Department of Health and Human Services 
OFFICE OF 
 
INSPECTOR GENERAL 
 
   
 
 
 
 
 
 
O   S M F
REGON  TATE  EDICAID  RAUD 
 
C U :  
  ONTROL  NIT  
 
2016 O R  
  NSITE  EVIEW
Suzanne Murrin 
Deputy Inspector General for 
Evaluation and Inspections 
 
December 2016 
OEI-09-16-00200 
 
   
   
OREGON STATE MEDICAID FRAUD CONTROL UNIT:  
2016 ONSITE REVIEW 
OEI-09-16-00200 
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 Oregon Unit in May 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; (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 Oregon Unit reported obtaining 92 criminal convictions, 
34 civil judgments and settlements, and combined criminal and civil recoveries of nearly 
$33 million.  We found that the Oregon Unit was generally in compliance with applicable 
laws, regulations, and policy transmittals; however, we identified three areas where the 
Unit should improve its adherence to performance standards and its compliance with 
applicable Federal requirements.  Specifically, the Unit did not fully secure its case files, 
part of the Units memorandum of understanding with two of its State partners was 
inconsistent with the Federal regulation governing Medicaid payment suspensions, and 
the Unit did not report some convictions and adverse actions to Federal partners within 
the appropriate timeframes. 
WHAT WE RECOMMEND 
We recommend that the Oregon Unit: 1) implement procedures for securing case files, 
2) revise its memorandum of understanding with State partners to be consistent with 
Federal regulation, and 3) implement processes to ensure it reports convictions and 
adverse actions to Federal partners within the appropriate timeframes.  The Unit 
concurred with all three recommendations. 
 
   
   
TABLE OF CONTENTS 
Objective ......................................................................................................1 
Background ..................................................................................................1 
Methodology ................................................................................................4 
Findings........................................................................................................5 
For FY 2013 through FY 2015, the Oregon Unit reported  
92 criminal convictions, 34 civil judgments and settlements,  
and recoveries of nearly $33 million ...............................................5 
The Unit did not fully secure its case files .......................................6 
Part of the Units MOU with State partners was inconsistent  
with Federal regulation ....................................................................6 
Although the Unit reported nearly all convictions and adverse 
actions to Federal partners, it did not report some within  
the appropriate timeframes ..............................................................7 
Other Observation ........................................................................................9 
The Unit took steps to increase patient abuse and neglect  
referrals from local agencies ............................................................9 
Conclusion and Recommendations ............................................................10 
Unit Comments and Office of Inspector General Response .......... 11 
Appendixes ................................................................................................12 
A:  2012 Performance Standards ...................................................12 
B:  Oregon MFCU Referrals by Referral Source for FYs 2013 
Through 2015 .................................................................................16 
C:  Investigations Opened and Closed by the Oregon  
MFCU, by Case Type, FYs 2013 through 2015 ............................17 
D:  Detailed Methodology .............................................................18 
E:  Unit Comments.........................................................................21 
Acknowledgments......................................................................................23 
 
   
 
OBJECTIVE 
To conduct an onsite review of the Oregon 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 SSA requires 
each State to operate a MFCU, unless the Secretary of Health and Human 
Services (HHS) 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) 2015, the 
50 Units collectively reported 1,553 convictions, 795 civil settlements or 
judgments, and approximately $745 million 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 2015, 
Accessed at http://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2015-statistical-chart.htm on August 1, 2016. 
6 All FY references in this report are based on the Federal FY (October 1 through 
September 30). 
7 SSA  1903(q)(2); 42 CFR  1007.5 and 1007.9(a). 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  1 
   
   
  develop a formal agreement, such as a memorandum of 
understanding (MOU), which 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 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 2015, combined Federal and State expenditures for the Units totaled 
$251 million, $188 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 the 
performance standards.  
OIG also performs periodic onsite reviews of the Units, such as this review 
of the Oregon MFCU.  During these onsite reviews, OIG evaluates Units 
                        ____________________________________________________________ 
8 42 CFR  1007.9(d).  
9 SSA  1903(q)(1). 
10 SSA  1903(a)(6)(B). 
11 Ibid. 
12 OIG, MFCU Statistical Data for Fiscal Year 2015.  Accessed at 
http://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2015-statistical-chart.htm on August 1, 2016. 
13 The SSA authorizes the Secretary of HHS to award grants to the Units (SSA  
1903(a)(6)(B)); 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).  
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  2 
   
