Department of Health and Human Services 
OFFICE OF 
   
INSPECTOR GENERAL 
 
 
 
 
 
 
PROGRA M INTEGRITY PROBLEMS 
 
W N E
ITH  EWLY  NROLLED 
 
 
M E
EDICARE  QUIPMENT 
 
  S  
UPPLIERS
 
 
 
 
 
 
Daniel R. Levinson  
Inspector General 
 
December 2011 
OEI-06-09-00230   
   
 E X E C U T I V E   S U M M A R Y  
OBJECTIVES 
1.  To determine the extent to which newly enrolled suppliers of 
durable medical equipment, prosthetics, orthotics, and supplies 
(DMEPOS) had their billing privileges revoked or were placed 
on prepayment claims review.  
2.  To determine the extent to which newly enrolled suppliers 
omitted from their Medicare applications required information 
regarding (a) owners or managers or (b) the criminal histories of 
owners or managers or any adverse legal actions taken against 
these individuals. 
BACKGROUND 
Historically, DMEPOS suppliers have presented significant program 
integrity problems for the Medicare program.  In 2010, the Patient 
Protection and Affordable Care Act (ACA) strengthened the 
enrollment-screening process for all Medicare, Medicaid, and Childrens 
Health Insurance Plan providers, including DMEPOS suppliers.  The 
Centers for Medicare & Medicaid Services (CMS) contractor responsible 
for enrollment of new DMEPOS suppliers is the National Supplier 
Clearinghouse Medicare Administrative Contractor (NSC).  At the time 
of our review and prior to ACA enactment, NSC assessed the fraud and 
abuse risk of new supplier applicants and assigned each a risk rating 
(from low to high), the Fraud and Abuse Indicator of Risk (FAIR).  NSC 
uses the FAIR rating to determine the frequency of unannounced site 
visits for new enrollees.  In February 2011, CMS staff stated that they 
were developing policies and procedures to transition NSCs FAIR 
rating system and corresponding monitoring practices to the specific 
policies and practices required by the ACA.   
This report uses the results of contractors oversight activities as 
indicators of program integrity problems among DMEPOS suppliers 
during their first year in Medicare.  Our nationally representative 
sample of 229 DMEPOS suppliers enrolled in Medicare during October
December 2008 includes suppliers representing all FAIR ratings.  We 
examined data from Medicare contractors to identify suppliers that had 
their Medicare billing privileges revoked by CMS or that CMS placed on 
prepayment claims review.  We also used a proprietary database of 
public records to identify suppliers that omitted required information 
from their enrollment applications. 
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E X E C U T I V E   S U M M A R Y  
FINDINGS 
During their first year in Medicare, 26 percent of high- and  
medium-risk suppliers and 2 percent of low/limited-risk suppliers 
had their billing privileges revoked or were placed on prepayment 
claims review.   
CMS revoked the Medicare billing privileges of 21 percent of high- and 
medium-risk suppliers in their first year of enrollment.  Although NSC 
conducted postenrollment site visits within the timeframes required by 
CMS, several suppliers in our sample had already received significant 
Medicare payments before the first site visit.  For example, one supplier 
in our sample received almost $800,000 from Medicare prior to NSCs 
first postenrollment site visit.  CMS placed 9 percent of high- and 
medium-risk suppliers on prepayment claims review for reasons such as 
billing for services not ordered by a physician or not rendered, having 
unusual billing patterns, and failing to respond to CMS or contractor 
requests for information.  CMS revoked the Medicare billing privileges 
of 2 percent of low/limited-risk suppliers.  CMS did not place any of the 
sampled low/limited-risk suppliers on prepayment claims review. 
Thirteen percent of high- and medium-risk suppliers and 4 percent 
of low/limited-risk suppliers omitted ownership or management 
information from their Medicare enrollment applications.  Our review 
of public records revealed that these suppliers did not disclose the name 
of at least one owner or manager.  Further, 11 of the 20 sampled 
suppliers that omitted ownership or management information remained 
in Medicare through December 2010.  This suggests that information 
omitted from enrollment applications can remain undetected for more 
than a year despite NSCs application reviews and postenrollment site 
visits.   
Four percent of high- and medium-risk suppliers omitted 
information regarding criminal histories or adverse legal actions 
from their applications.  In their applications, a small number of high- 
and medium-risk suppliers did not report information regarding criminal 
histories of their owners or managers and any adverse legal actions taken 
against these individuals.  Examples of omissions include convictions for 
insurance fraud, theft by deception, and felony aggravated battery.     
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EE XX EE CC UU TT II VV EE    SS UU MM MM AA RR YY   
RECOMMENDATIONS 
Although ACA provisions strengthen the enrollment screening of 
DMEPOS supplier applicants and CMSs oversight authorities, our 
review demonstrates that further scrutiny of the riskiest applicants is 
needed to prevent dishonest individuals from receiving Medicare 
payment.  We recommend that CMS: 
Conduct postenrollment site visits earlier for new DMEPOS suppliers 
receiving the most money from Medicare.  Although NSC conducted the 
correct number of site visits of high- and medium-risk suppliers as 
required by CMS, Medicare had already made significant payments to 
some suppliers in our sample before they received their first 
postenrollment site visits from NSC.  CMS could use the FAIR rating to 
prioritize certain newly enrolled suppliers and require NSC to conduct 
postenrollment site visits earlier, possibly within a month, for newly 
enrolled high- and medium-risk suppliers that submit large dollar 
amounts of claims. 
Apply investigative techniques and tools to identify any owners or 
managers of DMEPOS suppliers who are not reported on supplier 
applications as required.  Our findings demonstrate that omissions of 
the names of owners or managers can allow a supplier to gain billing 
privileges when it might otherwise be denied Medicare participation.  Such 
omissions could circumvent ACA-required fingerprint-based criminal 
background checks because CMS would not be running checks on omitted 
individuals.  CMS should improve processes to detect information that 
suppliers may have deliberately omitted.  CMS should focus such 
investigative activities on suppliers deemed high- or medium-risk by an  
in-depth assessment, such as the FAIR rating.  
Take appropriate action regarding DMEPOS suppliers that omit 
information from applications.  We will forward to CMS the names of 
those suppliers that we identified as having either omitted the names of 
owners or managers or omitted information regarding the criminal 
histories of owners or managers and any adverse legal actions taken 
against these individuals.  CMS can then determine whether the 
omissions were intentional and whether further action is needed.  
Additionally, in the future, when CMS determines that suppliers have 
inappropriately omitted required information from their Medicare 
enrollment applications, CMS should refer these individuals and 
suppliers to OIG for (if warranted) permissive exclusion.  
 
