Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
A MESSAGE FROM  
THE INSPECTOR  GENERAL  
I  am pleased to present the enclosed  Semiannual Report to Congress  summarizing significant work of  
the Office of Inspector General (OIG), Department of  
Health and Human Services (HHS or the Department) for 
the reporting period  covering October 1, 2017, to March  
31,  2018.  Each day, OIG uses data-driven decision making  
to  combat fraud, waste, and abuse of Federal health care 
programs and to improve the effectiveness of  Department  
programs.  Our multidisciplinary team of  auditors,  
investigators, evaluators,  analysts, and attorneys 
strategically focuses  on fraud  prevention,  detection, and 
enforcement efforts.  Over the 6-month reporting  period  
OIG  worked to  enhance the integrity of HHS programs and  
operations, protect vulnerable populations,  and drive value 
in  health and human services.  
 
OIG has long been a leader in the Departments fight  
against prescription drug fraud, including opioids, drug 
diversion, pill mills, medical identity theft, and other 
schemes that endanger people and communities.  OIG 
investigates a growing workload of opioid-related fraud 
cases and provides practical recommendations for programmatic changes to protect patients and  
programs.  In January, OIG testified before the U.S.  House of Representatives Committee on Ways and  
Means  about the current opioid landscape and highlighted our  related recommendations.  OIG works  
actively with the Department, Congress,  and key  external stakeholders to  reduce inappropriate 
prescribing and foster effective, efficient addiction treatment.   
 
We are in an information revolution that requires  constant vigilance over the security of sensitive data  
and systems.   Cybersecurity incidents and breaches pose a significant risk to the confidentiality,  
integrity, and availability  of sensitive data.  Incidents and breaches can impede HHSs ability to deliver  
essential  programs and services, threaten major elements of our countrys  critical infrastructure, and  
place at risk the health and safety  of patients.  OIG is focused on identifying and addressing 
cybersecurity risks within the Department.   During this reporting period, OIG found that security  
controls across four HHS agencies needed improvement to more effectively detect and prevent  
cyberattacks.   OIGs cybersecurity work helps protect the public from harm and helps the Department  
secure its data and systems.   
  
HHS programs  provide critical health and human services to many vulnerable populations, including 
adults and children in foster care and individuals receiving care in group home settings.  In March,  OIG  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
issued a report that found 20 group care facilities for children in foster care that were surveyed in 
Washington State did not comply with State health and safety requirements.   OIG works to ensure that  
these individuals have access to and receive high-quality services and are protected from abuse or  
neglect.   During this reporting period, OIG  also  released a  joint report  with  HHSs  Administration for  
Community Living and Office for Civil Rights that highlighted vulnerabilities in care provided to persons  
with disabilities in group homes and described model practices States can use to more effectively  
protect the health and safety of residents living in these group home settings.  In conjunction with the 
report, OIG held a forum  with our HHS partners to explore workable,  holistic solutions to ensure the 
safety  and quality  of care delivery for group home residents.    
 
Looking forward, OIG will continue to leverage our staff expertise to  inform  Department-wide goals,  
including  combating the opioid crisis, bringing down the high cost of prescription drugs, addressing the 
cost and availability of health insurance, and transforming our health  care system to a value-based  
system.    
 
Since Congress established  HHS-OIG in 1976, we have worked collaboratively with our partners to  
protect and oversee HHSs vital health and human services programs.  OIG appreciates the continued  
commitment and support of Congress  and the Department for the important work of our  office.    
 
Daniel R. Levinson  
Inspector General  
  
   
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
https://oig.hhs.gov  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
TABLE OF CONTENTS  
 
OIGs  Approach To Driving Positive Change   1  
   
          Highlights of OIG  Accomplishments   4  
          OIG Participation in Congressional Hearings   10  
   
Selected Acronyms and  Abbreviations   11  
 
          Oversight Activities by Program Area    
  12  
Centers for  Medicare &  Medicaid Services    
             
  24   
Legal and Investigative Activities Related to Medicare and Medicaid                                        
                                                                            
  41  
Public Health Agencies    
             
  50  
Other HHS-Related Reviews and Investigations     
          
Appendices    
   
A: Questioned Costs and Funds To Be  Put to Better Use   55  
B: Peer-Review Results   63  
C: Summary of Sanction Authorities   65  
D: Reporting Requirements in the Inspector General Act of 1978   68  
E: Reporting Requirements in the Inspector General Empowerment Act of 2016   70  
F: Anti-Kickback Statute   Safe Harbors   77  
   
 
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
OIGs  Approach  to  Driving  Positive Change  
 
THE  U.S.  DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS  or Department), Office of Inspector General  
(OIG), provides independent and objective oversight that promotes economy, efficiency, and effectiveness in 
HHS programs and operations.  OIGs program integrity and oversight  activities are shaped by legislative and  
budgetary  requirements  and adhere to professional standards established by the Government Accountability  
Office (GAO), the U.S.  Department of Justice (DOJ), and the Inspector General community.   Through a  nation-
wide network of audits, investigations, and evaluations, OIG  carries out its mission to protect the integrity of  
HHS programs and the health and welfare of the people served by those programs.  OIGs work is conducted  
by three operating componentsthe Office of Audit Services, the Office of Evaluation and Inspections, and the 
Office of Investigationswith assistance from the Office of Counsel to the Inspector General and  Executive 
Management.  
 
OIG  Organization  
 
The  Office  of  Audit  Services  (OAS).   OAS conducts audits of HHS programs and operations through its own 
resources or by overseeing audit work done by others.  Audits examine the performance of HHS programs and  
its  grantees and contractors in carrying out their respective responsibilities and  provide independent  
assessments of HHS programs and operations.  These assessments help reduce waste, abuse, and  
mismanagement and promote the economy, efficiency, and effectiveness of programs  and operations  
throughout HHS.   
 
The  Office  of Evaluation  and Inspections  (OEI).   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, and abuse and  promoting economy, efficiency, and effectiveness  in HHS  
programs.  OEI reports also present practical recommendations for improving program operations.    
 
The  Office  of  Investigations  (OI).   OI conducts  criminal, civil, and administrative investigations of  fraud and  
misconduct related to HHS programs,  operations, and beneficiaries. With investigators working in almost every  
State, the District of Columbia, and Puerto Rico, OI coordinates with DOJ and other Federal, State, and local law  
enforcement authorities.  OI also coordinates with OAS and OEI when audits and evaluations uncover potential  
fraud.  OIs investigative efforts often lead to criminal convictions, administrative sanctions, or civil monetary  
penalties (CMPs).    
 
The Office of Counsel to the Inspector General  (OCIG).   OCIG provides 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  (FCA), program exclusion, self-disclosure, and CMP cases.  In connection with these 
cases, OCIG also negotiates and monitors corporate integrity agreements (CIAs).  OCIG renders advisory  
opinions, issues compliance program guidance, publishes fraud alerts,  and provides other guidance to the 
health care industry about the anti-kickback statute and other OIG enforcement authorities.    
 
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
Executive  Management  (EM).   EM is composed of the Immediate Office of the Inspector General  and the 
Office of Management and Policy.  EM is responsible for coordinating OIG activities and providing mission 
support, including setting vision and direction for OIGs priorities and strategic planning; ensuring effective 
management of budget,  finance,  human resource management, and other  operations;  and serving as a liaison 
with HHS, Congress, and  other stakeholders.  EM  plans, conducts, and participates in a variety of cooperative 
projects within HHS and with other Government agencies.  EM provides critical data analytics, data 
management, and information technology  (IT) infrastructure that enables  OIG components to conduct their  
work efficiently and effectively.   
 
OIG  Strategic  Publications  
 
OIG Strategic Plan  
As delineated in OIGs  Strategic Plan  for 2014-2018, OIGs approach to protecting the integrity of HHS  
programs has four key goals: (1) fight fraud, waste, and abuse;  (2) promote quality, safety,  and value; (3) secure 
HHS programs future; and (4)  advance excellence and innovation.  These goals drive OIGs work planning for  
audits and evaluations as well as OIGs approach to enforcement.  They also serve as a starting point for OIGs  
own assessment of its effectiveness.   
 
Top Management and Performance  Challenges Facing HHS  
To focus the Departments attention on the most  pressing issues, each year OIG identifies the Top  
Management and  Performance Challenges  facing the Department.  These top challenges arise across HHS  
programs, and  they  cover critical HHS responsibilities that include  delivering quality services and benefits, 
exercising sound fiscal management, safeguarding public health and safety, and enhancing cybersecurity.    
 
OIG Work Plan  
OIGs  Work Plan  sets forth various projects that OIG plans to undertake during the fiscal year (FY) and beyond.   
Projects listed in the Work Plan  span the Departments operating divisions  (OPDIV) and staff divisions  
(STAFFDIV), which include the Centers for  Medicare & Medicaid Services (CMS); public health agencies such as  
the Centers for  Disease Control and Prevention (CDC),  Food and Drug Administration (FDA), and National  
Institutes of Health (NIH), as well as  human services  agencies such as the Administration for Children and  
Families  (ACF)  and the Administration  for Community Living  (ACL).  The Work Plan also includes oversight of  
State and local governments use of Federal funds as well as the administration of the Department.  Some of  
the projects described in the Work Plan  are statutorily required.    
 
Compendium of Unimplemented Recommendations  
OIG drives positive change not only by identifying  risks, problems, abuses, and deficiencies, but also by  
recommending solutions to address them.  OIG maintains a list of recommendations it has made  to HHS and  
its  OPDIVs  to  address vulnerabilities detected in its reviews, and it  keeps track of whether these 
recommendations have been implemented.   OIG systematically follows up on its recommendations with  the 
relevant  HHS  OPDIVs.   From among the recommendations that have not been implemented, OIG identifies the 
top recommendations that, if implemented, are likely to garner significant savings and improvements in quality,  
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
efficiency, and effectiveness.  OIG compiles these recommendations  in  the  Compendium of Unimplemented  
Recommendations.    
 
