U.S. Department of Health and Human Services 
Office of Inspector General 
 
Connecticut Medicaid Fraud 
Control Unit: 2021 Inspection 
 
Suzanne Murrin 
Deputy Inspector General for Evaluation and Inspections 
September 2022, OEI-06-21-00360  U.S. Department of Health and Human Services 
 
Office of Inspector General 
Report in Brief 
September 2022, OEI-06-21-00360 
Unit Case Outcomes  Connecticut Medicaid Fraud Control Unit: 
Federal fiscal years (FYs)  
2021 Inspection  
20192021 
  30 indictments  What OIG Found 
  9 convictions  From the information we reviewed, we found that the Connecticut MFCU 
  49 civil settlements and  generally operated in accordance with applicable laws, regulations, and 
judgments  policy transmittals.  However, we made four findings regarding the Units 
  $45.8 million in recoveries  adherence to the MFCU performance standards and compliance with 
with $33.1 million from  Federal regulations: 
global* civil cases,  
1.  During our review period, the Unit did not receive referrals of patient 
$9.2 million from nonglobal 
abuse or neglect and was unable to take sufficient steps to ensure 
civil cases, and $3.5 million 
that it received such referrals. 
from criminal cases 
2.  The Unit lacked a central repository for case information, making 
Unit Snapshot 
access to case data and pertinent case documents inefficient.   
The Connecticut Medicaid Fraud 
Control Unit (MFCU or Unit) is  3.  The Unit did not adhere to its policy of documenting supervisory 
located within the Connecticut  reviews monthly. 
Office of the Chief States 
Attorney (OCSA).  4.  The Unit did not consistently report convictions or adverse actions to 
Federal partners within the appropriate timeframes. 
At the time of our onsite 
inspection in November 2021,  In addition to the findings, we made several observations regarding Unit 
the Unit had a total of 13 staff  operations and practices. 
located in Rocky Hill.  
What OIG Recommends  
*Global recoveries derive from civil  To address the findings, we recommend that the Unit (1) develop and 
settlements or judgments involving  implement outreach efforts to ensure that the Unit regularly receives 
the U.S. Department of Justice and a 
referrals of patient abuse and neglect; (2) seek approval from OCSA to 
group of State MFCUs and are 
implement a new case management system; (3) conduct and document 
facilitated by the National 
supervisory reviews of case files in accordance with Unit policy; and  
Association of Medicaid Fraud 
(4) ensure that all convictions and adverse actions are reported to Federal 
Control Units. 
partners within the appropriate timeframes.  The Unit concurred with all 
four recommendations.   
   
TABLE OF CONTENTS 
 
 
BACKGROUND ................................................................................................................................................ 1 
Methodology ............................................................................................................................................................................. 5 
PERFORMANCE ASSESSMENT ................................................................................................................... 7 
Case Outcomes ......................................................................................................................................................................... 7 
Observation: The Unit reported 30 indictments, 9 convictions, and 49 civil settlements and 
judgments for FYs 20192021. 
Observation: The Unit reported combined civil and criminal recoveries of nearly $46 million 
for FYs 20192021. 
Performance Standard 1: Compliance with Requirements ...................................................................................... 8 
Observation: From the information we reviewed, the Connecticut MFCU generally complied 
with applicable laws, regulations, and policy transmittals. 
Performance Standard 2: Staffing ..................................................................................................................................... 8 
Observation: The Units staff levels were low in relation to State Medicaid expenditures. 
Performance Standard 3: Policies and Procedures ..................................................................................................... 9 
Observation: The Unit maintained policies and procedures, and staff were familiar with 
them. 
Performance Standard 4: Maintaining Adequate Referrals ..................................................................................... 9 
Finding: During our review period, the Unit did not receive referrals of patient abuse or 
neglect and was unable to take sufficient steps to ensure that it received such referrals. 
Performance Standard 5: Maintaining Continuous Case Flow ............................................................................. 11 
Observation: The Unit took steps to maintain a continuous case flow and to complete cases 
within appropriate timeframes. 
Performance Standard 6: Case Mix ................................................................................................................................. 11 
Observation: Despite the lack of patient abuse and neglect cases, the Units mix of cases 
covered 25 provider types. 
Performance Standard 7: Maintaining Case Information ....................................................................................... 12 
Finding: The Unit lacked a central repository for case information, making access to case 
data and pertinent case documents inefficient. 
Finding: The Unit did not adhere to its policy of documenting supervisory reviews monthly. 
 
   
Performance Standard 8: Cooperation with Federal Authorities on Fraud Cases ......................................... 14 
Observation: The Unit maintained a good working relationship with Federal agencies, 
including OI and the U.S. Attorneys Office. 
Finding: The Unit did not consistently report convictions or adverse actions to Federal 
partners within the appropriate timeframes. 
Performance Standard 9: Program Recommendations .......................................................................................... 16 
Observation: The Unit made programmatic recommendations to the State Medicaid agency 
during our review period. 
Performance Standard 10: Agreement with Medicaid Agency ............................................................................ 16 
Observation: The Unit had a four-way MOU with the State Medicaid agency, OI, and the 
State Attorney Generals Office, which created open communication and transparency 
among the four agencies. 
Performance Standard 11: Fiscal Control ..................................................................................................................... 17 
Observation: From our limited review, we identified no significant deficiencies in the Units 
fiscal control of its resources. 
Performance Standard 12: Training ................................................................................................................................ 17 
Observation: The Unit maintained a training plan for each professional discipline. 
CONCLUSION AND RECOMMENDATIONS ........................................................................................... 18 
Develop and implement outreach efforts to ensure that the Unit regularly receives referrals of patient 
abuse and neglect ................................................................................................................................................................. 18 
Seek approval from the Office of the Chief States Attorney to implement a new case management 
system  ....................................................................................................................................................................................... 19 
Conduct and document supervisory reviews of case files in accordance with Unit policy ....................... 19 
Ensure that all convictions and adverse actions are reported to Federal partners within the 
appropriate timeframes ...................................................................................................................................................... 19 
UNIT COMMENTS AND OIG RESPONSE ............................................................................................... 20 
DETAILED METHODOLOGY ....................................................................................................................... 21 
APPENDICES................................................................................................................................................. 24 
Appendix A: Unit Referrals by Source for Fiscal Years 20192021 ..................................................................... 24 
Appendix B: Point Estimates and 95-Percent Confidence Intervals of Case File Reviews .......................... 25 
Appendix C: Unit Comments ............................................................................................................................................. 26 
ACKNOWLEDGMENTS AND CONTACT ................................................................................................ 29 
ABOUT THE OFFICE OF INSPECTOR GENERAL .................................................................................... 30 
   
BACKGROUND 
OBJECTIVE 
To examine the performance and operations of the Connecticut Medicaid Fraud 
Control Unit (MFCU or Unit). 
 