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E X E C U T I V E   S U M M A R Y  
AGENCY COMMENTS  
In its comments on the draft report, CMS concurred with our 
recommendations and stated that it is using authorities granted under 
the ACA to address potential vulnerabilities.  CMS stated that it will 
instruct NSC to conduct earlier site visits of newly enrolled suppliers, 
have its new DMEPOS supplier-screening contractor alert NSC and 
MACs when it identifies individuals affiliated with companies but not 
reported on enrollment documents, take appropriate action regarding 
individuals identified by OIG, and continue to refer to law enforcement 
suppliers that omitted required enrollment information. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 T A B L E   O F   C O N T E N T S  
 
EX ECUT I VE  SUM M ARY  .....................................i 
 
 
 
I NT RO DU CT I O N  ............................................ 1 
   
 
 
F I NDI NG S  .................................................  11 
 
During their first year in Medicare, 26 percent of high- and  
medium-risk suppliers and 2 percent of low/limited-risk  
suppliers had their billing privileges revoked or were placed on 
prepayment review .....................................  11 
Thirteen percent of high- and medium-risk suppliers and 4 percent   
of low/limited-risk suppliers omitted ownership or management 
information from their Medicare enrollment applications.......  12 
Four percent of high- and medium-risk suppliers omitted         
information regarding criminal histories or adverse legal actions   
from their applications ..................................  13 
 
 
RECO M M END AT I O N S  .....................................  15 
  Agency Comments and Office of Inspector General Response ....  16 
 
APP EN DI X ES  .............................................  18 
  A:  Estimates and Confidence Intervals .....................  18 
  B:  Agency Comments ...................................  20 
   
ACKNO WL E DG M E N T S .....................................  23 
OEI-06-09-00230    PROGRAM INTEGRITY PROBLEMS WITH NEWLY ENROLLED MEDICARE EQUIPMENT SUPPLIERS       
   
 I N T R O D U C T I O N  
OBJECTIVES 
1.  To determine the extent to which newly enrolled suppliers of 
durable medical equipment, prosthetics, orthotics, and supplies 
(DMEPOS) had their billing privileges revoked or were placed 
on prepayment claims review.  
2.  To determine the extent to which newly enrolled suppliers 
omitted from their Medicare applications required information 
regarding (a) owners or managers or (b) the criminal histories of 
owners or managers and any adverse legal actions taken against 
these individuals. 
BACKGROUND 
DMEPOS are covered under Medicare Part B and include items such as 
oxygen supplies, wheelchairs, prosthetic limbs, and surgical dressings.1  
Medicare covers DMEPOS only when ordered for a beneficiary by a 
physician or, in some cases, a nonphysician practitioner.2  Medicare 
reimbursed $8.8 billion for DMEPOS in 2010.3   
Historically, DMEPOS suppliers have presented significant program 
integrity problems for the Medicare program.  Prior Office of Inspector 
General (OIG) work documented significant problems, including 
fraudulent Medicare billing by suppliers, particularly in specific 
high-risk geographic areas.4  To help protect Medicare from DMEPOS 
fraud and abuse, the Centers for Medicare & Medicaid Services (CMS) 
has over time instituted standards of participation for DMEPOS 
suppliers, processes for screening new supplier applicants, and 
 
1 See Social Security Act  1832(a), 1861(s)(6), and 1861(s)(8).  The complete list of 
covered items can be found online at www.cms.gov.  Accessed on October 7, 2010. 
2 Medicare Program Integrity Manual (PIM), Pub. No. 100-08, ch. 5,  5.2. 
3 The figure cited is for reimbursement amounts for all DMEPOS claims in 2010 and is 
based on OIG analysis of the National Claims History File. 
4 See, for example, Department of Health and Human Services (HHS) OIG, South Florida 
Suppliers Compliance With Medicare Standards:  Results From Unannounced Visits, OEI-
03-07-00150, March 2007; HHS OIG, Los Angeles County Suppliers Compliance With 
Medicare Standards:  Results From Unannounced Visits, OEI-09-07-00550, February 2008; 
HHS OIG, South Florida Medical Equipment Suppliers:  Results of Appeals,                   
OEI-03-07-00540, October 2008; HHS OIG, Power Wheelchairs in the Medicare Program:  
Supplier Acquisition Costs and Services, OEI-04-07-00400, August 2009; HHS OIG, 
Payments to Medicare Suppliers and Home Health Agencies Associated With Currently 
Not Collectible Overpayments, OEI-06-07-0080, November 2008; and HHS OIG, Aberrant 
Claims Patterns for Inhalation Drugs in South Florida, OEI-03-08-00290, April 2009.   
OEI-06-09-00230    PROGRAM INTEGRITY PROBLEMS WITH NEWLY ENROLLED MEDICARE EQUIPMENT SUPPLIERS  1   
   
I N T R O D U C T I O N  
requirements for contractor monitoring of suppliers.  In 2010, the 
Patient Protection and Affordable Care Act (ACA) strengthened the 
enrollment-screening process for all providersincluding DMEPOS 
suppliersparticipating in Medicare, Medicaid, and the Childrens 
Health Insurance Program (CHIP). 
DMEPOS Supplier Standards of Participation 
To participate in Medicare, each DMEPOS supplier must complete an 
enrollment application and demonstrate that it meets the 30 standards 
of participation.5  CMS can deny enrollment to applicants that do not 
meet one or more of the standards.6  CMS can also revoke the billing 
privileges of existing Medicare suppliers that do not continue to meet 
the standards.7  
DMEPOS applicants must also provide complete and accurate 
information in response to questions on enrollment applications.8  
Applicants must discloseamong other informationthe identity of any 
person or business that has an ownership or a controlling interest in the 
business or that functions in a management role.9  For each person or 
business on the application, suppliers must also report any history of 
certain types of criminal convictions and adverse legal actions taken 
against the person or business, such as exclusions from a Federal or 
State health care program, loss of billing privileges, and payment 
suspensions.10   
DMEPOS Supplier Applicant Screening and Risk Assessment 
The CMS contractor responsible for the DMEPOS supplier enrollment 
process is the National Supplier Clearinghouse Medicare 
Administrative Contractor (NSC).  NSCs responsibilities include 
reviewing enrollment applications, conducting unannounced site visits 
to applicants business locations, conducting fraud risk assessments, 
and issuing Medicare billing numbers to applicants that meet program 
participation standards. 
 