OIG  Semiannual Report to Congress  
OIGs  Semiannual Report(s) to Congress  (Semiannual Reports) describes OIGs work  to  identify significant  
problems, abuses, deficiencies, remedies, and investigative outcomes relating to the administration  of HHS  
programs and operations that were disclosed during the reporting period.   In the report  below, we present OIG 
expected recoveries, criminal and civil actions, and other statistics as a result of our work  for the first  half of FY  
2018.   We also highlight  some of our work completed during this semiannual reporting period  covering 
October 1, 2017,  through  March 31, 2018.   
 
 
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
Highlights  of OIG Accomplishments  
   
OIGs Semiannual Report describes OIGs work identifying significant risks,  problems, abuses, deficiencies,  
remedies, and investigative outcomes relating to the administration of HHS programs and  operations that were 
disclosed during the reporting period, October 1, 2017, through  March 31, 2018.  
The work of OIG we present here is supported by ongoing  investments  into data analytics capacity  and  
infrastructure, which we employ in conducting audits, investigations, and evaluations.  We also use data  
analytics to  assess relative risks to HHS programs  and beneficiaries and help determine where to invest our  
oversight and enforcement resources.    
In the highlights section below, we present OIG expected recoveries, criminal and civil actions, and other  
statistics as well as highlight some of our  most significant  work completed during this semiannual reporting  
period.  
   
Fighting Fraud   OIG remains at the forefront of the Nations efforts to  fight fraud in HHS programs and  
hold wrongdoers accountable for their actions.   Not only does fraud increase HHS  costs,  
in HHS  
it increases risk and potential harm to beneficiaries.   During  the semiannual reporting 
Programs   
period, OIG reported the following:  
Highlights of 
   Expected investigative recoveries of $1.46 billion  
Enforcement  
   Criminal actions against  424 individuals or entities that engaged in crimes against 
Accomplishments  
HHS programs  
   Exclusion of 1,588 individuals  and  entities from Federal health care programs  
   Civil actions against 349 individuals  or entities  
 
 
To combat health care fraud, OIG partners with DOJ,  State Medicaid Fraud Control Units  
(MFCUs  or Units), and other Federal, State, and local law enforcement agencies.  These 
partnerships include the Medicare Fraud Strike Force teams, which detect, investigate,  
and prosecute health care fraud through a coordinated and data-driven approach.    
 
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
The following examples highlight  two  of our significant enforcement accomplishments  
during this semiannual reporting period.  
 
Miami home health agency owner sentenced to more than 6  years, $45 million in 
restitution for home health fraud scheme.   Sila Luis was sentenced to over  6 years in 
prison and, jointly  and severally with her co-defendants, ordered to pay  $45 million in 
restitution following her conviction on conspiracy to commit health care fraud.  Luis and  
her co-defendants were involved in a scheme to improperly recruit patients and bill  
Medicare for unnecessary home health care  services.  
 
Drug manufacturer agreed to pay  $210 million and entered into a corporate integrity  
agreement  (CIA)  to resolve allegations of paying  kickbacks.   United Therapeutics  
Corporation (UT) agreed  to pay  $210 million to resolve False Claims Acts  (FCA)  liability  
associated with allegations that UT  violated the FCA by paying kickbacks to Medicare 
patients through donations it made to Caring Voice Coalition. UT also entered into a 5-
year CIA with OIG.  
 
OIG oversight  of HHS programs ensures integrity, effectiveness, and efficiency.   For the 
Assessing 
first half of FY 2018,  OIG  reported expected recoveries of $187.5  million and $1.5 billion  
Mismanagement 
in potential savings, which includes findings related to Improper Claims for  Managed  
and Abuse in   Long-Term Care and Improper Electronic Health Records Incentive Payments.  
HHS  Programs    
Highlights of 
Accomplishments  
 
The following examples highlight two  OIG  audits  that identified  significant  potential  
overpayments  during this semiannual reporting period.  
 
Services related to the replacement of  five recalled and prematurely failed  medical  
devices cost Medicare $7.7 million.   OIG found that all 296 payments reviewed for  
recalled cardiac medical devices with potential overpayments of $4.4 million  did not 
comply with Medicare requirements for reporting manufacturer credits.  (See report at  A-
05-16-00059.)    
 
Many Medicare claims for outpatient physical therapy services did not comply with 
Medicare requirements.   Sixty-one percent of  Medicare claims for outpatient physical  
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  Department of Health and Human Services Office of Inspector General 
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018
 
 
therapy services did not comply with Medicare medical necessity, coding, or 
documentation requirements.  (See report at A-05-14-00041.) 
 
Combatting the  Addressing the opioid abuse epidemic is a top priority for OIG.  OIG has a longstanding 
and extensive history of investigative and oversight work focused on the national 
Opioid Epidemic 
epidemic of prescription drug abuse, including opioid abuse.  We investigate opioid 
fraud and diversion cases and use advanced data analytics and tools to detect suspected 
problems for further review.  Our work also focuses on strengthening the integrity of 
HHS prescription drug and addiction treatment programs and protecting at-risk 
beneficiaries.  Significant OIG work during this semiannual reporting period includes 
the following. 
 
Our partnership with the Attorney General, Federal Bureau of Investigations (FBI), and 
the Drug Enforcement Administration on the Opioid Fraud and Abuse Detection Unit has 
led to positive outcomes.  The Unit focuses on opioid-related health care fraud using 
data to identify and prosecute individuals who are contributing to the prescription 
opioid epidemic.  This collaboration led to the selection of 12 judicial districts around the 
country where OIG has assigned Special Agents to support 12 prosecutors identified by 
DOJ to focus solely on investigating and prosecuting opioid-related health care fraud 
cases. 
 
Co-conspirators were convicted of charges resulting from their involvement in an 
unlawful prescription drug operation.  The defendantsphysician Dr. Rodney Moret and 
patient recruiter Kamani Jacobsconspired to operate a fraudulent medical practice with 
Advance Care Services.  Patient recruiters were found bringing patients to the clinic to 
obtain medically unnecessary prescriptions for controlled substances.  Dr. Moret was 
responsible for illegally distributing over 700,000 dosage units of Hydrocodone, more 
than 240,000 dosage units of Alprazolam, and more than 2 million milliliters of 
promethazine with codeine cough syrup, worth more than $15 million in the black 
market. 
 
A Kentucky pharmacist was convicted on 71 counts and excluded for 50 years from 
Medicare and Medicaid for illegally dispensing controlled substances.  Lonnie Hubbard 
sold prescription pain pills without a legitimate medical purpose, and sold 
pseudoephedrine, knowing or having reason to believe that it was being used to 
manufacture methamphetamine.  A jury convicted Hubbard on 71 counts involving the 
illegal dispensing of oxycodone, hydrocodone, and pseudoephedrine, and sentenced 
him to 30 years in prison. 
   
Protecting  HHS programs provide critical health and human services to many vulnerable 
populations, including adults and children in foster care and individuals receiving care in 
Vulnerable 
group home settings.  OIG helps ensure that these individuals have access to and receive 
Populations 
high-quality services and are protected from abuse or neglect.  Significant OIG work 
during this semiannual reporting period includes the following.  
 
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
Group homes for children in foster care did not always comply with State health and  
safety requirements.   OIG found that in Massachusetts, Ohio, and Washington, the 
States monitoring did not ensure that the group homes complied with State 
requirements related to the health and safety of children in foster care.  (See reports on 
Massachusetts at A-01-16-02500, Ohio at  A-05-16-00049,  and Washington  at A-09-16-
01006.)  
 
Minnesota did not comply with Federal requirements in family adult foster care homes.   
Of the 131 homes in Minnesota where vulnerable adults resided, we selected 20 homes  
for review. Eighteen of the 20 homes did not comply with 1 or more State licensing 
requirements.  Specifically, we found  64 instances of noncompliance related to health 
and safety and administrative requirements.  (See report at  A-05-16-00044.)  
 
OIG and partners produced a portfolio report highlighting vulnerabilities in group home 
settings.   Addressing troubling findings from OIG that found that residents of group 
homes often experienced serious injuries and medical conditions that resulted in  
emergency room visits,  we gathered together expertise on this issue from across HHS, as  
well as from the Department of Justice and State stakeholders, to create a joint portfolio 
report.  The report contains workable, holistic solutions that States can use to protect the 
health and safety of their residents living in group homes.   (See report at  Joint Report  
Portfolio.)  
 
Preventing and detecting fraud and abuse in Medicare is vital to safeguarding health 
Enhancing 
care resources and protecting beneficiaries.   Home- and community-based services,  
Program 
including  home health care  and hospice services, can be particularly susceptible to fraud  
Integrity in 
and abuse.  OIG, along with our law enforcement  partners, focuses specific attention on 
Home- and  
investigating suspected fraud committed by these  providers  and in assessing and  
Community- recommending safeguards to protect taxpayers and beneficiaries.   Significant OIG work  
Based Services   during this semiannual period includes the following.  
 
The Nations largest for-profit provider of hospice services  entered into a settlement  
agreement to resolve allegations that  it submitted false claims to Medicare.   Defendants  
from VITAS Hospice Services allegedly submitted false claims to Medicare for services  
provided to patients who were ineligible for hospice benefits, and continuous home care 
services that were not medically necessary, not provided, or not performed in  
accordance with Medicare requirements.  VITAS Hospice Services agreed to pay  $75.5 
million to resolve their FCA liability, and entered into a 5-year  CIA. 
 
A home- and  community-based services  agency settled for $6 million and  a 5-year  CIA  
to resolve allegations that it knowingly caused false claims to be submitted to Medicare.   
Catholic Health System, Inc., allegedly  submitted, or caused to be submitted, false claims  
to Medicare for rehabilitation therapy services that were unreasonable, medically 
unnecessary, and unsupported by the medical records.  
 