   
compliance with laws, regulations, and policies, as well as 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 as they support OIGs direct administration of the 
MFCU grant program.  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.  
Oregon MFCU  
The Oregon Units office is located in Portland.  The Unit is an 
autonomous entity within the States Office of the Attorney General.  At 
the time of our review, the Units management was composed of a 
director, a chief investigator, and an assistant attorney in charge.  
The Unit receives most of its referrals from the Oregon Health Authority 
(OHA) and Department of Human Services (DHS).16  The Unit also 
receives referrals from other sources, such as private citizens and law 
enforcement agencies.  Appendix B illustrates the Unit referrals by source 
for FYs 2013 through 2015.  When the Unit receives a referral, an 
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 meets these criteria, the 
investigator drafts a referral memo to the Unit director, who decides 
whether to open a case. 
If the Unit opens a case, Unit management typically assigns an attorney 
and an investigator to the case.  The Oregon Unit has the authority to 
investigate cases of Medicaid fraud and cases of patient abuse or neglect, 
but does not have original authority to prosecute criminal matters.17  The 
authority to prosecute criminals is vested with the county District 
Attorneys located across the State.  However, District Attorneys routinely 
authorize Unit attorneys to prosecute criminal matters in State courts by 
deputizing them as special prosecutors.  Appendix C provides details on 
opened and closed investigations.    
                        ____________________________________________________________ 
16 OHA administers Oregons Medicaid program, among other things, and DHS 
administers long-term care services for seniors and people with disabilities. 
17 For the purposes of this report, the misappropriation or theft of residential health care 
facility patients private funds is included in the category of patient abuse and neglect. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  3 
   
   
Previous Review 
In 2011, OIG issued a report regarding its onsite review of the Oregon 
Unit.  The review found that the Unit adhered to the 12 performance 
standards and complied with all applicable Federal rules and regulations 
that govern the grant.  
METHODOLOGY 
We conducted the onsite review in May 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; (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. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  4 
   
   
FINDINGS 
For FYs 2013 through FY 2015, the Oregon Unit 
reported 92 criminal convictions, 34 civil judgments 
and settlements, and recoveries of nearly $33 million  
For FYs 2013 through 2015, the Unit reported 92 criminal convictions and 
34 civil judgments and settlements.  See Table 1 for yearly convictions 
and civil judgments and settlements.  Of the Units 92 convictions over the 
3-year period, 78 involved provider fraud and 14 involved patient abuse or 
neglect.  Of the Units 34 civil judgments and settlements, 33 were from 
global cases and 1 was from a State-only civil case.18  According to Unit 
management, the Unit prioritizes the investigation of cases that will result 
in a criminal conviction and thus pursues few State-only civil cases.     
Table 1:  Oregon 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  28  25  39  92 
Civil Judgments and Settlements  13  13  8  34 
Source:  OIG review of MFCU self-reported quarterly statistical reports and other data, 2016. 
For the same period, the Unit reported combined criminal and civil 
recoveries of nearly $33 million.  See Table 2 for the Units yearly 
recoveries and expenditures.19  Global cases accounted for $24 million of 
the $33 million in total recoveries.  Of the approximately $8 million in 
recoveries from nonglobal cases, $2 million were from criminal cases and 
$6 million were from a State-only civil case in FY 2013.   
                        ____________________________________________________________ 
18 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.  Global cases accounted for 59 of the Units 265 cases over the 
3-year period. 
19 Figures in this paragraph and Table 2 are rounded. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  5 
   
   
Table 2:  Oregon MFCU Reported Recoveries and Total Expenditures, by 
Year, FYs 2013 through 2015 
Recovery Types  FY 2013  FY 2014  FY 2015  3-Year Total 
Global Civil Recoveries  $7,762,716   $16,315,640   $408,520   $24,486,876  
Nonglobal Civil Recoveries  $6,493,889   $0   $0   $6,493,889  
Criminal Recoveries  $697,088   $737,499   $188,867   $1,623,454  
Total Civil and Criminal 
$14,953,693   $17,053,139   $597,387   $32,604,219  
Recoveries 
Total Expenditures  $1,806,515   $2,067,044   $2,219,588   $6,093,146  
    