5 42 CFR  424.57 and 42 CFR pt. 424, subpart P.  The number of standards of 
participation that apply to DMEPOS suppliers has increased over time. 
6 42 CFR  424.57(b) and (d).  (Subsequently, paragraph (d) was moved to paragraph (e).) 
7 Ibid. 
8 42 CFR  424.57(c)(2).  See also 42 CFR  424.510(d)(2)(i). 
9 Sections 5 and 6 of Form CMS-855S.  CMS requires this information pursuant to  
42 CFR  420.206 and 424.510(d)(2)(i). 
10 Sections 3, 5, and 6 of Form CMS-855S. 
OEI-06-09-00230    PROGRAM INTEGRITY PROBLEMS WITH NEWLY ENROLLED MEDICARE EQUIPMENT SUPPLIERS  2   
   
I N T R O D U C T I O N  
Enrollment application review.  CMS requires NSC to review suppliers 
enrollment applications and supporting documentation for complete and 
valid information.11  To determine its accuracy, NSC compares some 
applicant-reported informationsuch as National Provider Identifier 
(NPI) and Tax Identification Numberto external sources.  However, 
the accuracy of some reported information cannot be readily determined 
by NSC.  For example, CMS recently stated:  While we require our 
Medicare contractors to verify data submitted on, and as part of, the 
Medicare provider/supplier application, our contractors are not able to 
verify information that may have been purposefully omitted or changed 
in a manner to obfuscate any previous criminal activity.12   
Preenrollment site visits.  CMS requires NSC to conduct at least one 
unannounced site visit to an applicants business location to assess 
compliance with the Medicare standards of participation, with certain 
types of supplier applicants exempted.13  In site visit reports, NSC 
investigators record their findings about supplier compliance with 
standards and their assessment of the fraud risk that the applicant 
poses.  The site investigation reports also include site investigator notes 
from supplier staff interviews; photographs of the business and onsite 
inventory; and any supporting documentation obtained, such as 
business and professional licenses.  
Supplier approval and risk rating.  Once NSC determines that a supplier 
applicant meets the Medicare standards of participation, it grants the 
new supplier Medicare billing privileges by assigning a unique billing 
number for each approved business location.  At the time of our review 
and prior to ACA enactment, NSC also assessed the fraud and abuse 
risk of new supplier applicants and assigned each a risk rating called 
the Fraud and Abuse Indicator of Risk (FAIR).14  (We discuss related 
ACA-required changes beginning on page 5.)  Prior to ACA enactment, 
DMEPOS suppliers were the only Medicare provider type to receive 
risk-based screening and monitoring as part of their participation.15 
 
11 NSC Statement of Work (SOW), Att. J.1,  1.2.2, obtained by OIG from CMS on                  
June 18, 2009. 
12 76 Fed. Reg. 5867 (Feb. 2, 2011). 
13 NSC SOW, Att. J.1,  1.15.  Certain Medicare suppliers were exempt from these 
preenrollment site visit requirements, including suppliers with 25 or more active locations, 
physicians, and certified Medicare providers (e.g., hospitals, home health agencies). 
14 PIM, ch. 10  21.4.  Formerly known as Fraud Level Indicator.  See also NSC SOW. 
15 See PIM, ch. 10. 
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I N T R O D U C T I O N  
To determine the FAIR rating, NSC scored each applicant using  
15 predefined risk factors, such as: 
 the applicants geographic area, 

 the fraud potential of the applicants products and services, 

 the applicants prior Medicare experience, and 

 the applicants site visit results.16 

Using information from the site visit report and the suppliers 
application, NSC assigned one of four FAIR ratings: 
 low risk (e.g., national drugstore), 

 limited risk (e.g., clinicians in low-fraud areas), 

 medium risk (e.g., medium-sized medical supplier in a high-fraud 

area), or  
 high risk (e.g., small supplier with low inventory levels in a 

historically high-fraud area).17 
NSC tracked each suppliers individual risk factors and FAIR score on a 
spreadsheet, known as the FAIR matrix.  Once a supplier was approved 
to participate in Medicare, the newly enrolled suppliers FAIR rating 
determined the number of postenrollment site visits that NSC 
performed to ensure continuing supplier compliance with the 
participation standards. 
Postenrollment Site Visits of DMEPOS Suppliers  
At the time of our review, CMS required NSC to conduct at least one 
postenrollment site visit per year for medium-risk suppliers and at least 
two for high-risk suppliers.18  CMS did not require postenrollment site 
visits for low-risk or limited-risk suppliers, although NSC could decide 
to conduct a visit if complaints or other factors generated concern about 
a supplier.19  CMS also required NSC to update each suppliers FAIR 
rating at least annually, based in part on information gathered during 
site visits.20 
 
16 NSC SOW, App. J.1, 1.2.1. 
17 PIM, ch. 10,  21.4; NSC SOW, Att. J.1,  1.2.1. 
18 NSC SOW, Att. J.1,  1.2.2. 
19 Ibid. 
20 NSC SOW, Att. J.1,  1.19.1. 
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II NN TT RR OO DD UU CC TT II OO NN   
Related Changes From the Affordable Care Act 
Section 6401 of the ACA added new requirements at 1866(j)(2) for the 
Secretary to conduct certain enrollment-screening measures for 
different types of Medicare providers, including DMEPOS suppliers.  In 
February 2011, CMS promulgated a final rule implementing those 
provisions effective March 25, 2011, for all new DMEPOS supplier 
applicants and existing Medicare suppliers revalidating their 
enrollment information.  For all other currently enrolled suppliers, the 
rule will become effective March 23, 2012.21   
To implement the new screening measures, CMS will classify all 
DMEPOS suppliers into one of three risk categories:  limited, moderate, 
or high.22  CMS will assign nearly all newly enrolling DMEPOS 
suppliers to the high risk category and currently enrolled and 
revalidating DMEPOS suppliers to the moderate risk category.23  
Screening will include at a minimum, verification of compliance with 
Federal and State requirements, licensure checks, and database checks.  
Each supplier in the moderate- and high-risk categories must also 
undergo an onsite visit.24  High-risk suppliersboth current suppliers 
and applicantsmust submit the fingerprints of all owners with 5 
percent or greater direct or indirect ownership, who are then subject to 
a fingerprint-based criminal history report.25 
The risk-rating system to be implemented by CMS puts all new 
DMEPOS supplier applicants into the high-risk category.  In  
February 2011, CMS staff stated that CMS is developing appropriate 
policies and procedures to transition NSCs FAIR rating system and 
corresponding monitoring practices to the specific ACA-required policies 
and practices.   
A related change resulting from the ACA involves disclosure of 
information on enrollment applications and updates of enrollment 
application information by existing suppliers.  The ACA requires 
suppliers to disclose any current or previous affiliation with other 
providers or suppliers that have certain Medicare, Medicaid, or CHIP 
 