Medicaid Fraud Control Units 
MFCUs investigate (1) Medicaid provider fraud and (2) patient abuse or neglect in 
facility settings and prosecute those cases under State law or refer them to other 
prosecuting offices.1, 2, 3  Under the Social Security Act (SSA), a MFCU must be a 
single, identifiable entity of State government, separate and distinct from the State 
Medicaid agency, and employ one or more investigators, attorneys, and auditors.4  
Each State must operate a MFCU or receive a waiver.5  Currently, 50 States, the District 
of Columbia, Puerto Rico, and the U.S. Virgin Islands operate MFCUs.6  
MFCUs are funded jointly by 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.7  In Federal fiscal year (FY) 2021, combined Federal and 
State expenditures for the MFCUs totaled approximately $314 million, of which 
approximately $235.5 million represented Federal funds.8   
 
 
_____________________________________________________________________________________________________________________________ 
1 SSA  1903(q)(3).  Regulations at 42 CFR  1007.11(b)(1) clarify that a Units responsibilities include the 
review of complaints of misappropriation of patients private funds in health care facilities. 
2 As of December 27, 2020, MFCUs may also receive Federal financial participation to investigate and 
prosecute abuse or neglect of Medicaid beneficiaries in a noninstitutional or other setting.  Consolidated 
Appropriations Act, 2021, Public Law 116-260, Division CC, Section 207. 
3 References to State in this report refer to the States, the District of Columbia, and the U.S. territories. 
4 SSA  1903(q). 
5 SSA  1902(a)(61). 
6 The territories of American Samoa, Guam, and the Northern Mariana Islands have not established Units. 
7 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. 
8 OIG analysis of MFCUs reporting of expenditures for FY 2021.  Unless stated otherwise, all FYs are from 
October 1 through September 30. 
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OIG Grant Administration and Oversight of MFCUs 
The Office of Inspector General (OIG) administers the grant award to each Unit and 
provides oversight of Units.9, 10  As part of its oversight, OIG conducts desk reviews of 
each Unit during the annual recertification process.  OIG also conducts periodic 
inspections and reviews.  Finally, OIG provides ongoing training and technical support 
to the Units. 
In its annual recertification review, OIG examines the Units reapplication materials, 
case statistics, and questionnaire responses from Unit stakeholders.  Through the 
recertification review, OIG assesses a Units performance, as measured by the Units 
adherence to published performance standards;11 the Units compliance with 
applicable laws, regulations, and OIG policy transmittals;12 and the Units case 
outcomes. 
OIG further assesses Unit performance by conducting inspections and reviews on 
selected Units.  These inspections and reviews result in public reports of findings and 
recommendations for improvement.  In these reports, OIG may also provide 
observations regarding Unit operations and practices, including beneficial practices 
that may be useful to share with other Units.  OIG also provides training and technical 
assistance to Units, as appropriate, during inspections and reviews. 
Connecticut MFCU 
The Connecticut Unit is located within the Office of the Chief States Attorney (OCSA) 
in the Division of Criminal Justice in Rocky Hill, a suburb of Hartford.13, 14  At the time 
of our onsite inspection in November 2021, the Unit had 13 staff7 investigators 
(including the chief investigator), 3 attorneys (including the director), 2 auditors,  
   