Source:  OIG review of MFCU self-reported quarterly statistical reports and other data, 2016. 
The Unit did not fully secure its case files  
During the onsite review, OIG observed that the Units paper case files 
were not secured from access by non-Unit staff.  Federal regulation 
requires Units to safeguard the privacy rights of all individuals and 
provide safeguards to prevent the misuse of information under the Units 
  
control.20 This includes safeguarding potentially sensitive personally 
identifiable information about witnesses, victims, suspects, and 
informants.  However, during our onsite review we observed that the Unit 
stored case files for closed cases in cabinets without locks, located in 
general office space.  Although individuals must use a coded access card 
to enter the Units general office space, non-Unit staff (including 
janitorial, information technology, and other Office of Attorney General 
staff) could access the space without supervision during non-business 
hours.  Additionally, the Unit did not have policies or procedures for 
securing paper case files from unauthorized access.     
Part of the Units MOU with State partners was 
inconsistent with Federal regulation 
In its MOU with OHA and DHS, the Unit requested that in all cases in 
which a credible allegation of fraud is referred to the Unit, the Medicaid 
agency find good cause not to impose a payment suspension.21  However, 
such a blanket request pertaining to all referrals is inconsistent with the 
                        ____________________________________________________________ 
20 42 CFR  1007.11(f). 
21 In the MOU, the Unit agreed to immediately notify DHS if a payment suspension 
would no longer compromise an investigation. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  6 
   
   
Federal regulation governing Medicaid payment suspensions.22, 23  Federal 
law requires that a Medicaid agency suspend payments to a provider when 
there is a credible allegation of fraud against the provider, unless the 
Medicaid agency determines that good cause exists not to suspend 
payments.24  Regulation stipulates that one type of good cause not to 
suspend payments is when law enforcement officials (e.g., MFCU 
officials) specifically request that a payment suspension not be imposed 
because the suspension may compromise or jeopardize an 
investigation.25  The Centers for Medicare & Medicaid Services (CMS) 
clarified this part of the regulation in 2014, specifying that a blanket 
request to not suspend payments based on a credible allegation of fraud, 
applying to all referrals, is not acceptable and that [e]ach case must be 
evaluated on its own merits to determine the appropriate course of 
action.26  Unit management reported that they were aware that the MOU 
needed to be revised to remove the blanket request and stated that they 
planned to make revisions in 2017.  Management also noted that although 
the Unit had not updated the MOU to reflect the change, in January 
2015 the Unit began making case-by-case determinations on whether to 
request that the Medicaid agency not impose payment suspensions for 
each referral. 
Although the Unit reported nearly all convictions and 
adverse actions to Federal partners, it did not report 
some within the appropriate timeframes 
Although the Unit reported nearly all convictions to OIG and all adverse 
actions to the National Practitioner Data Bank (NPDB), it did not report 
some within the appropriate timeframes.  Performance Standard 8(f) states 
that Units should transmit to OIG reports of all convictions for the purpose 
of exclusion from Federal health care programs within 30 days of 
sentencing.  Additionally, Federal regulations require that Units report any 
                        ____________________________________________________________ 
22 42 CFR  455.23(e)(1). 
23 Performance Standard 10(b) requires that the MOU meet current Federal legal 
requirements, including...42 CFR  455.23, Suspension of payments in cases of fraud. 
24 P.L. No. 111-148,  6402(h) codified at Social Security Act (SSA)  1903(i)(2)(C).  
42 CFR  455.23.   
25 42 CFR  455.23(e)(1). 
26 CMS, Medicaid Payment Suspension Toolkit.  Accessed at 
http://www.cms.gov/Medicare-Medicaid-Coordination/Fraud-
Prevention/FraudAbuseforProfs/Downloads/medicaid-paymentsuspension-toolkit-
0914.pdf on June 17, 2016. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  7 
   