21 76 Fed. Reg. 5865 (Feb. 2, 2011).  Any currently enrolled supplier that revalidates its 
enrollment information on or after March 25, 2011, and before March 24, 2012, is also 
subject to the rule.   
22 76 Fed. Reg. 5862, 5867 (Feb. 2, 2011). 
23 42 CFR  424.518 (b)(1)(x) and (c)(1)(ii), effective March 25, 2011. 
24 42 CFR  424.518 (a) and (b). 
25 42 CFR  424.518 (c); 76 Fed. Reg. 5862 (Feb. 2, 2011).  
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I N T R O D U C T I O N  
program integrity problems, including uncollected debt, payment 
suspension, exclusion from program participation, and revocation of 
billing privileges.26  CMS has authority to deny or revoke the Medicare 
billing privileges of suppliers for submitting false or misleading 
information on the Medicare enrollment applications.27   
Indicators of Program Integrity Problems 
This report uses the results of several contractors oversight activities as 
indicators of program integrity problems among DMEPOS suppliers 
during their first year in Medicare.  As stated, NSC is responsible for 
screening supplier applicants and conducting unannounced site visits.  
Durable Medical Equipment Medicare Administrative Contractors 
(DME MAC) are responsible for DMEPOS claims processing activities, 
which can include monitoring supplier billing, identifying and collecting 
overpayments, and following up on complaints against suppliers.  
Program Safeguard Contractors (PSC) and Zone Program Integrity 
Contractors (ZPIC) are responsible for conducting a variety of oversight 
activities, such as prepayment and postpayment medical reviews of 
claims, provider education, and data analysis, to detect potential 
overpayments and fraud.28   
We focus on two types of CMS enforcement actions that potentially 
result from these contractors oversight activities:  revocation of billing 
privileges and prepayment claims reviews. 
 Revocation of Billing Privileges.  A revocation is the termination of a 
suppliers billing privileges.  Revocations can be imposed for 
noncompliance with the participation standards, supplier misconduct, 
felony conviction, providing misleading information, or misuse of a 
billing number, among other reasons.29  Once their billing privileges 
are revoked, suppliers are barred from participating in Medicare for a 
minimum of 1 year, but not greater than 3 years, depending on the 
reason for revocation.30 
 Prepayment Claims Review.  PSCs and ZPICs conduct prepayment 
claims review when they have evidence that a supplier submitted 
 
26 ACA  6401; Social Security Act  1866(j)(5). 
27 42 CFR  424.530(a) and 424.535(a).  
28 CMS was transitioning PSCs to ZPICs nationwide at the time of our review. 
29 See 42 CFR  424.535(a) and  424.57(e) for the complete list of revocation reasons.   
See also PIM, ch. 10,  13.2. 
30 42 CFR  424.535(c). 
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I N T R O D U C T I O N  
improper or potentially fraudulent claims.  Factors leading to 
prepayment review include unusual supplier billing patterns, 
knowledge of abuses in the service area, or complaints received from 
beneficiaries or others.  Prepayment reviews vary in scope; they can 
include all claims from a particular provider, or they can focus on 
selected services, place of service, or other specific criteria.31 
METHODOLOGY 
Scope and Sample 
We selected a stratified random sample of DMEPOS suppliers that 
enrolled in Medicare for the first time between October 1 and  
December 31, 2008.  We stratified by the suppliers FAIR rating at the 
time of enrollment.  Using the NSC supplier enrollment file, we 
identified 430 low-risk, 529 limited-risk, 207 medium-risk, and  
67 high-risk suppliers. 
For sampling and analysis purposes, we combined the groups with FAIR 
ratings of low risk and limited risk into one stratum, because NSC 
staff informed us that it treats suppliers in the two groups virtually the 
same once they have been approved for Medicare participation.  We 
hereafter refer to this stratum as low/limited-risk suppliers.  The 
low/limited-risk stratum consisted of 91 of the 959 low-risk and 
limited-risk suppliers.  The medium-risk stratum consisted of 71 of the 
207 medium-risk suppliers, and the high-risk stratum consisted of all 
67 high-risk suppliers.  Our total sample consisted of 229 suppliers, and 
we had a 100-percent response rate.32 
We examined multiple data sources regarding the sampled suppliers, 
covering the period from the date of their Medicare enrollment through 
December 31, 2009.  Although we refer to the review period as the first 
year of enrollment, the actual review period for each supplier spanned 
up to 15 months, depending on each suppliers enrollment date.  For 
example, a supplier that was enrolled on October 1, 2008, would have 
been in the program for 15 months by December 31, 2009, whereas a 
supplier that enrolled on December 31, 2008, would have been in the 
program for only 12 months. 
 