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
Home health agencies  might  manipulate patient lists to avoid scrutiny from home health 
surveyors.   Home health surveyors rely on lists supplied by home health agencies to  
select patients for review, which creates a vulnerability because home health agencies  
could conceal fraudulent activity or health and safety violations by omitting patients  
from those lists.  Some lists we reviewed were indeed missing Medicare beneficiaries.   
(See report at  OEI-05-16-00510.)  
 
Protecting the  Protecting the integrity of Medicaid is another  key focus area in OIGs goal  to fight fraud,  
waste, and abuse.   We make recommendations to CMS and  States to correct problems  
Integrity of the 
and mitigate program risks, and we work closely  with State MFCUs to combat Medicaid 
Medicaid 
fraud.  Highlights of  OIGs work during this reporting period include the following. 
Program   
  
California and New York  did not correctly determine Medicaid eligibility for newly 
eligible beneficiaries.   OIG estimated that California made Medicaid payments of $738.2 
million ($628.8 million Federal share)  on behalf of  366,078 ineligible beneficiaries.  These 
deficiencies occurred because Californias eligibility determination systems  lacked the 
necessary system functionality and eligibility caseworkers made errors.   New York did not 
always determine  Medicaid eligibility for newly eligible beneficiaries in accordance with 
Federal and State requirements.   OIG estimated that New York made Federal Medicaid 
payments  of $26.2 million on behalf of 47,271 ineligible beneficiaries. (See reports on 
California  at A-09-16-02023  and New York  at  A-02-15-01015.)  
 
New Jersey did not  follow Federal  regulations and CMS guidance when it  developed its  
payment rates for  Medicaid school-based services.  As a result, the State claimed $300.5  
million in unallowable costs.   New Jersey claimed  an additional $306.2 million in  
reimbursement using payment rates  developed with unsupported costs.  (See report  at  
A-02-15-01010.)  
 
Assessing  OIG has a long history of assessing  prescription drug  payment policies  and procedures 
across HHS programs, including  Medicare Parts  B and D,  Medicaid, and the 340B  Drug 
Prescription 
Discount Program.  Our  work in this area has identified opportunities for  substantial cost  
Drug Payment 
savings, risks and instances in  which  HHS programs  have not obtained discounts to  
Policies and  
which they were entitled  by law, and has also resulted in CIAs to resolve fraud  
Procedures   allegations.   Examples from this reporting period  include the following. 
     
Potential misclassifications reported by drug manufacturers may have  led to $1  billion in  
lost Medicaid rebates.   OIG found that drug manufacturers may have misclassified 3  
percent of drugs in the Medicaid Drug Rebate Program (rebate program).  These 
potential misclassifications may have led to $1.3  billion in lost Medicaid rebates and  
demonstrate the opportunity for CMS to improve its oversight of classification data in 
the rebate program.  (See report at  OEI-03-17-00100.)  
 
OIG identified vulnerabilities in Arkansas  and Arizonas handling of physician-
administered drugs and the associated Medicaid rebates.   Arkansas did not invoice 
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
manufacturers  for rebates associated with $9.9 million (Federal share) in physician-
administered drugs.   Arkansas improperly  claimed Federal reimbursement for single-
source drugs and top-20 multiple-source drugs and did not submit the utilization data  
necessary to secure rebates for all other physician-administered drug claims totaling $1.4  
million (Federal share).  Arizona did not bill for and collect from manufacturers estimated  
rebates of  $36.7 million ($25.6 million Federal share) for physician-administered 
drugs.   Arizona did not  always bill for and collect from manufacturers rebates because it  
did not have a system edit to  ensure that National Drug Codes (NDCs) or valid NDCs 
were submitted for physician-administered drugs  before October 1,  2012.   (See reports  
at A-06-16-00018  and at A-09-16-02031.)  
 
Ensuring Food  Among other responsibilities,  FDA has the continuing challenge of ensuring the safety  
and security of  most of our Nations foods.  The Centers for  Disease Control and  
Safety   
Prevention estimates  that each year roughly  48 million people get sick from a foodborne 
illness, 128,000 are hospitalized,  and 3,000 die.   An  effective process for recalling  harmful  
food products is paramount to health and safety.   In 2011, Congress granted FDA the 
authority to require firms to recall certain harmful foods.    
 
FDAs food-recall process did  not always  ensure the safety  of the Nations food  supply.   
This report reiterated and expanded findings from an August 2016 Early  Alert.  We found  
that from 2012 to  2015,  FDA could not always ensure that firms initiated recalls promptly.  
We identified deficiencies in  FDAs oversight of recall initiation, monitoring of recalls, and  
the recall information captured and maintained in FDAs electronic recall data system.   
(See report  at  A-01-16-01502.)   
 
Identifying  Data management, use,  and security are essential to the effective and efficient operation 
of HHS and its programs.  As HHS works to leverage the power of data, the Department  
Cybersecurity 
will maintain and use expanding amounts of sensitive data.  So, too, will individuals and  
Risks  
entitiessuch as States, contractors, providers, grant recipients, and beneficiaries 
involved in delivering or receiving benefits from the many HHS programs.  Cybersecurity  
incidents and breaches pose a significant risk to the availability of sensitive data.  OIG is  
determined to identify cybersecurity risks within the Department.  
 
Security across four HHS  OPDIVs needs improvement to more effectively detect and  
prevent cyberattacks.   We conducted a series of  OIG audits at four HHS OPDIVs using 
network and web application penetration testing to determine how well HHS systems  
were protected when subject to cyberattacks.   Security controls across the four HHS  
OPDIVs needed improvement to more effectively  detect and  prevent certain 
cyberattacks.   During testing, we identified configuration management and access  
control vulnerabilities.  (See report  A-18-17-08500.)  
   
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
 
OIG  Participation  in  Congressional  Hearings  
 
 
10/31/2017   
Testimony of  James A. Cannatti III, Senior Counselor for Health 
Information Technology,  Office of Inspector General, U.S. Department  
of Health and Human Services: Senate Committee on Health,  
Education, Labor, and  Pensions: Implementation of the 21st Century  
Cures Act: Achieving the Promise of Health Information Technology  
(See testimony  here.)  
 
  
 
 
 
01/17/2018   
Testimony of Gary Cantrell, Deputy Inspector General for  
Investigations, Office of Investigations, Office of Inspector General,  
Department of Health and Human Services: House Committee on Ways  
and Means, Subcommittee on Oversight: The Opioid Crisis: The Current  
Landscape and CMS Actions to Prevent Opioid Misuse  (See testimony  
here.)  
 
 
 
 
 
01/19/2018   
Testimony of Gloria Jarmon, Deputy Inspector General for Audit  
Services, Department of  Health and Human Services: House Committee 
on Energy and Commerce, Subcommittee on Oversight and  
Investigations: Safety of the U.S. Food  Supply:  Continuing Concerns  
Over the Food and Drug Administration's Food-Recall Process  (See 
testimony  here.)  
   
 
  
 
 
   
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
 
Selected  Acronyms and Abbreviations  
 
ACA   Patient Protection and Affordable Care Act  
ACF   Administration for Children and Families  
ACL   Administration for  Community Living  
ACO   Accountable Care Organizations  
CY   calendar year  
CDC   Centers for  Disease Control and Prevention  
CIA   corporate integrity agreement  
CMP   civil monetary penalty  
CMS   Centers for  Medicare &  Medicaid Services  
DOJ   Department of Justice  
EHR   electronic health records  
EMTALA   Emergency  Medical Treatment and Labor Act  
FCA   False Claims Act  
FDA   Food and Drug Administration  
FY   fiscal year  
GAO   Government Accountability Office  
HCBS   home- and community-based services  
HHS   Department of Health and Human Services  
HIPAA   Health Insurance Portability and Accountability Act of 1996  
HRSA   Health Resources and Services Administration  
IHS   Indian Health Service  
IT   information technology  
MAC   Medicare  Administrative Contractor  
MCO   managed care organization  
MFCU   Medicaid Fraud Control  Unit  
NIH   National Institutes of Health  
OAS   Office of Audit Services  
OCIG   Office  of  Counsel  to  the  Inspector  General  
OEI   Office of Evaluation and Inspections  
OI   Office of Investigations  
OIG   Office of Inspector General  
PCS   personal care services  
SAMHSA   Substance Abuse and  Mental Health Services Administration  
SNF   skilled nursing facility  
11  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
Centers  for Medicare & Medicaid Services   
 
Medicare  Program  Reports  and  Reviews  
Financial Management and Improper  Payments  
 