   
adverse actions resulting from prosecutions of healthcare providers to the 
NPDB within 30 calendar days from the date of the adverse action.27, 28 
Although the Unit had procedures in place for reporting convictions to 
OIG, it did not report two convictions to OIG as required.  Unit 
management reported that one conviction inadvertently was not submitted 
and that the other was not submitted because Unit management mistakenly 
believed that they were not required to report convictions involving 
non-healthcare offenses.  Further, the Unit reported more than half of its 
convictions (54 of 92) more than 30 days after sentencing.  Specifically, 
the Unit reported 14 convictions more than 90 days after sentencing, 12 
within 61 to 90 days after sentencing, and 28 within 31 to 60 days after 
sentencing.  Late reporting of convictions to OIG could delay the initiation 
of the program exclusion process, resulting in improper payments to 
providers by Medicare or other Federal health care programs, or possible 
harm to beneficiaries.  Following the onsite review, the Unit sent 
information to OIG about the convictions that were not previously sent.   
As required, the Unit reported 95 adverse actions to the NPDB.  However, 
it reported 67 of these more than 30 days after the adverse action.  
Specifically, the Unit reported 21 adverse actions more than 90 days after 
the action, 8 within 61 to 90 days after the action, and 38 within 31 to 
60 days after the action.  The NPDB is designed to restrict the ability of 
physicians, dentists, and other health care practitioners to move from State 
to State without disclosure or discovery of previous medical malpractice 
and adverse actions.  As with program exclusions, late reporting of 
adverse actions to the NPDB could result in improper payments or 
beneficiary harm. 
According to the Unit, the main reason for late reporting to Federal 
partners was delays in receiving from courts the final sentencing 
documentation that Units must provide to OIG.  The Unit provided 
documentation demonstrating that Oregon courts issue preliminary, 
hand-written sentencing orders on the date of sentencing and send the final 
sentencing documentation days or weeks later.  The Unit also provided 
                        ____________________________________________________________ 
27 SSA  1128E(g)(1); 45 CFR  60.3.  Examples of adverse actions include criminal 
convictions; civil judgments (but not civil settlements); exclusions; and other negative 
actions or findings. 
28 45 CFR  60.5.  In addition to Federal regulations, the Performance Standards also 
require the Unit to report to NPDB.  Performance Standard 8(g) states that the Unit 
should report qualifying cases to the Healthcare Integrity & Protection Databank 
[HIPDB], the National Practitioner Data Bank, or successor data bases.  We reviewed 
the reporting of adverse actions under NPDB requirements because the HIPDB and the 
NPDB were merged during our review period (FYs 2013 through 2015).  78 Fed. Reg. 
20473 (April 5, 2013). 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  8 
   
   
evidence that they sometimes contacted the court when final 
documentation was particularly late.   
Unit management identified two other issues that contributed to reporting 
delays, particularly for convictions reported more than 90 days after 
sentencing.  For some of these convictions, management stated that 
reporting was delayed because the Unit mistakenly thought that they 
needed to wait until all co-defendants were sentenced.  The Unit also 
provided documentation indicating that an administrative assistant 
responsible for submitting conviction information to Federal partners 
resigned unexpectedly during the review period.  Unit management 
indicated that this contributed to the reporting delays for several 
convictions. 
Other observation:  The Unit took steps to increase 
patient abuse and neglect referrals from local 
agencies
 
In August 2013, the Unit created the Financial Abuse, Abuse and Neglect 
Group (FAANG) to conduct outreach with local agencies on potential 
patient abuse and neglect cases.  FAANGs goals are to (1) increase 
patient abuse and neglect referrals to the Unit, and (2) ensure that patient 
abuse and neglect cases are investigated when local agencies lack the 
resources to pursue them.  FAANG consists of the Units data analyst, 
Unit attorneys, and the assistant attorney in charge.   
During 2014 and early 2015, the group reached out to each county in 
Oregon and designated a Unit attorney as the main contact for the local 
patient abuse and neglect agencies.  Unit management reported that, at the 
time, some county district attorneys were not aware that the Unit could 
investigate and prosecute abuse and neglect cases.  As part of FAANG, 
Unit attorneys periodically attend multi-disciplinary team meetings in their 
assigned counties with local prosecutors, adult protective service agencies, 
and other stakeholders.  Unit attorneys sometimes give presentations about 
the Units mission and legal authorities and answer questions as needed.   
Unit management reported that as a result of FAANG, the quality of 
patient abuse and neglect referrals from local agencies improved 
dramatically.  Unit management also reported that the relationships made 
with these agencies through FAANG had helped the Unit with some of its 
cases, particularly in remote counties.   
 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  9 
   