31 PIM, ch. 3. 
32 We originally selected 92 low/limited-risk suppliers but eliminated 1 supplier from the 
sample because of an error in the data regarding the suppliers enrollment date. 
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I N T R O D U C T I O N  
Data Collection and Analysis 
We used multiple data sources for our review.  
 Medicare claims data.  We used CMSs National Claims History 

File to identify Medicare reimbursements for each supplier in our 
sample.   
 Data on revocation of Medicare billing privileges.  We used NSC 

data to identify suppliers in our sample whose billing privileges 
were revoked during the study period, the revocation dates, and the 
reasons for revocation.   
 Prepayment claims review data.  We used data from five CMS 

contractors to identify sampled suppliers placed on prepayment 
review during the study period and the dates of the reviews.33    
 Supplier enrollment applications.  We obtained all sampled 

suppliers enrollment applications (Form CMS-855S) and any 
updates to them. 
 NSC site investigator reports.  We obtained all reports completed by 

NSC site investigators after they conducted an unannounced visit 
to each sampled suppliers place of business.   
Analysis of DMEPOS supplier program integrity problems.  To determine the 
extent to which these newly enrolled suppliers had indicators of 
program integrity problems, we analyzed each suppliers Medicare 
enrollment application, reports from NSCs site investigation(s) of the 
supplier, claims submitted by the supplier, and any CMS enforcement 
actions taken against the supplier.  Our findings focus on two CMS 
enforcement actions:  revocation of suppliers billing privileges and 
placement of suppliers on prepayment claims review.  Revoking a 
suppliers billing privileges is one of the strongest enforcement actions 
that CMS can take.  Likewise, placing a supplier on prepayment review 
indicates that CMS has significant concerns about the legitimacy of that 
suppliers claims.  Collectively, these data sources exhibited indicators 
of program integrity problems with suppliers during their first year in 
Medicare.   
Analysis of supplier omission of required information.  To determine the 
extent to which newly enrolled suppliers omitted required information 
regarding their owners and managers and these individuals criminal 
 
33 AdvanceMed ZPIC, Health Integrity ZPIC, Safeguard Services ZPIC, Safeguard 
Services PSC, and Tricenturion PSC provided this data. 
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I N T R O D U C T I O N  
histories from their enrollment applications, we compared each 
suppliers reported information to the personal, corporate, and criminal 
records information stored in Lexis/Nexis Accurint for Government 
(hereinafter referred to as Accurint) for each of the 229 suppliers in our 
sample.34  We used Accurint to identify individuals who were not 
disclosed on the enrollment application, but who were listed in public 
records as a current owner or manager of the supplier.  By matching 
Social Security Numbers and dates of birth, we checked the criminal 
histories of owners or managers listed on the enrollment applications to 
identify whether any reported owners or managers did not fully disclose 
their criminal histories.35     
For purposes of the report, we present certain findings for the high- and 
medium-risk strata together.  We chose this presentation because we 
identified few notable differences in the rates of program integrity 
problems between the high- and medium-risk suppliers, whereas the 
main differences were between low/limited-risk suppliers and the 
combined group of high- and medium-risk suppliers.  Based on the 
stratified sample design, all findings can be projected to the population 
of suppliers newly enrolled in Medicare during OctoberDecember 2008, 
unless otherwise noted as applying specifically to sampled suppliers.  
See Appendix A for statistical estimates and confidence intervals.   
Limitations 
Our findings about supplier omissions on enrollment applications are 
subject to an inherent limitation in Accurints datanamely, that 
because of State privacy laws, the types of public records stored in 
Accurint are not uniform across States.  As a result, some record types 
 
34 Accurint is a database available to law enforcement agencies that collects a broad 
array of public records on both businesses and individuals.  For business searches, Accurint 
draws from corporate filings, property information, phone listings, professional licenses, 
and Securities and Exchange Commission filings, among other data.  For personal searches, 
Accurint contains information on Social Security numbers, drivers licenses, and 
professional licenses.  Information on property assets and court proceedings is also 
available both for individuals and businesses. 
35 We limited the Accurint review (for omitted criminal histories and adverse legal 
actions) to only high- and medium-risk suppliers.  We did this because of the  
time-consuming nature of the Accurint analysis and because low/limited-risk suppliers
such as larger national chain pharmaciesoften listed corporate officers rather than 
owners on their applications.  Additionally, exploratory analysis suggested that we would 
find few, if any, omissions of criminal history information among low/limited-risk suppliers.  
Criminal records data from Accurint typically included the specific charge, charge date, and 
legal outcome. 
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I N T R O D U C T I O N  
(e.g., financial filings) were not available for all sampled suppliers, and 
the comprehensiveness of criminal records, in particular, varied by 
State.  We did not verify the accuracy of the public records stored in 
Accurint, as that was beyond the scope of this review.   
Another limitation applies to our findings regarding indicators of 
supplier program integrity problems.  CMS and its contractors conduct 
more oversight of high- and medium-risk suppliers than of 
low/limited-risk suppliers, and this additional oversight may result in 
more enforcement actions.  
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of the Inspectors 
General on Integrity and Efficiency. 
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B A FN IN NE DR I  N2 NG DS    P A G E  
During their first year in Medicare, 26 percent of  
A projected 26 percent of high- and 
high- and medium-risk suppliers and 2 percent of  medium-risk suppliers had a CMS 
low/limited-risk suppliers had their billing privileges  enforcement action, and 4 percent 
revoked or were placed on prepayment claims review  both had their billing privileges 
revoked and were placed on 
prepayment review.  None of the low/limited-risk suppliers in the 
sample had been subject to both CMS enforcement actions. 
CMS revoked the Medicare billing privileges of 21 percent of high- and 
medium-risk suppliers, yet some received large Medicare payments prior to 
revocation  
Medicare reimbursed high-risk suppliers $2.8 million and medium-risk 
suppliers $70,582 prior to the revocations of their billing privileges.  
Combined, this equates to an average of $191,841 per supplier that had 
its billing privileges revoked and received any payments from 
Medicare.36 
Revocations occurred after NSC determined that the newly enrolled 
suppliers no longer met all Medicare supplier participation standards.  
Among the 28 suppliers in our sample whose billing privileges had been 
revoked, revocation occurred for 16 because they had not paid the surety 
bond newly required for DMEPOS suppliers as of July 1, 2009.  All 16 of 
these supplier revocations occurred within a 4-day period when NSC 
began fully enforcing the new surety bond requirement.   
For the remaining 12 of the 28 suppliers in our sample, NSC coded the 
reason for revocation of billing privileges as failure to meet all 
standards.  For this group, revocation often occurred shortly after NSC 
conducted postenrollment site visits to the suppliers places of business; 
CMS revoked these suppliers billing privileges an average of 16 days 
after a site visit.  This timing suggests that revocation stemmed from 
information gathered during NSCs site visits.   
NSC conducted postenrollment site visits largely within the timeframes 
required by CMS.  For the suppliers that required two unannounced 
visits during the first year of enrollment, NSC conducted its first 
postenrollment site visit an average of 163 days (5.4 months) after 
enrollment.  For suppliers that required only one site visit during the 
 