CMSs Policies and Procedures Were Generally  Effective in Ensuring That Capitation Payments Were Not Made 
After Beneficiaries Dates of Death  (A-07-16-05087),  October 2017  
CMS had policies and procedures in  place that were generally effective in ensuring that capitation payments to  
Medicare Advantage (MA) organizations for Medicare Parts A and  B services were not made on behalf of  
deceased beneficiaries after the individuals dates of death.   During calendar  years (CY)  2012 through 2015,  
CMS received updated beneficiary date-of-death information and then made approximately  1.8 million 
adjustments to capitation payments, thereby recouping $2.96 billion from MA organizations for Parts A and B  
capitation payments that had been made on behalf of beneficiaries who had died.   
CMS did not, however, identify and recoup all improper capitation payments.   As of March  7, 2017,  CMS had  
not recouped $2.4 million associated with 1,817 capitation payments that  were made on behalf of  978  
beneficiaries.   For our  audit period, these improper payments represented .0004 percent of the total capitation 
payments made to MA organizations and .08 percent of the total adjustments that CMS made after receiving  
information on beneficiaries dates of  death.  
CMS concurred with our  recommendations that it  recoup the $2.4 million in capitation payments  made to MA  
organizations for  Medicare Parts A and  B services on behalf of deceased beneficiaries and that it implement  
system enhancements to identify, adjust, and recoup improper capitation payments in the future.     
CMS Generally Met  Requirements in Round 2 of the DMEPOS Competitive Bidding Program  (A-05-14-00049),  
November 2017  
CMS usually selected Durable Medical Equipment  Prosthetics, Orthotics, and Supplies (DMEPOS) suppliers,  
calculated the sampled DMEPOS single-payment amounts (SPAs), and monitored suppliers in accordance with 
its established procedures and applicable Federal requirements.   We determined that CMS consistently 
followed its established program procedures and applicable Federal requirements for 192 of the 215 winning  
suppliers associated with the sampled SPAs reviewed.  
While the overall effect on Medicare payments to  suppliers was relatively small, we determined that CMS did  
not consistently follow its established procedures and applicable Federal requirements for selecting suppliers  
during the bid process for 23 of the 215 winning suppliers.   This affected 99 of  the 240 sampled SPAs.  On the 
basis of our sample, we estimated that CMS paid suppliers $182,000 less than they would have received  
without any errors, or less than 0.03 percent of the $553.7 million paid under Round 2 during the last 6 months  
of 2013.  
12  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
CMS concurred with our  recommendations that it  (1) follow its established program procedures and applicable 
Federal requirements consistently in evaluating the financial documents of all suppliers; (2) ensure that  
suppliers have the applicable licenses for the specific competitions in which they are submitting a bid by  
continuing to work with State licensing boards; and (3) monitor supplier licensure requirements by  
implementing a system to identify and address potential unlicensed suppliers.   
CMS Did Not Adequately  Address Discrepancies in the Coding Classification  for Kwashiorkor  (A-03-14-00010),  
November 2017  
Providers incorrectly billed diagnosis code 260 for Kwashiorkor for inpatients who did not have the disease.  In 
separately issued reports, we reviewed the medical records for a total of 2,145 inpatient claims at  25  providers  
and found that all but 1  claim incorrectly included the diagnosis code for  Kwashiorkor, resulting in 
overpayments in excess of $6 million.   
The ICD-9 coding classification contained a discrepancy between the tabular list and the alpha index on the use 
of diagnosis code 260, which may have resulted in other diseases being assigned this code.   CMS did not have 
adequate policies and procedures in place to address this discrepancy, resulting in a total potential loss of  
approximately $102 million during CYs  2006 through 2014.   Even though CMS was  aware of the discrepancy, it  
did not take any separate action to address it.   While our previous reviews successfully returned $5.7 million to  
the Medicare Trust Fund, we estimate that Medicare could have saved approximately $102 million from CYs  
2006 through 2014 if the coding discrepancy had  been immediately corrected.   
 
CMS concurred with our  recommendations that it  (1) review provider Medicare claims to ensure that the 
diagnosis code for Kwashiorkor is being used correctly by providers  and (2) formalize procedures for notifying 
providers of the correct  way to bill diagnosis codes when there is a discrepancy in the coding classification.   
The 25 hospitals that we reviewed repaid $5.7 million in overpayments. All of the providers stopped incorrectly  
using diagnosis code 260.   
Wisconsin Physicians Service Paid Providers for Hyperbaric Oxygen Therapy Services That Did Not  Comply With  
Medicare Requirements  (A-01-15-00515),  February 2018  
Hyperbaric oxygen  (HBO)  therapy involves giving a patient high concentrations of oxygen within a pressurized  
chamber in which the patient intermittently breathes in 100-percent oxygen. Wisconsin Physicians Service 
(WPS) paid  73 providers  for HBO therapy services  that did not comply with Medicare requirements.   WPS made 
payments  for HBO therapy that did not always comply with Medicare requirements because it had limited  
policies and procedures in place to ensure that it made correct payments.   On the basis of our sample results,  
we estimate that WPS  overpaid providers in Jurisdiction 5 $42.6 million during the audit period for  HBO  
therapy that did not comply with Medicare requirements.  
WPS generally agreed with our recommendations that it (1) recover the appropriate portion of the  $300,789 in  
identified Medicare overpayments;  (2) notify the providers responsible for the 44,820 nonsampled  claims, with 
potential overpayments  estimated at $42.3 million, so that those providers can investigate and return any  
identified  overpayments; (3) identify and recover  any improper payments for HBO therapy made after the audit  
period; and (4) strengthen its policies and procedures for making payments for HBO therapy, which would  
result in millions in future cost savings.   
13  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
 
Medicare Improperly Paid Providers for Specimen Validity Tests Billed in Combination With Urine Drug Tests  (A-
09-16-02034),  February 2018  
 
Medicare improperly paid 4,480 clinical laboratories and physician offices a total of $66.3 million for  specimen  
validity tests billed in combination with urine drug tests.   CMS officials explained that medically necessary tests  
used to diagnose certain conditions (which include the same tests that can be used to validate urine 
specimens) that are performed on the same day  as a urine drug test for a  single beneficiary should be a rare 
occurrence.   
 
The improper payments  occurred because providers did not follow existing Medicare guidance, and CMSs  
system edits were not adequate to prevent payment for specimen validity tests billed in combination with urine 
drug tests.   Although CMS implemented a system  edit designed to identify and prevent these improper  
payments, we still identified $1.8 million in improper payments  from April 1 through December  31, 2016.   At  
this observed rate, these improper payments would total $12.1 million over a 5-year period.   
 
CMS concurred with our  recommendations that it  (1) direct the Medicare contractors to recover the $66.3  
million in identified improper payments and (2) strengthen its system edits to prevent improper payments for  
specimen validity tests and instruct the Medicare contractors to educate providers on properly billing for  
specimen validity and urine drug tests, which could result in savings of an estimated $12.1 million over a 5-year  
period.   
 
Many Medicare Claims for Outpatient Physical Therapy Services Did Not Comply With Medicare Requirements  (A-
05-14-00041),  March 2018  
 
Sixty-one percent of Medicare claims for outpatient physical therapy services that we reviewed did  not comply  
with Medicare medical necessity, coding, or documentation requirements.  Specifically, of the 300 claims in our  
stratified random sample, therapists claimed $12,741 in Medicare reimbursement on 184 claims that did not  
comply with Medicare requirements.  Therapists properly claimed Medicare reimbursement on the remaining  
116 claims.    
 
On the basis of our sample results, we estimated that during the 6-month audit period, Medicare paid $367  
million for outpatient physical therapy services that did not comply with Medicare requirements.  These 
overpayments occurred  because CMSs controls  were not effective in preventing improper payments for  
outpatient physical therapy services.  
 
CMS partly agreed and partly disagreed with our recommendations that it (1) instruct the Medicare  
Administrative Contractors to notify providers of  potential overpayments so that those providers can exercise 
reasonable diligence to investigate and return any identified overpayments, (2) establish mechanisms to better  
monitor the appropriateness of outpatient physical therapy claims, and (3) educate providers about Medicare 
requirements for submitting outpatient physical therapy claims for reimbursement.  
 
Hospitals Did Not Comply With Medicare Requirements for Reporting  Certain Cardiac Device Credits   
(A-05-16-00059),  March 2018  
 
14  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
All 296 payments reviewed for recalled cardiac medical devices did not comply with Medicare requirements for  
reporting manufacturer credits.  Medicare contractors incorrectly paid hospitals $7.7 million for cardiac device 
replacement claims rather than the $3.3 million they should have been paid, resulting in potential  
overpayments of  $4.4 million.  For all  payments reviewed,  manufacturers  issued  reportable credits  to hospitals  
for  recalled cardiac medical  devices,  but the hospitals did not  adjust  the  claims  with the  proper  condition  codes,  
value  codes,  or modifiers to reduce payment as required.  The overpayments occurred because Medicare 
controls were not sufficient to ensure that  hospitals properly reported manufacturer credits for cardiac devices.   
 
CMS generally  concurred  with our recommendations that it instruct its Medicare contractors to notify the 210  
hospitals associated with the identified overpayments;  educate providers on the requirements for  reporting 
manufacturer credits;  and  consider studying alternatives to implementing edits in order to eliminate the current  
Medicare requirements for reporting device credits.  CMS did not concur  with our recommendation that it  
instruct its Medicare contractors to implement a postpayment process to follow up with hospitals that submit  
claims for certain cardiac device replacements. 
 
Excluding Non-Covered Versions When  Setting Payment for Two Part  B Drugs Would Have Resulted in Lower  
Drug Costs for Medicare and its Beneficiaries  (OEI-12-17-00260), November 2017  
 
OIG found that CMS and  a Federal court interpret  the law to require the inclusion of average sales prices (ASPs)  
for noncovered versions in limited circumstances  when setting payment amounts for  Part  B drugs.  As a result,  
the inclusion of noncovered versions of  two drugs  caused Medicare and its  beneficiaries to pay  an extra $366  
million from 2014 through 2016.    
 