   
CONCLUSION AND RECOMMENDATIONS 
The Unit was generally in compliance with applicable laws, regulations, 
and policy transmittals; however, we identified three areas where the Unit 
should improve its adherence to performance standards and its compliance 
with applicable Federal requirements.  Specifically, the Unit did not fully 
secure its case files, part of the Units MOU with two of its State partners 
was inconsistent with Federal regulation regarding Medicaid payment 
suspensions, and the Unit did not report all convictions to Federal partners 
as required or within the appropriate timeframes. 
We recommend that the Oregon Unit:   
Implement procedures for securing case files 
After our May 2016 onsite review, the Unit reported that it moved into a 
new building and sent documentation to OIG demonstrating that it began 
storing closed case paper files in a secure room.  Although the paper case 
files are now secure, the Unit should develop and implement procedures to 
ensure that all case files and any associated personally identifiable 
information are secured from unauthorized access in the future.   
Revise its MOU with State partners to be consistent with 
Federal regulation 
When the Unit revises its MOU with OHA and DHS in 2017, it should 
ensure that the MOU is consistent with Federal regulation.  The Unit 
should remove the blanket request for good cause exceptions from the 
MOU and describe the process through which the Unit can request, on a 
case-by-case basis, that the Medicaid agency not impose a payment 
suspension based on a credible allegation of fraud. 
Implement processes to ensure it reports convictions and 
adverse actions to Federal partners within the appropriate 
timeframes  
The Unit should implement processes to ensure it reports convictions to 
OIG within 30 days of sentencing and adverse actions to NPDB within 
30 days of the action.  Such processes could include contacting the various 
courts to explain the Units need to receive copies of sentencing 
documents promptly so that the Unit can make required reports within the 
appropriate timeframes.  The Unit also could implement automated 
reminders that alert Unit staff to report convictions and adverse actions to 
Federal partners. 
 
 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  10 
   
   
UNIT COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
The Oregon Unit concurred with all three of our recommendations. 
Regarding our recommendation to implement procedures to secure its case 
files, the Unit stated that it is in the process of implementing a new case 
file security policy. 
Regarding our recommendation to revise its MOU, the Unit reiterated that 
it plans to revise the MOU with OHA and DHS in 2017.  The Unit stated 
that the revised MOU will include the procedure that the Unit currently 
follows to review each case for possible suspension of payments based on 
a credible allegation of fraud. 
Regarding our recommendation to implement procedures to ensure timely 
reporting to Federal partners, the Unit stated that it will continue to 
communicate with the courts regarding the Units need to receive final 
documentation within 30 days of sentencing.  The Unit also noted that 
Oregon courts are adopting a new online system that the Unit hopes will 
grant more timely access to final documentation. 
The full text of the Units comments is provided in Appendix E. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  11 
   
   
APPENDIX A 
2012 Performance Standards29  
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 13 
                        ____________________________________________________________ 
29 77 Fed. Reg. 32645, June 1, 2012. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  12 
   
   
 
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 14 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  13 
   
   
 
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. 
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). 
Continued on page 15 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  14 
   
   
 
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.  
 
 
 
 
 
 
 
 
 
 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  15 
   
   
APPENDIX B 
Oregon 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  
62  11  89  24  93  25  304 
Other 
Adult Protective 
6  19  23  27  26  15  116 
Services 
Other  14  2  22  7  27  7  79 
Private Citizen  15  9  13  5  12  4  58 
Medicaid Agency  
9  0  9  1  33  5  57 
SUR/S or OMIG 
Law Enforcement  17  2  18  0  9  0  49 
Managed Care 
0  0  15  1  3  3  22 
Organizations 
HHS OIG  6  0  8  1  3  3  19 
Prosecutor  2  3  2  5  2  0  14 
Provider 
1  0  12  1  0  0  14 
Association 
State Agencies  
4  1  2  0  3  0  10 
Other 
Private Health 
0  0  7  1  0  0  8 
Insurer 
Provider  2  1  1  0  0  0  4 
Ombudsman  2  0  0  1  0  0  4 
Licensing Board  0  0  0  1  1  0  2 
   Total  140  48  221  75  212  62  760 
 
   Annual Total  188  296  276 
Source:  OIG analysis of Unit Quarterly and Annual Statistical Reports, 2016. 
1 The category of abuse & neglect referrals includes patient funds referrals. 
2 The referral source MFCU hotline was not a category reported on the FY 2015 Annual Statistical Report. 
3 The referral source Anonymous was not a category reported on the FY 2013 and FY 2014 Quarterly Statistical 
Reports. 
 
 
 
 
 
 
 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  16 
   
   
APPENDIX C 
Investigations Opened and Closed by the Oregon MFCU, by 
Case Type, FYs 2013 through 2015 
 
  Annual    
Case Type  FY 2013  FY 2014  FY 2015  3-Year Total 
Average* 
Opened  53  80  64  197  66 
Patient Abuse and 
3  15  7  25  8 
Neglect 
Provider Fraud  50  65  57  172  57 
Closed  70  44  82  196  65 
Patient Abuse and 
6  5  13  24  8 
Neglect 
Provider Fraud  64  39  69  172  57 
Source:   OIG analysis of Unit Quarterly and Annual Statistical Reports, 2016. 
*Averages in this column are rounded. 
 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  17 
   