36 CMS revoked the billing privileges of 28 high- and medium-risk suppliers in our 
sample.  Fifteen received Medicare reimbursement prior to revocation.  Of those suppliers 
that received reimbursement, eight were high risk and seven were medium risk.     
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F I N D I N G S  
first year of enrollment, NSC conducted the visit an average of 325 days 
(10.8 months) after enrollment.   
However, several suppliers in our sample had already received 
significant Medicare payments before their first postenrollment site 
visit and the subsequent revocation of their billing privileges.  For 
example, one sampled supplier received almost $800,000 from Medicare 
prior to its first postenrollment site visit, which NSC conducted  
7 months after the supplier enrolled.  Medicare paid another supplier in 
our sample over $500,000 before NSC conducted the first 
postenrollment site visit, 5 months after the supplier enrolled.   
CMS placed 9 percent of high- and medium-risk suppliers on  
prepayment claims review   
CMS instituted prepayment claims reviews for reasons such as billing 
for services not ordered by a physician, billing for services not rendered, 
having unusual billing patterns, and failing to respond to CMS or 
contractor requests for additional information.  As projected from our 
sample, high- and medium-risk suppliers placed on prepayment review 
received $6.7 million from Medicare during our study period.  During 
the study period, CMS ultimately revoked the billing privileges of 8 of 
the 17 suppliers in our sample that it placed on prepayment review.   
CMS revoked the Medicare billing privileges of a projected 2 percent of 
low/limited-risk suppliers; none of the low/limited-risk suppliers were placed 
on prepayment claims review 
Low/limited-risk suppliers demonstrated few problems.  Those sampled 
suppliers whose billing privileges were revoked did not receive any 
Medicare reimbursement prior to revocation.  Both suppliers billing 
privileges were revoked for nonpayment of the surety bond. 
Our review of public records 
Thirteen percent of high- and medium-risk 
revealed that a projected             
suppliers and 4 percent of low/limited-risk 
13 percent of high- and medium-
suppliers omitted ownership or management 
risk suppliers and 4 percent of 
information from their Medicare enrollment 
low/limited-risk suppliers omitted 
applications  the name of an owner or a 
manager.   By the end of 2009, 
Medicare reimbursed the 9 sampled high-risk suppliers $2.64 million 
and reimbursed the 6 sampled medium-risk suppliers $280,596.  Of the 
four low/limited-risk sampled suppliers that omitted ownership or 
management information, two received $5,217 during the study period 
and the other two did not receive any payments.  Further, 11 of the 
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F I N D I N G S  
20 high- and medium-risk sampled suppliers that omitted ownership or 
management information remained in Medicare at the end of 2010.  
Combined, these findings suggest that information omitted from 
enrollment applications can remain undetected despite NSC application 
reviews and postenrollment site visits.37   
The types of supplier omissions varied.  In one example, an owners 
spouse was listed as an owner on State incorporation documents but 
was never disclosed to CMS on the suppliers enrollment application.  In 
another example, individuals listed on incorporation documents had 
apparently left the company.  For 5 of the 20 high- and medium-risk 
sampled suppliers that omitted ownership or management information, 
we found that the omitted owners or managers had prior convictions for 
serious crimes or had been subject to adverse legal actions.  Whether 
those convictions were the reason that the applicant omitted the 
owner/manager or whether the omissions reflect honest errors requires 
further investigation.  For the low/limited-risk suppliers in our sample, 
we did not identify any prior convictions of omitted owners or managers 
or other adverse legal actions taken against these individuals.      
Four percent of high- and medium-risk suppliers  A small number of high- and 
medium-risk suppliers did not 
omitted information regarding criminal histories or 
report either criminal histories 
adverse legal actions from their applications 
or adverse legal actions taken 
against owners or managers listed on the suppliers applications.  
However, four of the six suppliers in our sample that omitted this 
information did not submit Medicare claims during our study period.  
Medicare reimbursed the other two suppliers a total of $369,054 by the 
end of 2009.   
Examples of adverse legal actions not reported by suppliers in our 
sample include insurance fraud, theft by deception, felony drug 
possession, and felony aggravated battery.  Convictions like these, if 
reported, might have resulted in the denial of an applicants Medicare 
enrollment application, and their omission is potential grounds for both 
revocation of billing privileges and permissive exclusion by OIG.38  For 
example, one high-risk supplier failed to disclose the prior Medicare 
exclusion of one of its owners by omitting that fact on the application.  
 
37 We did not classify an individuals name as omitted if the name was added to a 
suppliers file at any time during the first year of the suppliers enrollment.     
38 42 CFR  424.57(e). 
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FF II NN DD II NN GG SS   
Additionally, the supplier transposed the last two digits of the owners 
Social Security number, meaning that when NSC checked the listed 
Social Security number against the Medicare Exclusions Database, no 
matches came up.  Ultimately, NSC revoked the suppliers billing 
privileges within 4 months of enrollment.  The supplier did not receive 
any Medicare reimbursement prior to revocation. 
Other supplier omissions occurred after enrollment, with suppliers 
failing to notify NSC within 30 days of adverse legal actions taken 
against them, as required.  If this information is not disclosed, the 
supplier could continue to receive reimbursement until NSC detects the 
adverse legal action through other methods.  For example, during an 
unannounced site visit to a high-risk supplier in our sample, the NSC 
investigator learned from the suppliers landlord that the suppliers 
owner was incarcerated, which the investigator confirmed with the 
Federal Bureau of Prisons.  Based on the site investigators notes and 
our review of public records, the incarcerated owner also owned or 
managed five other Medicare-participating businesses.  This sampled 
supplier received $65,000 from Medicare before NSC conducted the 
postenrollment site visit, discovered the suppliers omission, and 
revoked its billing privileges 6 months after enrollment.
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 R E C O M M E N D A T I O N S  
The ACA strengthens enrollment screening for all supplier and provider 
types across Medicare, Medicaid, and CHIP.  Prior to ACA enactment, 
DMEPOS suppliers were the only Medicare provider type to receive 
risk-based screening and monitoring as part of their Medicare 
participation.  This subjected the highest risk DMEPOS applicants to 
enrollment screening, unannounced preenrollment site visits, and one 
or more postenrollment site visits during the first year of program 
participation.   
We found that a number of newly enrolled high- and medium-risk 
DMEPOS suppliers still exhibited program integrity problems once 
enrolled.  Some suppliers in our sample received significant Medicare 
reimbursement before NSC conducted its first postenrollment site visits 
and CMS took enforcement actions.  Further, some high- and 
medium-risk DMEPOS applicants omitted owner or manager 
information that, if disclosed on their applications or discovered by CMS 
and its contractors, might have prevented their entering the program or 
prevented their continued enrollment.  These findings demonstrate 
enduring program integrity problems among DMEPOS suppliers and 
illustrate why effective monitoring of this provider group is essential. 
Although the ACA strengthens enrollment screening of DMEPOS 
supplier applicants and CMS oversight authorities, further scrutiny of 
the riskiest applicants and enrolled suppliers is needed to prevent 
dishonest individuals from receiving Medicare payment.  Therefore, we 
recommend that CMS: 
Conduct postenrollment site visits earlier for new DMEPOS suppliers 
receiving the most money from Medicare  
Although NSC conducted site visits of high- and medium-risk suppliers as 
required by CMS, Medicare had already made significant payments to 
some suppliers in our sample before they received their first 
postenrollment site visits from NSC.  CMS could use the FAIR rating to 
prioritize certain newly enrolled suppliers and require NSC to conduct 
postenrollment site visits earlier, possibly within a month, for newly 
enrolled high- and medium-risk suppliers that submit large dollar 
amounts of claims.  CMS could also use prepayment claims reviews for 
high-billing newly enrolled high- and medium-risk suppliers. 
 