OIG recommended that CMS seek a legislative change that would provide the agency flexibility to determine 
when noncovered versions of a drug should be included in Part B payment amount calculations.  CMS did not  
concur with our recommendation.   
Quality of Care, Safety, and Access  
 
Followup Review: CMSs Management of the Quality Payment Program  (OEI-12-17-00350), December 2017  
 
CMS continued its progress toward implementing the Quality Payment  Program (QPP),  a set of clinician 
payment reforms designed to put increased focus on the quality and value of care.   During  2017, CMS made 
significant efforts to address the two vulnerabilities that OIG identified in its 2016 management review 
developing IT systems and preparing clinicians to participate in the QPP.  CMS appears on track to deploy the 
IT systems needed for data submission by  January 1, 2018. With regard to  clinician readiness, CMS  has  
conducted outreach, communicated eligibility information, issued subregulatory guidance, awarded technical  
assistance contracts, and  established a Service Center to respond to questions. Clinician feedback  
demonstrates widespread awareness of the QPP,  but also uncertainty  about eligibility, data submission, and  
other elements of the program. With regard to emerging challenges, we found that CMS has not yet 
developed a comprehensive program integrity plan.  OIG has identified two vulnerabilities that are critical for  
CMS to  address in 2018:  (1) if clinicians do not receive sufficient technical assistance, they may struggle to  
succeed under the QPP or choose not to participate, and (2) if CMS does not develop and implement a  
comprehensive QPP program integrity plan, the program will be at greater risk of fraud and improper  
payments.   
15  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
Program Integrity  
CMS Ensured That Medicare Shared Savings Program Beneficiaries Were Properly Assigned: Beneficiaries Were 
Assigned  to Only One Accountable Care Organization and Were Not Assigned to Other Shared Savings Programs  
(A-09-17-03010), October  2017  
The Patient Protection and Affordable Care Act  (ACA)  established the Medicare Shared Savings Program  
(MSSP) to facilitate coordination and cooperation among providers  and suppliers to (1) improve quality of care 
for  Medicare fee-for-service beneficiaries and (2) reduce health care costs.   Eligible providers and suppliers may  
voluntarily participate in the MSSP by creating or joining an accountable care organization (ACO).   Beneficiary  
assignment is the basis for many  key  MSSP operations, such as determining an ACOs financial performance 
and reporting quality measures after each performance year.   The designated ACO is responsible for the quality  
and cost of care of its assigned Medicare beneficiaries during a performance year.   ACOs may be eligible to  
receive additional payments (i.e., shared savings payments) if they reduce health care costs and meet certain 
quality performance standards.   ACOs may also be responsible for a portion of any shared losses.  
CMS complied with Federal requirements when assigning beneficiaries to ACOs in the MSSP during 
Performance Years 2013  through 2015 by ensuring that MSSP beneficiaries were assigned to only  one ACO and  
were not assigned to other savings programs.   Consequently, this report contained no recommendations.   
Medicare Needs Better Controls To Prevent Fraud, Waste, and Abuse Related to Chiropractic Services  (A-09-16-
02042),  February 2018  
This portfolio presents  an overview of program vulnerabilities identified in prior OIG audits, evaluations,  
investigations, and legal  actions related to chiropractic services in the Medicare Program.   It consolidates the  
findings and issues identified in that work and discusses recommendations  from prior reports that have not  
been implemented or have been implemented ineffectively.   In addition, this portfolio provides information to  
help CMS understand the need for effective controls over chiropractic services.  
CMS  partly agreed and partly disagreed with our recommendations that it implement the recommendations  
from prior OIG reports that were not implemented or were ineffectively implemented; work with its contractors  
to educate chiropractors  on the training materials  that are available to them; educate beneficiaries on the types  
of chiropractic services that are covered by Medicare; identify chiropractors with aberrant billing patterns or  
high service-denial rates, review a sample of their  services,  review  the medical records for the sampled service,  
estimate the amount overpaid, and request that the chiropractors refund the overpayments; and establish a  
threshold for the number of chiropractic services beyond which medical review would be required for  
additional services.  
 
Medicare Advantage Encounter Data Show Promise for Program Oversight,  but Improvements Are Needed  (OEI-
03-15-00060), January 2018  
 
CMS collects detailed information from  MA  organizations regarding each service provided to beneficiaries in 
the  MA  program.  This information is known as  MA encounter data.  
 
16  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
Overall, 28 percent of MA encounter records that we reviewed from the first quarter of  2014 had at least  
1  potential error, but CMS reported correcting the majority of these records.   With CMSs subsequent  
correction, only 5 percent of the records in our review would contain a potential error.  Some of these errors  
may raise concerns  about the legitimacy of services documented in the data, such as records that lacked  
a  beneficiary last name or a valid identifier for the billing provider.  Only a few MA  organizations  submitted half  
of the encounter records that had a potential error.  CMS does not require MA  organizations  to submit certain  
provider identifiers used  in program integrity reviews, and these were frequently absent from encounter data.  
Furthermore, CMS has not tracked how MA  organizations  responded to edits that reject data, i.e., reject edits,  
nor has it  established performance measures to monitor MA  organizations  submission of records with missing  
or invalid data.   
   
CMS concurred with our  recommendations to  (1)  take actions as  appropriate to address potential errors in the 
MA encounter data;  (2)  provide targeted oversight of MA  organizations  that submitted a higher percentage of  
encounter records with potential errors;  (3)  ensure that billing provider identifiers are valid and active on all  
records in the MA encounter data; and  (4)  establish and monitor  MA encounter data performance thresholds  
related to MA  organizations submission of records with complete and valid data.   
   
CMS did not concur with our recommendations to  (1)  require MA  organizations  to submit ordering and 
referring provider identifiers for applicable records;  (2)  ensure that MA  organizations  submit rendering provider  
identifiers for applicable records; and  (3)  track MA  organizations response to reject edits.   
   
Reliance on Unverified Patient Lists Creates a Vulnerability in Home Health  Surveys  (OEI-05-16-00510), March  
2018  
 
In our review, we found that some patient lists supplied by home health agencies  (HHAs)  were missing  
Medicare beneficiaries, allowing them to be excluded from surveyor inspections.   We also found that surveyors  
cannot comprehensively  verify that HHA-supplied patient lists are complete at the time they conduct their  
surveys.   While our analysis does not demonstrate that these providers were engaged in fraudulent  activity, it  
does illustrate a vulnerability that  HHAs  could exploit to conceal fraudulent  activity or health and safety  
violations.  However, existing data sources may be useful tools for both surveyors  and CMS.   OIG encourages  
CMS to explore actions to mitigate this vulnerability.   
 
CMS Ensured Nearly All Part D Drug Records Contained  Valid Prescriber Identifiers in 2016  (OEI-03-17-00040),  
October 2017  
   
Nearly all prescription drug event (PDE) records for Part  D drug claims in 2016 contained valid prescriber 
National  Provider Identifiers (NPIs).   Prescriber identifiers are a valuable program integrity safeguard as they  
enable CMS and  Part  D plan sponsors to determine if legitimate practitioners have prescribed drugs  for  
enrollees.  The Medicare Access and  the Childrens Health Insurance Program  (CHIP)  Reauthorization Act of  
2015 requires that, beginning in 2016, pharmacy claims for covered Part D  drugs must contain valid prescriber  
NPIs.  Additionally, the law requires the Secretary  of Health and Human Services to establish procedures for  
determining the validity of these prescriber NPIs and requires OIG to submit to Congress a report on the 
effectiveness of these procedures no later than January  1, 2018.  This evaluation report fulfills OIGs mandate  
under the CHIP Reauthorization  Act.  Our report concludes that the system edits that CMS currently  has in 
place to check PDE records are effective in ensuring the validity of the vast majority of  Part  D prescriber NPIs.  
17  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
 
Review of the Department of Health and Human Services (HHS) Cancellation of Marketplace Enrollment  
Outreach  Efforts  (OEI-12-17-00290), October 2017  
 
In response to a congressional request, OIG conducted a descriptive, fact-finding review of HHSs cancellation 
of certain Marketplace enrollment outreach activities (outreach  activities) before the January 31st  end of the 
fourth open enrollment period.  
 
OIG determined that HHS canceled and then reinstated certain outreach activities on January  26  and 27,  2017.   
An official on  the HHS Beachhead Team orally instructed HHS officials to cancel Marketplace outreach, and that  
same official later provided updated instructions about which outreach should remain canceled and which 
should resume.   However, we were unable to determine conclusively whether that individual made the decision 
to cancel outreach or merely conveyed the decisions made by someone else.  In addition, HHS officials  
conducted a preliminary  assessment of costs  and  savings associated with canceling certain outreach activities,  
but reported that they did not perform any analyses of the impact that canceling outreach activities  would  
have on Marketplace enrollment.   
 
Medicaid Program  Reports  and  Reviews  
Financial Management and Improper  Payments  
 
Ohio Received Millions in Unallowable Bonus Payments  (A-04-16-08049), November 2017   
Kansas Received Millions in Unallowable Bonus Payments  (A-04-16-08050),  November 2017  
 
Under the CHIP  Reauthorization Act of 2009, States receive bonus payments to offset the costs of increased  
enrollment of children in Medicaid.   These two reports are part of a series of reviews that OIG conducted to  
determine  whether these bonus payments were allowable.  
 
Both Ohio and Kansas overstated their current enrollment in their bonus requests to CMS because they  
included individuals who did not qualify because of their basis-of-eligibility category.  As a result of the  States  
overstated enrollment numbers, CMS overpaid Ohio $29.5 million and Kansas $17.8 million in bonus payments.   
Ohio and Kansas did not  concur with our findings or our recommendations to refund the excess payments.   
 
North Carolina Did Not  Comply With  Federal and State Requirements When  Making Medicaid Cost-Sharing  
Payments for Professional Medical Services  (A-04-16-04054),  November 2017  
 
States must make medical assistance available  for Medicare deductibles, coinsurance, and copayments (cost-
sharing) for certain individuals who are dually eligible to be enrolled in both Medicare and  Medicaid.  In North 
Carolina,  Medicaid is required to make cost-sharing payments  at the lesser of the cost-sharing amount or the 
Medicaid allowable payment.   
 
North Carolina did not comply with Federal and State requirements when making Medicaid cost-sharing  
payments  for professional medical services.  On the basis of our sample results, we estimated that North  
Carolina made  at least $63 million in improper Medicaid cost-sharing payments and claimed Federal  
18  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
reimbursement of at least $41.2 million for these payments.   These improper payments  occurred because 
North Carolina did not program its Medicaid Management Information System (MMIS) to calculate Medicaid  
cost-sharing payments for professional medical services in accordance with the States required cost-sharing 
payment methodology.   
 
North Carolina replaced its MMIS after our  audit period.   We reviewed a  limited number of cost-sharing  
payments made after  our audit period and verified that North Carolinas replacement MMIS calculated  
payments in compliance with the States required cost-sharing payment methodology.  
 
North Carolina disagreed with our findings and recommendations that it (1) refund $41.2 million to  the Federal  
Government for cost-sharing payments  for professional medical services that did not comply with Federal and  
State requirements, and (2) ensure that future changes to Medicaid payment methodologies comply with the 
Medicaid State plan.    
 