_____________________________________________________________________________________________________________________________ 
9 As part of grant administration, OIG receives and examines financial information from Units, such as 
budgets and quarterly and final Federal Financial Reports that detail MFCU income and expenditures. 
10 The SSA authorizes the Secretary of Health and Human Services to award grants (SSA  1903(a)(6)) and 
to certify and annually recertify the Units (SSA  1903(q)).  The Secretary delegated these authorities to 
OIG in 1979. 
11 MFCU performance standards are published at 77 Fed. Reg. 32645 (June 1, 2012).  The performance 
standards were developed by OIG in conjunction with the MFCUs and were originally published at 59 
Fed. Reg. 49080 (Sept. 26, 1994). 
12 OIG occasionally issues policy transmittals to provide guidance and instruction to MFCUs.  Policy 
transmittals are located at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/index.asp.  
13 The Unit is one of five State MFCUs that are not part of a State Attorney Generals Office.  The other 
four MFCUs that do not reside in an Office of Attorney General are those of the District of Columbia, 
Illinois, Iowa, and Tennessee.   
14 Connecticut State Division of Criminal Justice, Office of the Chief States Attorney.  Accessed at 
https://portal.ct.gov/DCJ/About-Us/About-Us/Office-of-the-Chief-States-Attorney on March 1, 2022.  
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OEI-06-21-00360   Background | 2    
and 1 support staff.15  During our review period of FYs 20192021, the Unit spent 
approximately $7.5 million (with a State share of approximately $1.9 million).  
Referrals  
During FYs 20192021, the Unit reported receiving referrals of Medicaid provider 
fraud primarily from the State Medicaid agency, known as the Department of Social 
Services (DSS).  The referral process and other aspects of the working relationship are 
memorialized in a memorandum of understanding (MOU) between the MFCU, DSS, 
the State Attorney Generals Office, and OIGs Office of Investigations (OI).  The 
Connecticut Unit is the only MFCU that includes OI as a signatory in an MOU with 
State partners.  This MOU instructs DSS to refer allegations of fraud to the MFCU, the 
State Attorney Generals Office, and OI simultaneously.  The Unit also has an MOU 
with the State Department of Public Health (DPH) that directs DPH to share referrals 
of potential fraud and patient abuse or neglect with the Unit.16, 17  See Appendix A for 
a list of Unit referrals by source for FYs 20192021.  
When the Unit receives a referral, the chief investigator performs an initial review, and 
then assigns it to an auditor and/or investigator for preliminary review of the facts 
alleged in the referral to determine whether the Unit has authority and jurisdiction to 
open a case.  At the end of the review, the chief investigator submits a report with a 
recommendation to the director, who ultimately decides whether the Unit should 
accept or decline the referral.  If the director declines to open a referral for 
investigation, the director or chief investigator evaluates the referral for possible 
administrative action by DSS or another agency.  
Investigations and Prosecutions 
The Connecticut Unit has Statewide jurisdiction to investigate and prosecute all 
criminal Medicaid provider fraud and patient abuse and neglect cases.18, 19  The Unit 
_____________________________________________________________________________________________________________________________ 
15 The Unit had two directors during our review period.  The previous, longstanding director passed away 
in February 2021, and the current director accepted the position in March 2021. 
16 During our review period, the Unit did not report receiving any referrals of patient abuse or neglect.  
For more information about the Units lack of patient abuse and neglect referrals and cases, see 
Performance Standard 4 on page 9. 
17 DPH serves as Connecticuts State agency for protecting the public health and providing health 
information, policy, and advocacy.  DPH houses the Facility Licensing and Investigations Section, which is 
charged with licensing and regulating the States health care institutions.  Connecticut State DPH, 
Welcome to the Facility Licensing and Investigations Section Webpage.  Accessed at 
https://portal.ct.gov/DPH/Facility-Licensing--Investigations/FLIS on March 30, 2022. 
18 Connecticut State Division of Criminal Justice, Medicaid Fraud Control Unit.  Accessed at 
https://portal.ct.gov/DCJ/Programs/Programs/Medicaid-Fraud-Control-Unit on March 1, 2022.  
19 Connecticut General Statutes  51-281. 
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refers all civil matters to the Connecticut Attorney Generals Office, which has 
Statewide authority to investigate and prosecute civil cases.20   
Once the Unit opens a case, it assigns the matter to a team consisting of a Unit 
attorney, an investigator, and an auditor.  The chief investigator meets monthly with 
investigators and auditors assigned to each case to review their investigative files and 
ensure that cases are progressing.  When available, the assigned attorney also attends 
the case reviews.  The Unit also meets monthly with all staff to discuss the 
investigations to ensure that they move forward.  According to its four-way MOU, if 
the Unit determines that a case does not have substantial potential for criminal 
prosecution, the Unit refers the matter to DSS and the State Attorney Generals Office 
for potential administrative and/or civil action.   
Connecticut Medicaid Program 
DSS administers the State Medicaid program and provides care for the approximately 
960,000 beneficiaries enrolled in the program.21  Connecticut operates its Medicaid 
program entirely on a fee-for-service basis.22  DSS houses the State Medicaid 
program integrity unit, which investigates allegations of fraud in the Connecticut 
Medicaid program and, when appropriate, refers credible allegations of fraud to the 
MFCU, the State Attorney Generals Office, and OI.23   
Prior OIG Report 
OIG conducted a previous onsite review of the Connecticut Unit in 2013.24  In that 
review, OIG found that the Unit (1) did not always maintain case files effectively;  
(2) did not follow policies and procedures for case management; (3) did not provide 
OIG with adequate information to initiate exclusion of convicted individuals; (4) did 
not work exclusively on Unit-related matters; (5) did not properly allocate its vehicle 
_____________________________________________________________________________________________________________________________ 
20 The Office of Attorney General William Tong, About the Attorney Generals Office.  Accessed at 
https://portal.ct.gov/AG/About-Us on March 1, 2022.  
21 CMS, State Medicaid and CHIP Applications, Eligibility Determinations, and Enrollment Data, January 
2022.  Accessed at https://data.medicaid.gov/dataset/6165f45b-ca93-5bb5-9d06-
db29c692a360/data?conditions[0][property]=report_date&conditions[0][value]=2021-07-
01&conditions[0][operator]=%3D&conditions[1][property]=preliminary_updated&conditions[1][value]=P
&conditions[1][operator]=%3D on February 15, 2022.  
22 Kaiser Family Foundation, Share of Medicaid Population Covered under Different Delivery Systems, July 
2021.  Accessed at https://www.kff.org/medicaid/state-indicator/share-of-medicaid-population-covered-
under-different-delivery-
systems/?currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22,%22sort%22:%22asc%22
%7D on March 14, 2022.  
23 The Provider Investigations Unit, located within DSSs Office of Quality Assurance, serves as the 
program integrity unit.  DSS, The Office of Quality Assurance.  Accessed at 
https://portal.ct.gov/DSS/Quality-Assurance/The-Office-of-Quality-Assurance on February 28, 2022.  
24 OIG, Connecticut Medicaid Fraud Control Unit: 2013 Onsite Review, OEI-07-13-00540, September 2014.  
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costs; and (6) did not regularly communicate and coordinate with OIG to investigate 
and prosecute health care fraud.   
OIG recommended that the Unit (1) ensure that case files are maintained in an 
effective manner; (2) adhere to Unit policies and procedures for case management;  
(3) refer individuals for exclusion to OIG with the appropriate information for 
exclusion; (4) ensure that Unit professional staff perform only Unit-related duties in 
accordance with performance standards and Federal regulations; (5) properly allocate 
vehicle costs; and (6) regularly communicate and coordinate with OI to investigate 
and prosecute Medicaid provider fraud.   
To address these recommendations, the Unit (1) implemented a new policy to 
standardize its case files; (2) hired additional staff in order to assign cases more 
timely, and revised its policies and procedures for supervisory reviews of case files;  
(3) revised its policy for reporting convictions to OIG; (4) instructed its OCSA financial 
officer to credit the value of non-MFCU time back to the grant; (5) implemented a 
vehicle cost allocation; and (6) began meeting and communicating regularly with OI.25  
On the basis of information received from the Unit, OIG considered the 
recommendations implemented as of August 2015.  As we discuss further below, 
several issues from the prior OIG report continued in this inspection.  
Methodology 
We conducted an onsite inspection of the Connecticut MFCU in November 2021.  Our 
inspection covered the 3-year period of FYs 20192021.  We based the inspection on 
an analysis of data and information from 7 sources as follows: (1) a review of Unit 
documentation; (2) a review of financial documentation; (3) structured interviews with 
key stakeholders; (4) structured interviews with Unit management and selected staff; 
(5) a review of a random sample of 62 case files from the Units 121 nonglobal case 
files that were open at any point during the review period; (6) a review of convictions 
submitted to OIG for program exclusion and adverse actions submitted to the 
National Practitioner Data Bank (NPDB) during the review period; and (7) an onsite 
review of Unit operations.  See the Detailed Methodology on page 21. 
In examining the Units operations and performance, we applied the published MFCU 
performance standards, but we did not assess adherence to every performance 
indicator for every standard.   
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.  
These inspections 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 
_____________________________________________________________________________________________________________________________ 
25 The policies and procedures the Unit developed from its implementation of OIGs recommendations 
were still in place during FYs 20192021.   
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quality controls as are other OIG evaluations, including internal and external peer 
review. 
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PERFORMANCE ASSESSMENT 
In assessing the performance and operations of the Connecticut MFCU, we identified 
the Units case outcomes and assessed whether the Unit complied with legal 
requirements and adhered to the 12 MFCU performance standards.  We made four 
findings regarding the Units adherence to the performance standards and 
compliance with Federal regulations.  We also made several observations regarding 
Unit operations and practices.  
Case Outcomes 
Observation: The Unit reported 30 indictments, 9 convictions, and 49 civil 
settlements and judgments for FYs 20192021.26  
All nine convictions involved Medicaid provider fraud.27 
 
 
 
 
 
 
 
_____________________________________________________________________________________________________________________________ 
26 The State of Connecticut does not obtain indictment by grand jury proceedings.  Typically, the 
Connecticut MFCU obtains an arrest warrant to initiate the legal proceeding.  Upon the submission of an 
application for an arrest warrant by a prosecuting authority, a judicial authority may issue a warrant for 
the arrest of an accused person if the judicial authority determines that the affidavit shows that there is 
probable cause to believe that an offense has been committed and that the accused committed it.  State 
of Connecticut, Connecticut Practice Book, Section 36-1, 2022.  Accessed at 
https://jud.ct.gov/Publications/PracticeBook/PB.pdf on July 8, 2022.  
27 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 attorneys should apply 
professional judgment and discretion in determining what criminal and civil cases to pursue. 
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Observation: The Unit reported combined civil and criminal recoveries of nearly 
$46 million for FYs 20192021. 
 