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R E C O M M E N D A T I O N S  
Apply investigative techniques and tools to identify any owners or 
managers of DMEPOS suppliers who are not reported on supplier 
applications as required 
Our findings demonstrate that omissions of the names of owners or 
managers can allow a supplier to gain billing privileges when it might 
otherwise be denied Medicare participation.  Additionally, CMS 
recognizes that its contractors are not currently able to verify 
information that may have been purposely omitted or changed in such a 
manner as to obfuscate it.  Consequently, such omissions could 
circumvent new fingerprint-based criminal background checks added by 
the ACA.   
Therefore, CMS should improve processes to detect information that 
may be purposely omitted by individuals who are intent on defrauding 
the program.  In doing so, CMS could establish mechanisms to access 
public records, as we did for this report, to identify all owners and 
managers who should be listed by new DMEPOS applicants.  Given that 
few low/limited-risk suppliers in our sample omitted such information, 
CMS should focus such investigative activities on suppliers deemed high 
or medium risk by in-depth assessments, such as the FAIR rating.   
Take appropriate action regarding DMEPOS suppliers that omit 
information from applications  
We will forward to CMS the names of those suppliers that we 
identified as having omitted (a) the names of owners or managers or  
(b) information regarding the criminal histories of owners or 
managers or any adverse legal actions taken against these 
individuals.  CMS can then determine whether the omissions were 
intentional and whether further action is needed.  Additionally, in the 
future, when CMS determines that suppliers have inappropriately 
omitted required information from a Medicare enrollment application, 
CMS should refer these individuals and suppliers to OIG for (if 
warranted) permissive exclusion.  
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
In its comments on the draft report, CMS concurred with our 
recommendations and stated that it is using authorities granted 
under the ACA to address potential vulnerabilities. 
  
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R E C O M M E N D A T I O N S  
In response to our recommendation to conduct postenrollment site 
visits earlier for new DMEPOS suppliers receiving the most money 
from Medicare, CMS stated that it has already taken steps to address 
this issue.  In December 2009, the NSC began conducting at least bi-
monthly observational site visits on suppliers with a FAIR rating of 
High.  CMS stated that it will instruct NSC to perform, at a 
minimum, an observational site visit on all suppliers with a FAIR 
rating of High within 60 days of enrollment and those with a FAIR 
rating of Medium within 120 days of enrollment. 
In response to our recommendation to apply investigative techniques 
and tools to identify any owners or managers of DMEPOS suppliers 
who are not reported on supplier applications as required, CMS 
stated that beginning December 2011, a new screening contractor will 
use external referential data to identify individuals affiliated with 
companies but not reported on enrollment documents and will alert 
NSC and the MACs accordingly. 
In response to our recommendation to take appropriate action 
regarding DMEPOS suppliers that omit information from 
applications, CMS stated that it will research and take action, if 
appropriate, on those individuals identified by OIG.  CMS also stated 
that it will continue to refer to law enforcement agencies for action at 
their discretion any individuals and suppliers identified as having 
inappropriately omitted required information from enrollment 
applications.   
For the full text of CMS comments, see Appendix B.  We made minor 
changes to the report based on technical comments. 
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 A P P E N D I X   ~   A  
Estimates and Confidence Intervals 
We calculated estimates and corresponding 95-percent confidence 
intervals using the statistical software program Sudaan, which 
calculated correct standard errors based on the stratified sample design. 
 
Table A-1:  Percent Estimates and Confidence Intervals 
 
Estimated  95-Percent 
 
Percentage   Confidence  
  Type of Supplier  of Suppliers  Interval 
  At Least One Enforcement Action 
  Low Risk  2.2%  0.68.0% 
  High and Medium Risk  26.1%  20.332.8% 
  Both Enforcement Actions 
 
High and Medium Risk  3.6%  2.35.8% 
 
Billing Privilege Revocation 
 
Low Risk  2.2%  0.68.0% 
 
High and Medium Risk  20.7%  15.427.2% 
 
Prepayment Review 
 
Low Risk  0.0%  0.04.0% 
 
High and Medium Risk  9.0%  6.212.9% 
 
Omission of Ownership or Management 
     Information 
  Low Risk  4.4%  1.710.8% 
  High and Medium Risk  12.9%  9.018.2% 
  Omission of Criminal or Adverse Legal History 
  High and Medium Risk  3.6%  1.86.9% 
  Low/Limited-Risk Suppliers (sample size=91)   
  High- and Medium-Risk Suppliers (sample size=138) 
  Source:  Office of Inspector General (OIG) analysis of 229 newly enrolled suppliers of 
durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS), 2011. 
 
   
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A P P E N D I X ~ A  
 
 
 
Table A-2:  Reimbursement of Suppliers on Prepayment Review 
 
  Estimated Reimbursement   95-Percent  
Type of Supplier  of Suppliers  Confidence Interval 
 
  High and Medium Risk  $6,722,258.35  $5,781,020.95$7,663,495.75 
 
High- and Medium-Risk Suppliers (sample size=138) 
 
Source:  OIG analysis of 229 newly enrolled DMEPOS suppliers, 2011. 
 