New Jersey Claimed Hundreds of Millions in Unallowable or Unsupported Medicaid School-Based Reimbursement  
(A-02-15-01010), November 2017  
 
New Jersey did not  follow Federal regulations and CMS guidance when it  developed its payment rates for  
Medicaid school-based services and, as a result, claimed $300.5 million in unallowable costs.   New Jersey  
claimed an additional $306.2 million in reimbursement using payment rates developed with unsupported costs.  
 
Among our findings, we determined that (1) New  Jerseys contractor changed school employees responses to  
timestudies  to indicate that their activities were directly related to providing Medicaid services when the 
responses indicated the activities were unrelated;  (2)  New Jersey improperly incorporated into its payment  
rates more than $400 million owed to the school employees pension fund despite not having made scheduled  
payments to the fund  in nearly 20 years; and (3) salaries of some employees who did not provide health-
related services were incorporated into the payment rates. In addition, New Jersey did not maintain 
documentation related to the timestudies, which it used to identify the percentage of time personnel provided  
particular services.  
 
New Jersey disagreed with our findings and recommendations that it  (1)  refund $300.5 million in Federal 
Medicaid reimbursement  that it claimed based on payment rates that incorporated unallowable costs; (2)  work  
with CMS to determine the allowable amount of the remaining $306.2 million claimed for Federal  Medicaid  
reimbursement; and (3)  revise its payment rates so  it complies  with Federal requirements.  
  
Texas Did Not Appropriately  Spend Some State Balancing Incentive Payments Program Funds  (A-06-15-00041),  
December 2017  
 
Texas appropriately spent $272.4 million of the $284.4 million in Balancing  Incentive Payments  Program (BIPP)  
funds it received.   Of the remaining $12 million, Texas inappropriately spent $6.3 million for medical service  
rate increases that did not benefit Medicaid recipients and did not spend $5.7 million in BIPP funds  before the 
end of the funding period.  Additionally, Texas did not separately track BIPP  funds or follow CMS instructions  
for extending the funding period.   
 
19  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
Texas did not indicate concurrence or nonconcurrence with our recommendations that it refund  $12 million in 
BIPP  funds that did not benefit Medicaid recipients or that were not spent  before the end of the funding  
period.   Additionally, we recommended that, for  future grant programs, Texas separately track funds to ensure 
(1)  the funds are not used in violation of applicable statutory restrictions or prohibitions and (2) all grant  
procedures and requirements are met, such as following instructions for extending funding periods.  
  
New York Did Not  Correctly Determine Medicaid Eligibility for Some Newly Enrolled Beneficiaries  (A-02-15-
01015),  January 2018  
 
New York did not always  determine Medicaid eligibility for newly eligible beneficiaries in accordance with 
Federal and State requirements.   In our sample of  130 beneficiaries, New York correctly determined  eligibility  
for 90 beneficiaries.   However, it did not determine eligibility for 37 beneficiaries in accordance with Federal  
and State requirements  and did not provide supporting documentation to  verify beneficiaries were newly 
eligible for the remaining 4 potentially ineligible beneficiaries.   The total exceeds 130 because 1 beneficiary was  
found to be ineligible for one determination period and found to be potentially ineligible for another  
determination period.   On the basis of our sample results, we estimated that New York made Federal Medicaid  
payments  of $26.2 million on behalf of 47,271 ineligible beneficiaries.  
 
New York disagreed with our recommendations that it (1) redetermine, as  appropriate, the current Medicaid  
eligibility status of the sample beneficiaries and (2) improve the design of its enrollment system to ensure that 
it maintains applications, verifies income and citizenship eligibility data, and determines eligibility by using 
available electronic data  sources, as appropriate.   
 
California Made Medicaid Payments on Behalf of Newly Eligible Beneficiaries Who Did Not Meet Federal and  
State Requirements  (A-09-16-02023), February 2018  
 
For our sample of 150 beneficiaries who were newly eligible for Medicaid, California made Medicaid payments  
on behalf of 112.   However, for the remaining  38  beneficiaries, California made payments on behalf of ineligible 
beneficiaries (e.g., a woman who did not meet eligibility requirements for the newly eligible group because she 
was pregnant)  and potentially ineligible beneficiaries (e.g., a beneficiary who may not have met the residency  
requirement).   On the basis of our sample results, we estimated that California made Medicaid payments of  
$738.2 million ($628.8 million Federal share)  on behalf of  366,078 ineligible beneficiaries and $416.5  million  
($402.4 million Federal share) on behalf of  79,055 potentially ineligible beneficiaries.  These deficiencies  
occurred because Californias eligibility determination systems lacked the necessary system functionality and  
eligibility caseworkers made errors.  We also identified a weakness in Californias procedures related to  
determining eligibility of individuals who may not  have intended to apply for Medicaid.  
 
California partly agreed and partly disagreed with our recommendations that it (1) redetermine, if necessary,  
the current Medicaid eligibility of the sampled beneficiaries; (2) ensure its  eligibility determination systems have  
the functionality to verify eligibility requirements and perform eligibility determinations in accordance with 
Federal and State requirements; and (3) develop and implement written policies and procedures, as  
appropriate.    
 
New Jersey Claimed Federal Medicaid Reimbursement for  Childrens Partial Hospitalization Services That Did Not  
Meet Federal and State Requirements  (A-02-16-01008), March  2018  
20  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
 
New Jersey did not comply with Federal and State requirements for all 100  of the claims in our sample,  
including 94 that contained more than 1 deficiency.  For all  100 claims, we found that services provided were 
not documented or adequately supported.  For  81 claims,  outpatient hospital services were provided at a  
facility not licensed by New Jerseys hospital licensing agency.  For  48 claims, providers did not meet the 
minimum staff-to-client ratio requirement for group therapy services.  For  16 claims, services were provided by  
staff members who  did not meet qualification requirements.  Finally, for 10 claims  weekly progress  notes were 
not maintained.  As a result, the quality of care provided to the children at these providers might have been 
inadequate.  
 
The deficiencies occurred because New Jersey did not ensure that childrens partial hospitalization services  
were provided by appropriately licensed hospitals. Also, New Jersey did not adequately monitor the childrens  
partial hospitalization program to ensure that providers complied with Federal and State requirements.  
 
New Jersey disagreed with our recommendations  that it refund $54.7 million to the Federal Government and  
that its Medicaid agency  work with the States hospital licensing agency to  ensure that childrens partial  
hospitalization services are provided by appropriately licensed hospitals.  We also made other procedural  
recommendations.  
 
New York Did Not  Comply With Federal Grant  Requirements for Claiming Marketplace Contract Costs to  
Medicaid and the Childrens Health Insurance Program  (A-02-15-01014), March  2018  
 
New York did not always  follow Federal requirements for allocating and claiming contract costs to its grants for  
establishing New Yorks marketplace customer service center or for claiming contract costs to Medicaid and  
CHIP.   Specifically, for the customer service center, New York may have misallocated costs totaling nearly  $19.6  
million and claimed unallowable profit fees and other costs totaling nearly  $3.8 million.  For  Medicaid and  
CHIP,  New York claimed unallowable costs totaling as much as $954,521 (as much as $852,992 in unallowable 
profit fees and  $101,529  in unallowable general and administrative costs and related profit fees).  
 
This occurred because New York did not have written policies that explained how to properly  allocate costs  
when it developed its original cost allocation plan.   Further, New York did  not establish a basis for the profit fee 
rate with its contractor, Maximus, Inc., at the beginning of the contract; did not require Maximus to always use 
its final cost rate for general and administrative costs; and did not require  Maximus to retroactively  adjust the  
calculation of its profit fee and general and administrative costs by removing project costs that should not have 
been subject to these charges.  
 
New York disagreed with our recommendations that it (1) refund to CMS  $852,992  in unallowable profit fees or  
work with CMS to determine the appropriate amount that should have been claimed to  Medicaid and CHIP and 
(2) refund to CMS  $101,529  in unallowable general and administrative costs and  related profit fees.   
 
Potential Misclassifications Reported by Drug Manufacturers May Have Led to $1  Billion in  Lost Medicaid Rebates  
(OEI-03-17-00100),  December 2017  
 
We found that drug manufacturers may have misclassified 3 percent of drugs in the Medicaid Drug  Rebate 
Program (rebate program).  These potential misclassifications may have led to $1.3 billion in lost Medicaid  
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rebates and demonstrate the opportunity  for CMS to improve its oversight  of classification data in the rebate 
program.   
 
CMS concurred with all of our recommendations  to  follow up with manufacturers associated with potentially  
misclassified drugs identified in this report to determine whether current classifications are correct; improve 
CMSs  Drug  Data  Reporting for Medicaid system to minimize inconsistent data submissions and track potential  
classification errors for followup; and  pursue a means to compel manufacturers to correct inaccurate 
classification data reported to the rebate program.  
Quality of Care, Safety, and Access  
 
Minnesota Did Not  Comply With Federal Waiver and State Requirements for 18 of  20 Family Adult Foster Care 
Homes Reviewed  (A-05-16-00044), October 2017  
 
Minnesota funds  home and  community-based services for people aged 65  and older who are eligible for  
medical assistance and require the level of care provided in a nursing home but choose to live in the 
community, such as at a licensed family adult foster care home (home).   
 
Of the 131 homes in Minnesota where vulnerable adults who receive services through the program  resided for  
the quarter ended March 2016, we reviewed  20 homes.  We determined that 18  of the 20 homes did not  
comply with 1 or more State licensing requirements.  Specifically, we found 64 instances of noncompliance 
related to health and safety and administrative requirements.   
 
County licensor supervisors stated that instances  of noncompliance occurred mainly because of low staffing 
levels and a lack of training opportunities for license holders (providers) and county licensors. Additionally,  
specific State licensing requirements on the necessity of  safeguarding hazardous materials were unclear.  
 