   
APPENDIX D 
Detailed Methodology 
Data collected from the seven sources below were used to describe the 
caseload and assess the performance of the Oregon 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, its policy and procedures manuals, and its MOU with OHA 
and DHS.  We requested any additional data or clarification from the Unit 
as necessary. 
Review of Unit Financial Documentation.  We reviewed the Units control 
over its fiscal resources 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 three purposive samples to assess the Units internal control 
of fiscal resources.  All three samples were limited to the review period of 
FYs 2013 through FY 2015.  The three samples included the following: 
1.  To assess the Units expenditures, we selected a purposive sample 
of 24 items from the Units 849 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 829 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 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  18 
   
   
reviewed documentation (e.g., time card records) to support the 
time and effort of the MFCU staff during the selected pay periods. 
We also reviewed a purposive sample of the Units supply inventory. 
Specifically, we selected and verified a purposive sample of 48 items from 
the current inventory list of 259 items maintained in the Units office.   
Interviews with Key Stakeholders.  In April and May 2016, we interviewed 
ten individual stakeholders from six agencies who were familiar with 
MFCU operations.  Specifically, we interviewed two program integrity 
managers from OHA; two Assistant U.S. Attorneys; the Civil 
Enforcement Division Administrator for the Oregon Department of 
Justice;30 two managers from the Office of Adult Abuse Prevention and 
Investigations; a policy analyst from the Oregon Department of Human 
Services; and two OIG Special Agents based in Oregon.  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 April 2016, we conducted an online survey of all 13 
nonmanagerial staff within each professional discipline (i.e., investigators, investigative 
auditors, and attorneys) as well as support staff.  We received responses from 12 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.  We conducted structured 
interviews with the MFCUs director, chief investigator, and assistant 
attorney in charge in May 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 2013-2015.  We 
requested data on the 265 open cases that included, but was not limited to, 
the current status of the case; whether the case was criminal, civil, or 
global; and the date on which the case was opened.  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, we 
exclude those cases from our review of a Units case files.  Therefore, we 
                        ____________________________________________________________ 
30 The division administrator supervises the MFCU director. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  19 
   
   
excluded 59 cases that were categorized as global from the list of cases.  
The remaining number of case files was 206. 
We then selected a simple random sample of 100 cases from the 
population of 206 cases.  We determined that 83 of these 100 sampled 
cases were open longer than 90 days, and 41 were open longer than 1 year.  
We reviewed the 83 sampled case files that were open for at least 90 days 
to determine whether documentation for required supervisory reviews was 
present.  Additionally, we reviewed the 41 of those sampled case files that 
were open for at least a year to determine whether there were investigation 
or prosecution delays of 1 year or more that were not explained in the case 
files.  Because our case file review generated no findings, we do not report 
estimates of the number of case files for these subpopulations, nor do we 
report point estimates and their 95-percent confidence intervals. 
From the initial sample of 100 case files, we selected a further 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 estimate any population or subpopulation 
proportions from this additional sample of 50 case files. 
Onsite Review of Unit Operations.  During our May 2016 onsite visit, we 
reviewed the Units workspace and operations.  Specifically, we visited 
the Unit headquarters in Portland, Oregon.  While onsite, 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. 
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.31 
                        ____________________________________________________________ 
31 All relevant regulations, statutes, and policy transmittals are available online at 
http://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  20 
   
   
APPENDIX E 
           Unit Comments 
 
Continued on page 22
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  21 
   
   
 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  22 
   
   
ACKNOWLEDGMENTS 
This report was prepared under the direction of Blaine Collins, Regional 
Inspector General for Evaluation and Inspections in the San Francisco 
regional office, and Michael Henry, Deputy Regional Inspector General; and 
in consultation with Richard Stern, Director of the Medicaid Fraud Policy 
and Oversight Division. 
Rosemary Rawlins, of the San Francisco regional office, served as the 
project leader for the study.  Other Office of Evaluation and Inspections staff 
who conducted the review include Matt DeFraga and Linda Min.  Other 
Medicaid Fraud Policy and Oversight Division staff who participated in the 
review include Frantzy Clement.  Office of Investigations staff also 
participated in the review.  Other central office staff who contributed to this 
review include Kevin Farber, Lonie Kim, and Joanne Legomsky. 
 
 
Oregon State Medicaid Fraud Control Unit:  2016 Onsite Review (OEI-09-16-00200)  23 
   
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.