 
 
 
Table A-3:  Averaged Elapsed Time Before First 
   
Postenrollment Site Visit 
95-Percent  
Type of Supplier  Estimated Days  Confidence Interval 
Medium Risk  325.30 days  306.69343.91 days 
Medium-Risk Suppliers (sample size=60)* 
* Eleven medium-risk suppliers in our sample did not have postenrollment site visits 
conducted by the National Supplier Clearinghouse, six were exempt from site visits, and 
five had their Medicare billing privileges revoked prior to a first site visit. 
Source:  OIG analysis of 229 newly enrolled DMEPOS suppliers, 2011. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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A  P  PEN  D  B 

Agency Comments 
(J
......
.,'~ 
DEPAIUMENT OF H1!ALTH & HUMAN SERVICES  Cenle", for Medicare & Medicaid Services
Administrlltor 
Washington, DC 20201 
NOV 0 2 2011 
DATE: 
TO:  Daniel R. Levinson 
Inspector General 
FROM:  Donald M. lle1\Vick, M.D. 
Administrato'r-
SUBJECT:  Office ofInspector General (OlG) Draft Report: "Program Integrity Problems 
with Newly Enrolled Medicare Suppliers of Durable Medical Equipment, 
Prosthetics, Orthotics, and Supplies" (OEI-06-09-00230) 
The Centers for Medicare & Medicaid Services (CMS) appreciates the opportunity to review and 
comment on the Office oflnspector General (OlG) draft report entitled, "Program Integrity 
Problems with Newly Enrolled Medicare Suppliers ofDurable Medical Equipment, Prosthetics, 
Orthotics, and Supplies." The OIG had mUltiple objectives. First, it seeks to determine the 
extent to which newly enrolled suppliers ofdurable medical equipment, prosthetics, orthotics, 
and supplies (DMEPOS) had their billing privileges revoked or were placed on prepayment 
claims review. Secondly, it seeks to determine the extent to which newly enrolled DMEPOS 
suppliers omitted from their Medicare enrollment applications required information regarding (a) 
owners/managers or (b) the criminal histories ofowners/managers or any adverse legal actions 
taken against those individuals. 
The Affordable Care Act strengthens the focus on the integrity ofthe Medicare, Medicaid, and 
Children's Health Insurance Program (CHIP) programs and ,provides important new tools to 
combat fraud and abuse, including enhanced provider and supplier screening requirements, 
authority to suspend payments pending investigations of credible allegations of fraud, and, when 
necessary, authority to impose moratoria on new providers and suppliers. 
The DMEPOS benefit has historically been vulnerable to abuse. As such, CMS is taking 
additional steps to address potential vulnerabilities in the ellfollment and claims payment process 
for this supplier group using the authorities granted under the Atfordable Care Act.  Under the 
new screening provisions ofCMS 6028-FCI, currently enrolled (revalidating) DMEPOS are 
considered a moderate-risk provider/supplier and all newly enrolling suppliers of DMEPOS are 
considered a high-risk provider/supplier. Both risk groups are, therefore, subject to unannounced 
site visits. 
I CMS 6028-FC entitled. "Medicare, Medicaid and Children's Health Insurance Programs; Additional Screening 
Requirements, Application Fees, Temporary Enrollment Moratoria, Payment Suspensions and Compliance Plans for 
Providers and Suppliers" was published in the Federal Register on February 2, 20 II. 
OEI060900230  PROGRAM INTEGRITY PROBLEMS WITH NEWLY ENROLLED MEDICARE EQUIPMENT SUPPLIERS  20   
   
A P P E N D I X   ~   B  
 
 
   
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A P P E N D I X   ~   B  
 
   
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 A C K N O W L E D G M E N T S  
This report was prepared under the direction of Kevin Golladay, 
Regional Inspector General for Evaluation and Inspections in the Dallas 
regional office; Blaine Collins, Deputy Regional Inspector General; and 
Ruth Ann Dorrill, Deputy Regional Inspector General.   
Tom Browning served as the Project Lead for this study and  
Jennifer Gist served as the Lead Analyst.  Other principal Office of 
Evaluation and Inspections staff from the Dallas regional office who 
contributed to the report include Ben Gaddis and Deborah McGurk.  
Central office staff who contributed include Kevin Farber, Rob Gibbons, 
Scott Manley, and Meghan Ruhnke.  
 
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Office of Inspector General 
http://oig.hhs.gov 
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as 
amended, is to protect the integrity of the Department of Health and Human Services 
(HHS) programs, as well as the health and welfare of beneficiaries served by those 
programs.  This statutory mission is carried out through a nationwide network of audits, 
investigations, and inspections conducted by the following operating components: 
Office of Audit Services 
The Office of Audit Services (OAS) provides auditing services for HHS, either by 
conducting audits with its own audit resources or by overseeing audit work done by others.  
Audits examine the performance of HHS programs and/or its grantees and contractors in 
carrying out their respective responsibilities and are intended to provide independent 
assessments of HHS programs and operations.  These assessments help reduce waste, 
abuse, and mismanagement and promote economy and efficiency throughout HHS. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 
HHS, Congress, and the public with timely, useful, and reliable information on significant 
issues.  These evaluations focus on preventing fraud, waste, or abuse and promoting 
economy, efficiency, and effectiveness of departmental programs.  To promote impact, OEI 
reports also present practical recommendations for improving program operations.  
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations 
of fraud and misconduct related to HHS programs, operations, and beneficiaries.  With 
investigators working in all 50 States and the District of Columbia, OI utilizes its resources 
by actively coordinating with the Department of Justice and other Federal, State, and local 
law enforcement authorities.  The investigative efforts of OI often lead to criminal 
convictions, administrative sanctions, and/or civil monetary penalties. 
Office of Counsel to the Inspector General 
The Office of Counsel to the Inspector General (OCIG) provides general legal services to 
OIG, rendering advice and opinions on HHS programs and operations and providing all 
legal support for OIGs internal operations.  OCIG represents OIG in all civil and 
administrative fraud and abuse cases involving HHS programs, including False Claims 
Act, program exclusion, and civil monetary penalty cases.  In connection with these cases, 
OCIG also negotiates and monitors corporate integrity agreements.  OCIG renders 
advisory opinions, issues compliance program guidance, publishes fraud alerts, and 
provides other guidance to the health care industry concerning the anti-kickback statute 
and other OIG enforcement authorities.