Minnesota partially concurred with our recommendations that it ensure that the 64 instances of noncompliance 
with health and safety and administrative requirements identified in this report are corrected; work with  
counties to ensure the health and safety of vulnerable adults by considering staffing standards and  caseload  
thresholds for county agencies; review training opportunities available to  providers and county licensors and  
improve or increase them as needed; and ensure that Minnesota guidance accurately reflects administrative 
requirements related to  hazardous materials.   
Drug  Pricing and Reimbursement  
Arkansas Claimed Unallowable Federal Reimbursement for Some Medicaid  Physician-Administered Drugs  (A-06-
16-00018), February 2018  
Arkansas did not invoice manufacturers  for rebates associated with $9.9 million (Federal share) in physician-
administered drugs.   Arkansas improperly claimed Federal reimbursement for single-source drugs  and top-20 
multiple-source drugs and did not submit the utilization data necessary to  secure rebates for  all other  
physician-administered drug claims totaling $1.4  million (Federal share).    
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Arkansas partly agreed with our recommendations that  it  refund the overpayments and work with CMS to  
determine the resolution of other drug claims in question.    
Arizona Did Not  Bill Manufacturers for Some Rebates for Drugs Dispensed to Enrollees of Medicaid Managed-Care 
Organizations  (A-09-16-02031),  February 2018  
Arizona did not bill for and collect from manufacturers estimated rebates  of $36.7 million ($25.6 million Federal 
share) for physician-administered drugs.   Arizona  did not always bill for and collect  rebates  from manufacturers  
because it did not have a system edit to ensure that National  Drug Codes (NDCs) or valid NDCs were 
submitted for physician-administered drugs before October 1, 2012.  
Arizona partly agreed with our recommendations  that  it  refund the overpayments and work with CMS to  
determine the resolution of other drug claims in question.   Arizona concurred with our recommendations that  
it strengthen the NDC edit to ensure that NDCs are captured and valid for  all drug utilization data and ensure 
that all eligible physician-administered drugs are  processed for rebates.      
23  
  Department of Health and Human  Services Office of Inspector General  
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Legal and Investigative Activities Related  to  
Medicare and Medicaid   
 
OIG investigates allegations of fraud, waste, and abuse in all HHS programs.  Our largest body  of  work involves  
investigating matters related to Medicare and  Medicaid, such as patient harm; billing for services not rendered,  
medically unnecessary services,  or upcoded services (i.e.,  services billed for at a level higher than warranted);  
illegal billing, sale, and diversion of prescription drugs; marketing of off-label uses for prescription drugs; and  
solicitation and receipt of kickbacks, including illegal payments to patients for involvement in fraud schemes  
and illegal referral arrangements between physicians and medical companies.    
 
Specific case types include fraud schemes related to:  
   controlled and noncontrolled prescription drugs,  
   home health agencies and personal care services,  
   ambulance transportation,  
   durable medical equipment, and  
   diagnostic radiology  and laboratory testing.    
 
OIG also conducts investigations regarding organized criminal activity, including medical identity theft and  
fraudulent medical schemes established for the sole purpose of stealing Medicare dollars.  Investigators are 
opening an increasing number of cases against health care providers and patients who engage in these health 
care fraud schemes.  Those who participate in the schemes may face heavy  fines, jail time, and exclusion from  
participation in Federal health care programs.    
 
In addition to investigating Medicare and  Medicaid fraud, OIG investigates fraud, waste, and abuse in other  
HHS programs, including ACF,  Indian  Health Service (IHS), the Health Resources and Services Administration 
(HRSA), and ACL.  OIG investigates potential misuse of grants and contract funds awarded by CDC,  NIH, the 
Substance Abuse and  Mental Health Services Administration (SAMHSA), and other HHS agencies.  Under  
certain circumstances, OIG investigates noncustodial parents who fail to pay court-ordered child support.  OIG 
also investigates allegations of employee misconduct, whistleblower reprisals, and wrongdoing by  HHS agency  
officials.    
 
One of the most common types of  fraud perpetrated against Medicare,  Medicaid, and other Federal health care 
programs involves  filing false claims for reimbursement.  False claims may  be pursued under Federal and State 
criminal statutes and, when appropriate,  under the FCA.  Depending on the types of fraud or  other  violations  
involved, OIG investigations may culminate in criminal or civil court judgments and decisions, administrative  
sanctions and decisions,  and/or negotiated settlement agreements.  Investigative outcomes take many forms,  
including incarceration, restitution, fines, penalties, forfeitures,  assessments, and exclusion of individuals or  
entities from participation in all Federal health care programs.  Frequently  used exclusion and penalty  
authorities are described on our website at  http://oig.hhs.gov/fraud/enforcement/cmp/. 
 
During this semiannual reporting period, we reported  374  criminal and  346  civil actions against individuals or  
entities that engaged in offenses related to health care.  We also reported more than  $1.24  billion  in  
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  Department of Health and Human  Services Office of Inspector General  
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investigative receivables due to HHS and more than $203.7  million  in non-HHS investigative receivables,  
including civil and administrative settlements or civil judgments related to Medicare, Medicaid, and  other  
Federal, State,  and private health care programs.    
 
The following are recently completed actions and  settlements organized by subject area.   
 
Prescription Drugs   
The following are two case examples involving prescription drugs:  
 
   Michigan   Two co-conspirators connected with the health clinic Advance Care Services (ACS),  pleaded  
guilty to  charges resulting from their involvement in an unlawful prescription drug operation.  In all,  
they were sentenced to a combined 10  years in prison and ordered to pay $2.5 million in restitution,  
joint and several.  The defendantsACS physician Dr. Rodney  Moret  and  patient recruiter Kamani 
Jacobsconspired to  operate a fraudulent medical practice.  ACS purported to be a pain management  
and HIV infusion clinic; however, the actual scheme involved patient recruiters bringing patients to the 
clinic to obtain medically unnecessary  prescriptions for controlled substances.  Medicare was billed for  
medical examinations and tests that were not conducted properly or at  all.   According to statements  
made at the plea hearing and evidence submitted  at sentencing, Dr.  Moret often took advantage  of the 
female patients who received  controlled-substance prescriptions by sexually molesting or harassing 
them.  Dr.  Moret was responsible for illegally distributing more than 700,000 dosage units of  
Hydrocodone, more than 240,000 dosage units of  Alprazolam,  and more than 2 million milliliters of  
promethazine with codeine cough syrup, worth more than $15 million on the street market.  Three 
other  defendants involved in the scheme were previously sentenced to a combined 6 years and  5  
months in prison and  ordered to pay  $2.5 million in restitution  (joint and several).  
 
   Pennsylvania   Dr. Clarence Verdell, Dr. Keyhosrow Parsia,  Dr. Alan Summers, and their codefendants  
conducted a scheme to illegally sell prescriptions for controlled substances.  The investigation disclosed  
that from about February 2012 through August 2016, Verdell and Summers owned substance-abuse 
clinics in Philadelphia, while  Parsia worked at a nearby substance-abuse clinic.  Verdell, Parsia, Summers,  
and other doctors sold prescriptions for Suboxone and Klonopin to drug dealers and drug addicts in 
exchange for cash payments.  Drug dealers openly sold controlled substances inside the clinics and on 
the street immediately outside.  The physicians did not perform medical or mental health examinations  
of their patients as required by law to legally prescribe these controlled substances.  Virtually every  
customer who visited the clinics received the maximum daily doses of Suboxone and Klonopin 
regardless of the customers medical or mental health history.  Verdell,  Parsia, and Summers  all pled  
guilty to multiple counts regarding controlled substances and health  care fraud and were sentenced to  
a combined 4 years and  1 day in prison; ordered to pay  $39,199 in restitution; joint and several; and 
ordered to forfeit $153,193.  
 
 
Pharmacy 
The following is a case example involving a pharmacy:  
 
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   Texas   DaVita Rx, LLC (DaVita Rx), a nationwide pharmacy that specializes  in serving patients with 
severe kidney disease, entered into a  settlement agreement to resolve allegations that it billed Federal  
health  care programs for prescription medications that were never shipped, that were shipped but  
subsequently returned, and that did not comply with requirements for documentation of proof of  
delivery, refill requests, or patient consent.   In addition, the settlement also resolves allegations that  
DaVita Rx paid financial inducements to Federal health  care program beneficiaries in violation of the 
anti-kickback  statute.   Specifically, DaVita Rx allegedly accepted manufacturer copayment discount  
cards in lieu of collecting copayments from Medicare beneficiaries, routinely wrote off unpaid  
beneficiary debt, and extended discounts to beneficiaries who paid for their medications by credit card.   
These allegations relating to improper billing and unlawful financial inducements were the subject of  
self-disclosures by DaVita Rx and a subsequently  filed whistleblower lawsuit.   DaVita Rx agreed to pay  
$63.7 million to resolve its FCA liability.  
 