Source: OIG analysis of Unit statistical data, FYs 20192021.   
Note: Global civil recoveries derive from civil settlements or judgments in global cases, which are cases that involve 
the U.S. Department of Justice and a group of State MFCUs and are facilitated by the National Association of Medicaid 
Fraud Control Units. 
Performance Standard 1: Compliance with Requirements 
A Unit conforms with all applicable statutes, regulations, and policy directives. 
Observation: From the information we reviewed, the Connecticut MFCU 
generally complied with applicable laws, regulations, and policy transmittals. 
From the information reviewed, we found that the Unit was generally in compliance 
with applicable requirements.  However, we identified one area of concern related to 
the Units reporting of convictions and adverse actions to Federal partners, as 
described under Performance Standard 8 below (see page 14).   
Performance Standard 2: Staffing 
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.  
Observation: The Units staff levels were low in relation to State Medicaid 
expenditures. 
The Units staff levels were low in relation to the State Medicaid expenditures during 
our review period.  According to Performance Standard 2(b), the Unit should employ 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 or neglect.  In FY 2021, 
Connecticuts Medicaid expenditures were over $7.3 billion, and at the end of that 
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year, the Unit employed 13 staff.  We observed that the Units staff size was low 
compared to that of other Units; our analysis shows that a Unit with a similar level of 
Medicaid expenditures would, on average, employ 21 staff.28  We also observed that, 
in FY 2021, the Unit had approximately $562.4 million in Medicaid expenditures per 
Unit employee, compared to the national average of $361.5 million in Medicaid 
expenditures per Unit employee across all Units.  Despite the low number of staff, 
Unit management did not express concern about negative impacts on the Units 
ability to investigate or prosecute cases in a timely manner. 
Performance Standard 3: Policies and Procedures 
A Unit establishes written policies and procedures for its operations and ensures 
that staff are familiar with, and adhere to, policies and procedures. 
Observation: The Unit maintained policies and procedures, and staff were 
familiar with them. 
The Unit maintained a policies and procedures manual, which was last updated in 
November 2018.  Unit staff reported that they were familiar with Unit policies and 
procedures and could access the manual electronically on the Units shared drive.   
Performance Standard 4: Maintaining Adequate Referrals 
A Unit takes steps to maintain an adequate volume and quality of referrals from 
the State Medicaid agency and other sources. 
Finding: During our review period, the Unit did not receive referrals of patient 
abuse or neglect and was unable to take sufficient steps to ensure that it 
received such referrals. 
According to Performance Standard 4(d), for States in which Units have original 
jurisdiction to investigate or prosecute patient abuse and neglect cases, the Unit 
should take steps to ensure that pertinent agencies refer such cases to the Unit.  
Despite having independent, or original, jurisdiction to investigate and prosecute 
cases of patient abuse and neglect, the Unit did not receive any such referrals from its 
referral sources during FYs 20192021.29  Consequently, the Unit did not obtain any 
patient abuse or neglect indictments or convictions during our review period.   
Unit management reported that State regulatory agencies, such as DPH, typically 
received patient abuse or neglect complaints.  Despite a longstanding MOU that 
required DPH to refer to the Unit allegations of Medicaid patient abuse or neglect, 
DPH referred no such complaints during our review period.  In interviews with DPH 
officials, they explained that DPH investigated patient abuse or neglect complaints for 
_____________________________________________________________________________________________________________________________ 
28 OIG does not prescribe MFCUs staffing levels.  We assessed the Units staffing levels using a linear 
regression model to compare Medicaid expenditures to actual staff. 
29 Prior to FY 2019, the Unit reported receiving referrals of patient abuse and neglect and opening 
investigations from those referrals.  One of those investigations, which the Unit opened in FY 2018, was 
still open during our review period.   
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administrative action and typically referred criminal allegations to local police 
departments.  As a result, DPH and local police departments, rather than the MFCU, 
conducted most investigations of alleged patient abuse or neglect.   
In addition to preventing the MFCU from identifying appropriate patient abuse and 
neglect referrals for investigation, this existing arrangement may also have an impact 
on the Units ability to submit convicted providers to OIG for exclusion from Federal 
health care programs.  If local law enforcement agencies have convicted providers of 
patient abuse or neglect crimes in connection with a health care item or service, they 
may not know to inform OIG to exclude these providers from Federal health care 
programs.30   
We found that the Unit conducted limited outreach to potential referral sources, 
including DPH, to encourage referrals of patient abuse or neglect during our review 
period.  The Units outreach largely consisted of the following efforts: (1) the Unit 
maintained a website outlining the Units authority to investigate and prosecute fraud 
and patient abuse or neglect; and (2) the Unit included its contact information in 
press releases, requesting the public to report any suspected Medicaid provider fraud 
and patient abuse or neglect to the Unit.  We found that the passing of the former 
Unit director further limited the Units outreach regarding referrals of patient abuse 
and neglect.  Unit management reported that the former Unit director was 
responsible for conducting outreach efforts and facilitating the Units relationships 
with referral agencies, but when he became ill during our review period, it hampered 
the Units outreach.31   
In interviews, both DPH and Unit management recognized that their working 
relationship was limited.  DPH officials reported that they had little contact with the 
Unit during our review period.  The officials expressed interest in receiving training on 
the types of referrals the Unit would like to receive from DPH and the information the 
Unit would need for those referrals.  During our onsite visit, Unit management 
acknowledged that the Unit should be conducting more outreach to encourage 
referrals.  The new Unit director explained that the lack of patient abuse or neglect 
referrals was a concern that she planned to address soon.   
Following our onsite visit in November 2021, the Unit director reported to us that the 
Unit initiated steps to address the absence of patient abuse or neglect referrals.  The 
director reported that to encourage such referrals, Unit managers met with DPH 
officials to discuss the Units responsibility for investigating and prosecuting cases of 
patient abuse and neglect.  The director stated that the two agencies plan to discuss 
the types of patient abuse or neglect referrals that the Unit would like to receive as 
well as procedures for future communication.  The director also stated that DPH will 
conduct training for the Unit investigators about reviewing medical charts for patient 
abuse and neglect referrals.  Additionally, the director informed us that the Units 
_____________________________________________________________________________________________________________________________ 
30 42 USC  1320a-7(a)(2). 
31 The current director assumed the outreach duties after becoming the Unit director in March 2021.  
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outreach has begun to generate patient abuse and neglect referrals as well as 
