
possible that there were other ineligible cases in the population of 
407 cases that the Unit identified as distinct, non-global investigations 
open at any point during FYs 2013 through 2015.  Therefore, we estimated 
the number of case files in the population based on the eligible sample, as 
shown in Exhibit D-1.  We estimated (1) the total number of eligible case 
files, (2) the number of eligible closed case files, and (3) the number of 
eligible case files that were open for more than 180 days. 
Exhibit D-1:  Estimates of the Population of Eligible Case Files 
Population 
Sampled  95-Percent 
Estimate Description  of Case 
Case Files  Confidence Interval 
Files 
Total eligible case files  95  387  364399 
Eligible closed case 
files  79  322  288349 
Eligible case files open 
for more than 180 days  58  236  199272 
Source:  OIG analysis of Alaska MFCU case files, 2016. 
 
   
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  21 
   
   
Using the results of our review of the sampled case files, we report an 
estimate for the percentage of case files that were open longer than 
180 days that lacked documentation of periodic supervisory review.  We 
recognize that cases that have been open for a short period of time may not 
yet warrant supervisory review, and so we chose to exclude cases that 
were open for fewer than 180 days (6 months) from this analysis.  The 
point estimate and 95-percent confidence interval are in Appendix E. 
Onsite Review of Unit Operations.  During our August 2016 onsite visit, 
we reviewed the Units workspace and operations.  Specifically, we 
visited the Unit headquarters in Anchorage, Alaska.  While onsite, we 
observed the Units offices and meeting spaces; the security of data and 
case files; the location of select equipment; and the general functioning of 
the Unit. 
Data Analysis 
We analyzed data to identify any opportunities for improvement and 
instances in which the Unit did not fully meet the performance standards 
or was not operating in accordance with laws, regulations, or policy 
transmittals.26 
   
                        ____________________________________________________________ 
26 All relevant regulations, statutes, and policy transmittals are available online at 
http://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu. 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  22 
   
   
APPENDIX E 
Point Estimate and 95-Percent Confidence Interval Based on 
Reviews of Case Files 
95-Percent Confidence 
Sample  Point  Interval  
Estimate 
Size   Estimate 
Lower  Upper 
Percentage of case files that were open longer 
than 180 days that lacked documentation of  58  87.9%  77.4%  94.6% 
periodic supervisory review 
Source:  OIG analysis of Alaska MFCU case files, 2016. 
 
   
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  23 
   
   
APPENDIX F 
           Unit Comments 
 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  24 
   
   
 
 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  25 
   
   
 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  26 
   
   
ACKNOWLEDGMENTS 
Linda Min served as the project leader for this study.  Others in the Office 
of Evaluation and Inspections who conducted the study include 
Jordan Clementi and Rosemary Rawlins.  Office of Evaluation and 
Inspections central office staff who provided support include Kevin Farber 
and Christine Moritz. 
We would also like to acknowledge the contributions of other Office of 
Inspector General staff, including Lonie Kim in the Office of Counsel to 
the Inspector General and staff from the Office of Investigations. 
This report was prepared under the direction of Blaine Collins, Regional 
Inspector General for Evaluation and Inspections in the San Francisco 
regional office, and Abby Amoroso and Michael Henry, Deputy Regional 
Inspectors General, and in consultation with Richard Stern, Director of the 
Medicaid Fraud Policy and Oversight Division. 
 
 
Alaska State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00430)  27 
   
Office of Inspector General
http://oig.hhs.gov  
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95452, 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 individuals 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 individuals.  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.