additional fraud referrals.  
Further, the Unit director expressed interest in hiring additional staff, including a 
nurse investigator, if the Unit is successful in increasing its patient abuse and neglect 
caseload.  A nurse investigator may be helpful in conducting the Units future 
outreach efforts, reviewing patient abuse or neglect referrals, and investigating those 
cases.  As we observe under Performance Standard 2, the Units staff levels were low 
in relation to the State Medicaid expenditures (see page 8), and an increased caseload 
may suggest the need for additional staff.  
Performance Standard 5: Maintaining Continuous Case 
Flow 
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. 
Observation: The Unit took steps to maintain a continuous case flow and to 
complete cases within appropriate timeframes.  
Our review of the Units case files found that most investigations and subsequent 
prosecutions or settlements were completed in a timely manner.  Further, most case 
files contained appropriate documentation of supervisory approval for case openings 
and case closings.  Specifically, we observed that 97 percent of case files contained 
documentation of supervisory approval to open a case, and 85 percent of the Units 
closed cases contained supervisory approval to close a case.  See Appendix B for the 
point estimates and confidence intervals for our case file review.  
Performance Standard 6: Case Mix 
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.  
Observation: Despite the lack of patient abuse and neglect cases, the Units mix 
of cases covered 25 provider types. 
Of the 121 nonglobal cases that were open during our review period, 99 percent  
(120 cases) involved provider fraud and 1 percent (1 case) involved patient abuse and 
neglect.32  The Unit opened its one case of patient abuse and neglect in FY 2018, and 
the case was still open during our review period.33, 34  During FYs 20192021, the 
_____________________________________________________________________________________________________________________________ 
32 We excluded all global cases from our review of the Units case files because global cases are civil false 
claims actions that typically involve multiple agencies, such as the U.S. Department of Justice and a group 
of State MFCUs.   
33 The case of patient abuse and neglect was closed at the time of our inspection.  
34 For more information about the Units lack of patient abuse and neglect referrals and cases, see 
Performance Standard 4 on page 9.  
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OEI-06-21-00360  Performance Assessment | 11    
Units cases covered 25 different provider types, including dentists, personal care 
services attendants, clinical social workers, and pharmaceutical manufacturers. 
Performance Standard 7: Maintaining Case Information 
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. 
Finding: The Unit lacked a central repository for case information, making access 
to case data and pertinent case documents inefficient.   
Performance Standards 7(e) and 7(f) state that the Unit should have a case 
management system that manages and tracks case information from initiation to 
resolution.  This system should also allow for the monitoring and reporting of case 
information.35  Rather than using one consolidated case management system, the 
Unit used several repositories to track case information and other performance data.   
At the time of our onsite inspection, the Unit stored case information in different 
locations, including a legacy case management system, an internal electronic file 
structure, and various spreadsheets.  The Unit used the legacy case management 
system during most of our review period, but because the system was antiquated, the 
chief investigator created an electronic file structure on the Units shared drive where 
investigators stored their case documents.  The chief investigator also kept a separate 
master case list spreadsheet to track case progression and another spreadsheet to 
track monthly supervisory reviews.  
We found that using several repositories to track case information presented 
challenges when attempting to locate documents and track case statuses during our 
case file review.  For example, we found that the legacy system limited the amount of 
information an investigator could add to the case files.  Specifically, the system 
allowed investigators to enter notes about cases but did not allow them to upload 
case documents.  Further, the Units files within the electronic case file structure did 
not maintain consistent naming conventions, track case progression, or identify joint 
cases with partner agencies.  During our onsite visit, OIG provided the Unit with 
technical assistance regarding methods to mitigate the inefficiencies of its self-
created electronic case file structure.   
After our onsite visit, Unit management reported that OCSA officials had adopted a 
new Statewide case management system; however, Unit management assessed the 
new system and reported that it would not meet the Units needs.  Specifically, the 
Unit reported that data within the Statewide case management system would be 
shared among all users in the State and that the system lacked the functionality that 
the Unit needed for investigations.  The Unit director has communicated these 
_____________________________________________________________________________________________________________________________ 
35 The 2014 OIG report found that the Unit did not always maintain case files in an effective manner.  
Specifically, OIG found that some of the Units case files lacked basic organizational structure and 
documentation of case progression.  In response to OIGs recommendation, the Unit implemented a 
policy to standardize its case files. 
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concerns to OCSA officials and reported that she is considering other case 
management systems.  
Finding: The Unit did not adhere to its policy of documenting supervisory 
reviews monthly. 
According to Performance Standard 7(a), reviews by supervisors should be conducted 
periodically, consistent with the Units policies and procedures, and should be noted 
in the case file.  The previous OIG report found that 82 percent of the Units 
applicable cases lacked documentation of quarterly supervisory reviews consistent 
with Unit policy during FYs 20102012.  In response to OIGs recommendation, the 
Unit required the supervisor to submit the supervisory reviews to the director.  In July 
2013, the Unit changed its frequency of supervisory reviews from quarterly to 
monthly.   
We reviewed sampled case files to determine whether they contained documentation 
of monthly supervisory reviews, consistent with the Units policy.  We found that  
88 percent of applicable case files lacked documentation of one or more monthly 
supervisory reviews.  Further, 7 percent of the Units applicable case files did not 
contain documentation of any supervisory reviews at all.  (See Appendix B for the 
point estimates and confidence intervals for the case file reviews.)   
Unit management explained that investigative teams generally discussed their cases 
with the chief investigator during their scheduled team meetings and other informal 
conversations, often more frequently than monthly.  However, the investigative teams 
did not consistently document these conversations in the case files.  We found that 
the Unit inconsistently documented its supervisory reviews because of its technical 
difficulties with remote work due to the COVID-19 pandemic and the inefficiencies of 
its case management system, among other reasons.36    
In OIGs experience, conducting and documenting official case file reviews as 
frequently as monthly may present an unwarranted burden on investigators as well as 
supervisors.  We found that the monthly supervisory reviews required by the Units 
policy may have been more frequent than necessary, which may have contributed to 
the Units difficulty meeting its policy.    
 
 
 
 
_____________________________________________________________________________________________________________________________ 
36 After the onsite visit, the Unit director reported to us that the Units technical difficulties surrounding 
remote work were resolved.  
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Performance Standard 8: Cooperation with Federal 
Authorities on Fraud Cases 
A Unit cooperates with OIG and other Federal agencies in the investigation and 
prosecution of Medicaid and other health care fraud. 
Observation: The Unit maintained a good working relationship with Federal 
agencies, including OI and the U.S. Attorneys Office.   
In its 2014 report, OIG found that the Unit did not regularly communicate and 
coordinate with OI investigators to investigate and prosecute health care fraud.  OIG 
recommended that the Unit improve cooperation with the OI investigators.  Following 
that onsite review, the Unit reported that its relationship with OI improved and that 
the two agencies began to meet regularly.   
We found that during our review period of FYs 20192021, the Unit and OI 
maintained a good working relationship and jointly investigated a total of 21 cases.  
An OI investigative supervisor reported that the Unit and OI have continued to work 
well together and have fostered that relationship over the years.  OI management also 
attributed the good working relationship to OIs four-way MOU with the MFCU, DSS, 
and the State Attorney Generals Office, citing that the arrangement worked as a 
force multiplier and enhanced trust between the agencies.37  Additionally, OI 
management and the Unit chief investigator reported communicating openly and 
regularly with each other.   
Further, we observed a strong working relationship between the MFCU and the U.S. 
Attorneys Office in Connecticut.  We interviewed the Assistant U.S. Attorney who 
serves as the criminal health care fraud coordinator and regularly works joint cases 
with the MFCU.  The Assistant U.S. Attorney attributed the strong working relationship 
to the longstanding work history and open communication between the two agencies 
and stated that the Unit works together seamlessly with the other Federal 
investigative agencies in Connecticut.  
Finding: The Unit did not consistently report convictions or adverse actions to 
Federal partners within the appropriate timeframes.  
According to Federal requirements and Performance Standard 8(f), the Unit should 
generally transmit to OIGwithin 30 days of sentencing, or as soon as practicable if 
the Unit encounters delays in receiving the necessary information from the court
reports of all MFCU convictions for the purpose of permitting OIG to exclude those 
convicted parties from Federal health care programs.38  We found that the Unit either 
reported late or did not report seven of its nine convictions to OIG for exclusion, and 
_____________________________________________________________________________________________________________________________ 
37 For additional information about the benefits of the MOU, see the observation in Performance 
Standard 10 on page 16.  
38 42 CFR  1007.11(g).  
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the Unit did not report court delays to explain the late reporting.39  Of the nine 
convictions, the Unit submitted four convictions late: one was submitted within 31 to 
60 days after sentencing, two were submitted within 61-90 days after sentencing, and 
one was submitted more than 90 days after sentencing.  Late reporting of convictions 
to OIG delays the initiation of the program exclusion process, which may result in 
improper payments to providers by the Medicaid program or other Federal health 
care programs as well as possible harm to beneficiaries.   
Further, the Unit did not submit three of its nine convictions to OIG during our review 
period.40  The Unit explained that these three convictions were joint Federal cases, 
and Unit officials were unaware of the requirement to submit these convictions for 
OIG exclusion.  Although this may appear to be an understandable error, Federal 
requirements make no exception for joint cases.  OIG has also provided guidance that 
Units should report all convictions for OIG exclusion.41   Reporting convictions in joint 
cases reduces the risk of system error and ensures that OIG has a complete and 
accurate record of all convicted parties, including full names and current addresses. 
Federal regulations, consistent with Performance Standard 8(g), also require that the 
Unit report any adverse actions of health care providers to the NPDB within  
30 calendar days of the final adverse action date.42  The Unit did not report 4 of its  
11 adverse actions to the NPDB within the appropriate timeframe.  Of the four 
adverse actions submitted late, two were submitted within 31 to 60 days after the 
action and two were submitted more than 90 days after the action.  The NPDB is 
intended to restrict physicians, dentists, and other health care practitioners from 
moving from State to State without disclosure or discovery of previous medical 
malpractice and adverse actions.43  If a Unit fails to report adverse actions to the 
NPDB, other health care organizations may unknowingly hire individuals who have 
adverse actions made against them.   
Unit management attributed the delayed submissions to OIG and the NPDB to staff 
being out of the office due to long-term illness and working remotely during the 
COVID-19 pandemic. 
_____________________________________________________________________________________________________________________________ 
39 In its 2014 report, OIG found that the MFCU did not provide OIG with adequate information to initiate 
exclusion of convicted individuals.  OIG recommended that the Unit submit appropriate information for 
individuals exclusions to OIG.  Although we did not find this same issue during our 2021 inspection, we 
found that the Unit did not submit all of its convictions to OIG timely.  
40 We observed that OIG has excluded these three convicted providers. 
41 OIG, State Fraud Policy Transmittal No. 2020-1: Plea Negotiations and Reporting Convictions to the 
Office of Inspector General, April 2020.   
42 45 CFR  60.5.  Examples of final adverse actions include, but are not limited to, convictions, civil 
judgments (but not civil settlements), and program exclusions (SSA  1128E(g)(1)). 
43 NPDB, About Us.  Accessed at https://www.npdb.hrsa.gov/topNavigation/aboutUs.jsp on June 30, 2022.  
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Performance Standard 9: Program Recommendations 
A Unit makes statutory or programmatic recommendations, when warranted, to the 
State government. 
Observation: The Unit made programmatic recommendations to the State 
Medicaid agency during our review period. 
The Unit, in collaboration with OI and the State Attorney Generals Office, made 
recommendations to DSS regarding potential program deficiencies identified by the 
agencies during their investigations and prosecutions.  For example, the agencies 
identified programmatic vulnerabilities and made recommendations related to 
behavioral health providers.  Specifically, the Unit recommended that DSS clarify 
billing rules regarding licensed and unlicensed behavioral health providers, in both 
clinical and nonclinical settings, to ensure that DSS appropriately pays for services 
rendered.  The Unit also recommended that DSS establish edits to the States claims 
payment system to limit the number of hours that a behavioral health provider may 
bill in 1 day.  DSS implemented the Units recommendations and made programmatic 
changes as suggested.  
Performance Standard 10: Agreement with Medicaid 
Agency 
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. 
Observation: The Unit had a four-way MOU with the State Medicaid agency, OI, 
and the State Attorney Generals Office, which created open communication and 
transparency among the four agencies.  
During our review period, the MFCU had an MOU with DSS, OI, and the State 
Attorney Generals Office.  This MOU is unique in that the Connecticut Unit is the only 
MFCU that has an MOU with OI.  The four-way MOU reflected current practice, policy, 
and legal requirements and was last updated in January 2019.  The MOU described 
each agencys role in the fraud referral process and provided guidelines for their 
collaboration. 
We found that the unique four-way working relationship had benefits for each 
agency, as it appeared to enhance communication and collaboration among the four 
agencies.  An official in the State Attorney Generals Office stated that the MOU 
created a framework for the agencies strong working relationship.  Unit 
management also observed, as benefits of the MOU, open communication, 
information sharing, and clearly defined investigative roles.  An OI manager expressed 
that the MOUs system of simultaneous referrals to the MFCU, the Attorney General, 
and OI created automatic investigative partners among the three agencies.  The DSS 
program integrity director reported that the MOU arrangement worked well and 
resulted in successful collaboration on fraud referrals among the four agencies.  OIG 
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OEI-06-21-00360  Performance Assessment | 16    
found that the MOU created multiple benefits for the fraud referral process among 
the four agencies, including the ability to discuss the specifics of each referral 
efficiently and to determine which agency should investigate and prosecute the 
referral.   
Performance Standard 11: Fiscal Control 
A Unit exercises proper fiscal control over its resources.  
Observation: From our limited review, we identified no significant deficiencies in 
the Units fiscal control of its resources.   
From the Units responses to a detailed fiscal controls questionnaire and from 
follow-up with fiscal staff and Unit officials, we identified no significant issues related 
to the Units budget process, accounting system, cash management, procurement, 
electronic data security, property, or personnel.  In our inventory review, we located 
30 of the 30 sampled inventory items.  
Performance Standard 12: Training 
A Unit conducts training that aids in the mission of the Unit.  
Observation: The Unit maintained a training plan for each professional 
discipline.  
The Unit had an annual training plan that required Unit attorneys, investigators, and 
auditors to complete an annual minimum number of training hours.  The plan 
required Unit employees to complete an in-house basic training program, as well as 
Medicaid fraud and discipline-specific training.  
 
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CONCLUSION AND RECOMMENDATIONS 
From the information we reviewed, we found that the Connecticut Unit generally 
complied with applicable legal requirements and adhered to performance standards.  
However, we identified four areas in which the Unit should improve its adherence to 
the performance standards and/or program requirements.  We found that the Unit 
did not receive any patient abuse or neglect referrals during FYs 20192021.  As a 
result, the Unit did not have any patient abuse or neglect indictments or convictions 
during our review period.   
In addition, we found that the Unit lacked a central repository for case information, 
which made accessing case data and pertinent documents inefficient.  Further, we 
found that the Unit documented periodic supervisory reviews in most of its case files 
but did not adhere to its policy of documenting these reviews monthly.  Finally, we 
found that the Unit did not report all of its convictions and adverse actions to Federal 
partners within the appropriate timeframes.   
To address the findings in this report, we make four recommendations to the 
Connecticut MFCU. 
We recommend that the Connecticut Unit: 
Develop and implement outreach efforts to ensure that the Unit 
regularly receives referrals of patient abuse and neglect  
The Unit should develop and implement a written plan to ensure that pertinent 
agencies refer suspected abuse and neglect cases to the Unit.  The plan should 
include steps for conducting outreach efforts and educating referral sources, such as 
State regulatory agencies and local law enforcement agencies.  If hired, the nurse 
investigator could contribute to this outreach.  In developing the plan, the Unit could 
consider educating referral sources regarding the expanded MFCU authority to 
investigate and prosecute abuse or neglect of Medicaid beneficiaries in 
noninstitutional or other settings.  Once the plan is established, the Unit should 
continue outreach with these referral sources to ensure that any referrals the Unit 
receives are of good quality and within the Units jurisdiction.  If the Unit is successful 
in generating more cases from referrals of patient abuse or neglect, it would likely 
result in an increased workload for Unit staff, and the Unit could consider hiring 
additional staff to better handle the increased number of cases.  
 
 
 
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OEI-06-21-00360  Conclusion and Recommendations | 18    
Seek approval from the Office of the Chief States Attorney to 
implement a new case management system  
The Unit should seek approval from OCSA officials to implement a new, 
comprehensive system that meets the functional needs for Unit investigations.  The 
Unit should also ensure that the new case management system has sufficient capacity 
to contain case documents, case information, and performance data.  For example, 
the system should have the ability to (1) house all documents for each case;  
(2) upload documents and information even when investigators are in the field;  
(3) track case progression; (4) show joint cases with partner agencies and link those 
joint cases; and (5) include the cases supervisory reviews. 
Conduct and document supervisory reviews of case files in 
accordance with Unit policy 
The Unit should conduct and document reviews of case files consistent with Unit 
policy.  The Unit should assess whether its current policy of monthly reviews should 
be revised to a quarterly or other less frequent schedule.   
Ensure that all convictions and adverse actions are reported to 
Federal partners within the appropriate timeframes 
The Unit should ensure that it consistently reports all convictions, including those 
worked jointly with Federal partners, to OIG within 30 days of sentencing, or as soon 
as practicable if the Unit encounters delays in receiving the necessary information 
from the court.  The Unit should also ensure that it reports all adverse actions to the 
NPDB within 30 days of the action.  The Unit could provide training to staff on 
reporting convictions and adverse actions to Federal partners and could implement 
automated reminders to alert staff about when to report the convictions and adverse 
actions.  
Connecticut Medicaid Fraud Control Unit: 2021 Inspection  
OEI-06-21-00360  Conclusion and Recommendations | 19    
UNIT COMMENTS AND OIG RESPONSE 
The Connecticut MFCU concurred with all four of our recommendations.  
First, the Unit concurred with our recommendation to develop and implement 
outreach efforts to ensure that the Unit regularly receives referrals of patient abuse 
and neglect.  The Unit reported that since our review, it has established minimum 
criteria for referrals and protocols to improve the referral process.  The Unit also 
reported strengthening its relationships with stakeholders, such as the Department of 
Public Health, the Department of Developmental Services, the State Long-Term Care 
Ombudsman, the States Agency on Aging, and the State Medicaid Agency.  
Additionally, the Unit reported that it is working on a request to its management to 
acquire a new nurse investigator position to assist with Unit investigations and 
conduct outreach and education regarding patient abuse and neglect.  
Second, the Unit concurred with our recommendation to seek approval from the 
Office of the Chief States Attorney (OCSA) to implement a new case management 
system.  The Unit reported that it has notified OCSA of the need for a case 
management system to meet its case tracking needs.  A new system would need to 
include, among other capabilities, the ability to house all documents for each case, 
upload documents and information while investigators are in the field, and track case 
progression.   
Third, the Unit concurred with our recommendation to conduct and document 
supervisory reviews of case files in accordance with Unit policy.  The Unit reported 
that technical difficulties during the COVID-19 pandemic inhibited the Unit from 
recording supervisory reviews in a timely manner but that those issues have been 
resolved.  The Unit also reported that it has revised its policy regarding the frequency 
of supervisory reviews from a monthly to a quarterly schedule.  
Fourth, the Unit concurred with our recommendation to ensure that all convictions 
and adverse actions are reported to Federal partners within the appropriate 
timeframes.  The Unit stated that it has revised its reporting procedures and explained 
that the responsibility is now shared among the attorneys and auditors to encourage 
timely submissions of convictions and adverse actions.   
For the full text of the Units comments, see Appendix C.  
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OEI-06-21-00360                                                                                                                  Unit Comments and OIG Response | 20    
DETAILED METHODOLOGY 
Data Collection and Analysis 
We collected and analyzed data from seven sources as described below to identify 
any opportunities for improvement and instances in which the Unit did not adhere to 
the MFCU performance standards or was not operating in accordance with laws, 
regulations, or policy transmittals.  We also used the data sources to make 
observations about the Units case outcomes as well as the Units operations and 
practices concerning the performance standards.  
Review of Unit Documentation 
Prior to the onsite inspection, we reviewed the recertification analysis for  
FYs 20192021, which involved examining the Units recertification materials, 
including (1) the Units annual reports; (2) the Unit directors recertification 
questionnaires; (3) the Units MOU with DSS, OI, and the State Attorney Generals 
Office; (4) the DSS program integrity directors questionnaires; and (5) the OI Special 
Agent in Charge questionnaires.  We also reviewed the Units policies and procedures 
manual and the Units self-reported case outcomes and referrals included in its annual 
statistical reports for FYs 20192021.  Additionally, we examined the 
recommendations from the 2014 OIG onsite review report and the Units 
implementation of the recommendations.  
Review of Unit Financial Documentation 
We conducted a limited review of the Units control over its fiscal resources.  Prior to 
the onsite inspection, we analyzed the Units responses to a questionnaire about 
internal controls and conducted a review of the Units quarterly financial reports.  We 
followed up with OCSA officials and the Unit to clarify any issues identified in the 
questionnaire about internal controls.  We also reviewed the Units fixed asset 
inventory by purposively selecting 30 of the Units 75 fixed assets and verifying those 
items onsite.  
Interviews with Key Stakeholders 
In October 2021, we interviewed key stakeholders, including officials in DPH, DSS, OI, 
the U.S. Attorneys Office, and the Connecticut Attorney Generals Office.  We focused 
these interviews on the Units relationship and interaction with the stakeholders as 
well as opportunities for improvement.  We used the information collected from these 
interviews to develop subsequent interview questions for Unit management and staff.  
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Onsite Interviews with Unit Management and Selected Staff 
We conducted structured interviews with the Units management and selected staff in 
November 2021.  We interviewed the director, one other attorney, one auditor, and 
four investigators, including the chief investigator.  In addition, we interviewed the 
supervisor of the Unitthe Deputy Chief States Attorney.  We asked these individuals 
questions related to (1) Unit 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; (4) clarification regarding 
information obtained from other data sources; and (5) the Units training and 
technical assistance needs. 
Onsite Review of Case Files 
To craft a sampling frame, we requested that the Unit provide us with a list of cases 
that were open at any time during FYs 20192021 and include the status of each case; 
whether the case was criminal, nonglobal civil, or global civil; and the dates on which 
the case was opened and closed, if applicable. The total number of cases was 219.  
We excluded all global civil cases from our review of the Units case files because 
global civil cases are civil false claims actions that typically involve multiple agencies, 
such as the U.S. Department of Justice and a group of State MFCUs.  Thus, we 
excluded 98 global civil cases, leaving 121 case files.  We then selected a simple 
random sample of 62 cases from the population of 121 cases.  This sample allowed us 
to make estimates of the overall percentage of case files with various characteristics 
with an absolute precision of no more than +/- 10 percent at the 95-percent 
confidence level.  We reviewed the 62 case files for adherence to the relevant 
performance standards and compliance with statutes, regulations, and policy 
transmittals.  During the onsite review of the sampled case files, we consulted MFCU 
staff to address any apparent issues with individual case files, such as missing 
documentation. 
Review of Unit Submissions to OIG and the NPDB 
We also reviewed all 9 of the Units convictions that should have been submitted to 
OIG for program exclusion during our review period, and all 11 of the Units adverse 
actions that should have been submitted to the NPDB during our review period.  We 
reviewed whether the Unit submitted information on all sentenced individuals and 
entities to OIG for program exclusion and all adverse actions to the NPDB for  
FYs 20192021.  We also assessed the timeliness of the submissions to OIG and the 
NPDB.  
 
 
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Onsite Review of Unit Operations 
During the onsite inspection, we observed the Units workspace and operations of the 
Units office in Rocky Hill.  We observed the Units offices and meeting spaces; 
security of data and case files; location of select equipment; and the general 
functioning of the Unit.  
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OEI-06-21-00360  Detailed Methodology | 23    
APPENDICES 
Appendix A: Unit Referrals by Source for Fiscal Years 20192021 
 
FY 2019  FY 2020  FY 2021  3-Year Total 
Abuse &  Abuse &  Abuse &  Abuse & 
Referral Source  Fraud  Fraud  Fraud  Fraud  Total 
Neglect  Neglect  Neglect  Neglect 
Adult Protective 
0  0  0  0  0  0  0  0  0 
Services 
Anonymous  0  0  0  0  0  0  0  0  0 
HHS-OIG  0  0  0  0  0  0  0  0  0 
Law Enforcement 
0  0  0  0  0  0  0  0  0 
(other) 
Licensing Board  0  0  1  0  0  0  1  0  1 
Local Prosecutor  0  0  0  0  0  0  0  0  0 
Long-Term Care 
0  0  0  0  0  0  0  0  0 
Ombudsman 
Medicaid Agency 
25  0  22  0  21  0  68  0  68 
(PI/SURS) 
Medicaid Agency 
18  0  35  0  22  0  75  0  75 
(other)  
Private Citizen  3  0  0  0  1  0  4  0  4 
Private Health Insurer  0  0  0  0  0  0  0  0  0 
Provider  0  0  0  0  0  0  0  0  0 
Provider Association  0  0  0  0  0  0  0  0  0 
State Survey and 
0  0  0  0  0  0  0  0  0 
Certification Agency 
State Agency (other)  0  0  0  0  0  0  0  0  0 
Sub-Total  46  0  58  0  44  0  148  0  148 
Total  46  58  44  148 
Source: OIG analysis of Unit Annual Statistical Reports, FYs 20192021.
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OEI-06-21-00360  Appendix A | 24    
Appendix B: Point Estimates and 95-Percent Confidence Intervals of 
Case File Reviews 
95-Percent 
     
Confidence Interval 
Estimate Description  Sample Size  Point Estimate  Lower  Upper 
Percentage of All Cases That Had Supervisory Approval 
62  96.77%  90.91%  98.35% 
To Open 
Percentage of All Cases Closed at the Time of Our 
62  32.26%  23.97%  42.51% 
Review* 
Percentage of All Closed Cases That Had Supervisory 
20  85.00%  65.31%  93.88% 
Approval To Close* 
Percentage of Eligible Cases That Contained 
Documentation of Supervisory Reviews Consistent with  60  5.00%  1.04%  13.92% 
Unit Policy 
Percentage of Eligible Cases That Contained 
Documentation of Supervisory Reviews But Not  60  88.33%  77.43%  95.18% 
Consistent with Unit Policy*    
Percentage of Eligible Cases That Contained No 
60  6.67%  1.85%  16.20% 
Documentation of Supervisory Review 
Source: OIG analysis of Connecticut MFCU case files, 2021. 
*The 95-percent confidence intervals for these estimates exceed 10-percent absolute precision. 
 
 
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OEI-06-21-00360  Appendix B | 25    
Appendix C: Unit Comments 
 
 
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OEI-06-21-00360  Appendix C | 26    
 
 
 
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OEI-06-21-00360  Appendix C | 27    
Connecticut Medicaid Fraud Control Unit: 2021 Inspection  
OEI-06-21-00360  Appendix C | 28    
ACKNOWLEDGMENTS AND CONTACT 
Acknowledgments 
Keith Peters of the Medicaid Fraud Policy and Oversight Division served as the team 
leader for this study, and Anna Brown served as the lead analyst.  Others in the Office 
of Evaluation and Inspections who conducted the study include Jordan Clementi and 
Kristen Calille.  Office of Evaluation and Inspections headquarters staff who provided 
support include Robert Gibbons and Sarah Swisher.  
We would also like to acknowledge contributions of two special agents from the 
Office of Investigations, and a peer reviewer from another State MFCU. 
This report was prepared under the direction of Ruth Ann Dorrill, Regional Inspector 
General for Evaluation and Inspections in the Dallas Regional Office, and Petra Nealy, 
Deputy Regional Inspector General, as well as 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 
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ABOUT THE OFFICE OF INSPECTOR GENERAL 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 
95-452, as amended, is to protect the integrity of the Department of Health and 
Human Services (HHS) programs, as well as the health and welfare of beneficiaries 
served by those programs.  This statutory mission is carried out through a nationwide 
network of audits, investigations, and inspections conducted by the following 
operating components: 
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 
beneficiaries.  With investigators working in all 50 States and the District of Columbia, 
OI utilizes its resources by actively coordinating with the Department of Justice and 
other Federal, State, and local law enforcement authorities.  The investigative efforts 
of OI often lead to criminal convictions, administrative sanctions, and/or civil 
monetary penalties. 
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. 
Connecticut Medicaid Fraud Control Unit: 2021 Inspection  
OEI-06-21-00360  About the Office of Inspector General | 30