Pharmaceutical Companies  
The following is a case example involving a pharmaceutical company:  
 
   Massachusetts    United Therapeutics Corporation (UT) entered into a civil settlement agreement to  
resolve its FCA liability associated with donations it made to a 501(c)(3) foundation.  UT manufactures  
and sells a number of drugs used to treat pulmonary arterial hypertension. The settlement resolved  
allegations that from 2010 to 2014 UT violated the FCA by paying kickbacks to Medicare patients  
through donations it made to Caring Voice Coalition (CVC).   CVC, in turn, allegedly used the donations  
to pay copayments  for patients in order to induce the patients to use UT's drugs.   The Government  
alleged that UT routinely obtained data from CVC detailing how much CVC spent for patients who  were 
using UT's drugs and that UT used this data to decide how much money to donate to CVC.   Essentially,  
the Government alleged  that UT used CVC as a conduit to pay the copayments of Medicare patients  
who were using UT's drugs.   UT agreed to pay $210 million to resolve its liability and entered  a 5-year  
CIA with OIG.  
False EHR Oncology  Claims   
The following is an oncology-related case example:  
 
   Florida    21st Century Oncology, Inc., and 21st Century Oncology, LLC (collectively, 21C)  and North 
Carolina Radiation Therapy Management  Services, LLC and Radiation Therapy Associates of Western 
North  Carolina,  P.A. (collectively, Radiation Therapy) entered into a settlement agreement to resolve 
allegations that they submitted false claims to Medicare.  21C is the largest integrated network of  
cancer treatment centers and affiliated physicians  in the world.   It is alleged that 21C knowingly  
submitted, or caused the submission of, false claims under the Medicare Electronic Health Record (EHR)  
Incentive Program for meaningful use performance years 2012-2014 on behalf of  121 physicians.   21C  
allegedly submitted false attestations to CMS regarding its compliance with the Medicare EHR Incentive 
Program and CMS made incentive payments for performance years  2012-2014 to physicians who did  
not meet the criteria for  meaningful use and paid claims for physician services in CYs 2015 and 2016 at  
a rate that did not reflect the required downward adjustments.  This settlement also resolves allegations  
of violations of the physician self-referral law (commonly referred to as the Stark  law)  because of  
prohibited referrals made by certain physicians with improper compensation arrangements.   Between 
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  Department of Health and Human  Services Office of Inspector General  
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February 2013 and October 2016, financial relationships with certain 21C physicians allegedly violated  
the Stark  law.  Between October 2014  and October 2017,  financial relationships with certain Radiation  
Therapy physicians allegedly violated the Stark  law.  21C and Radiation Therapy  agreed to pay $26 
million to resolve their FCA liability, and 21C entered into a 5-year  CIA with OIG.  
Home Health  
The following are two  case examples  involving home health:  
 
   Florida   Sila Luis, the co-owner and operator of  two  home health agencies, engaged in an elaborate 
health care fraud scheme.  According to court documents, from January  2006 through June 2012, Luis  
and her co-defendants enlisted and paid patient recruiters kickbacks and bribes in exchange for the  
referral of  Medicare beneficiaries to the two home health agencies to receive home health and physical  
therapy services that were not medically necessary, not provided, or both.  Luis pleaded guilty to  
conspiracy to commit health care fraud and was sentenced to 6 years and  8 months in prison and  
ordered to pay restitution of $45 million, joint and several.  Two additional defendants involved in the 
scheme were previously  sentenced to a combined 11  years and 8 months in prison and ordered to  pay  
a portion of the  $45 million in restitution, as well as an additional $27 million in restitution.  
 
   Texas   Eric Ugorji, a  registered nurse who owned  and operated two  home health agencies, engaged in 
a scheme to defraud  Medicare.  According to the investigation, from  approximately  August 2009  
through April 2016, Ugorji and his co-defendants  were involved in a scheme to recruit patients to  
receive home health services that were not medically necessary, not provided, or both.  Ugorji also  paid  
kickbacks to physicians who would falsely certify in a plan of care that the Medicare beneficiaries were 
under their care and confined to the home when they were not.  Ugorji pleaded guilty to conspiracy to  
commit health care fraud and was sentenced to 10 years in prison and  ordered to pay  $17.1 million in 
restitution.  
Transportation  
The following is a transportation-related case example:  
 
   Florida   AmeriCare Ambulance Service, Inc., and its sister company, AmeriCare ALS, Inc. (collectively,  
AmeriCare), entered into  a settlement agreement to resolve allegations that they defrauded Medicare 
by billing for medically unnecessary  ambulance transportation services.  From January  2008 through  
December 2016, AmeriCare allegedly submitted fraudulent claims to Medicare and TRICARE for Basic  
Life Support (BLS), nonemergency ambulance transports that were not medically justified.  AmeriCare 
had created thousands of false reports  and other  documentation during this time period in a failed  
effort to support this illicit practice.  AmeriCare agreed to pay  $5.49 million to resolve its  liability under  
the FCA, and entered into a 5-year CIA.  
Durable Medical Equipment  
The following is a case example involving durable medical equipment:  
 
   Louisiana   Geoffrey Ricketts and Samuel Kim directed a  $38 million Medicare fraud scheme.  The 
defendants operated Care Concepts, LLC and Choice Home Medical Equipment and Supplies. According  
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  Department of Health and Human  Services Office of Inspector General  
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to court documents, the defendants paid  kickbacks to workers  at call centers from which operators  
would cold-call Medicare recipients to convince them to accept talking glucose meters and related  
supplies.   From 2007 through 2015, the defendants caused thousands of claims to be submitted to  
Medicare, virtually  all of  which were fraudulent. Ricketts and Kim both pleaded guilty to conspiracy to  
commit health care fraud. Ricketts was sentenced to 3 years and  10 months in prison and ordered to  
pay  $1.3 million in restitution, while Kim was sentenced to 2 years and 1 month in prison and ordered to  
pay  $988,593 in restitution.  Two defendants involved in the scheme were previously sentenced to  a  
combined 1 year and 1 day in prison and ordered  to pay  $133,807 in restitution.  
Laboratories  
The  following is a case example involving laboratories:  
 
   Texas    Primex Clinical Laboratories, LLC (Primex) and Mitch Edland, the  CEO and owner of DNA Stat, 
LLC (DNA Stat), entered into settlement agreements to resolve allegations that they paid  kickbacks in 
exchange for laboratory referrals for patient pharmacogenetic  testing.  Primex is a licensed clinical 
laboratory providing clinical diagnostic testing services, including pharmacogenetic testing.   DNA Stat  
was a laboratory management company that employed sales representatives and licensed pharmacists.   
Primex  and DNA Stat entered into a services agreement related to pharmacogenetic testing services.   
From June 2013 through March 2016,  Primex and  DNA Stat  allegedly were involved in several kickback  
schemes, including a scheme where the defendants created the appearance of paying physicians to  
provide clinical study data for a  Primex-sponsored study related to pharmacogenetic testing when, in 
fact, the physicians were being paid for referring patients for the testing.   Primex and DNA Stat also  
allegedly provided physicians with in-office medical technicians to do work related to the Primex-
sponsored study in an effort to induce those physicians to order pharmacogenetic tests from Primex.   
Primex agreed to pay  $3.5 million and enter into a 5-year CIA.  Edland agreed to pay $270,000 and  to  
be excluded for a period  of 5  years.  
Radiology 
The following is a radiology-related case example:  
 
   Delaware  Orthopaedic and Neuro Imaging LLC (ONI) and its owner, Richard Pfarr, engaged in a  
scheme to defraud  Medicare.  The investigation disclosed that ONI and Pfarr knowingly submitted false 
claims to Medicare by administering contrast dye during MRI scans on patients without proper  
supervision by  a physician.  Contrast dye is a chemical that is injected intravenously into the body in 
order to make certain tissues more clearly visible on an MRI.  ONI was ordered to pay  $16.2 million in 
damages, and  Pfarr was  ordered to pay $6.1 million in damages, joint and several.  
Nursing Homes 
The following case example pertains to  a  nursing home:  
 
   New York   Catholic Health System, Inc., Home &  Community  Based Care (Catholic Health) entered  into  
a settlement agreement to resolve allegations that it knowingly caused false claims to be submitted to  
Medicare.  Catholic Health operated and provided long- and short-term skilled nursing care and  
postacute care to seniors at Father Baker  Manor, the McAuley Residence, and St. Frances Williamsville 
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(collectively described herein as the Subject Facilities).  The agreement resolves allegations that  
between January 1, 2007,  and December  31,  2014, Catholic Health submitted, or caused to be 
submitted, false claims to Medicare for rehabilitation therapy services at the Ultra High Resource 
Utilization Group level it administered to beneficiaries that were unreasonable, not medically necessary,  
and unsupported by the medical records at its Subject Facilities.   Catholic  Health agreed to pay $6  
million and enter into a 5-year CIA with OIG to resolve this liability.   
Mental Health  
The following is a case example related  to  mental health:  
 
   Mississippi  Region 8  Mental Health Services (Region 8) agreed to pay a lump sum of $6.9 million, plus  
approximately $1.7 million based on the anticipated value of six properties, to resolve allegations that  it  
violated the FCA by submitting false claims to Medicaid.  Region 8 provides a variety of mental health 
services to children and adults located in five counties in Mississippi.  The settlement resolves  
allegations that, from October 2004 through December 2010, Region 8  submitted false claims for  
services to Medicaid beneficiaries enrolled in its preschool Day Treatment program that it did not  
provide or that were not  provided by qualified individuals.   Medicaid defines Day Treatment as a  
behavioral intervention program,  provided in the context of a therapeutic  milieu, which provides  
children/adolescents with serious emotional disturbances the intensity of treatment necessary to enable 
them to live in the community.    
Identity Theft  
The following is a case example involving identity theft:  
 
   Florida   Miguel  De Paula Arias was engaged in a sophisticated scheme to defraud Medicare by  
committing identity theft.   According to the investigation, Arias stole the identities of  five  retired and 
semi-retired physicians along with their Medicare provider numbers used to submit claims for services  
provided to patients.   Arias utilized fake passports, drivers licenses, and other identification documents  
to establish bank  accounts, mailing addresses, and phone answering services in the names of the victim  
physicians to give the appearance that the physicians were in practice and providing medical care to  
deceased beneficiaries in different locations around the country.   From  June 2011 through December  
2016, Arias submitted fraudulent claims to Medicare for purportedly providing medical services.   Arias 
had the money paid by  Medicare deposited into  the bank accounts he controlled in the victim doctors 
names.   The doctors, as  a result of Arias crimes, received bills from the IRS for unpaid taxes  and from 
Medicare for repayment  of the apparently fraudulent claims.   Arias pleaded guilty to health care fraud,  
false statements regarding health care fraud,  and  aggravated identity theft.  He was sentenced to 13  
years  and 5 months in prison and  ordered to pay  $1.6 million in restitution.  
Hospitals  
The following is a case example involving a hospital:  
 
   Georgia   Meadows Regional Medical Center, Inc.  (MRMC), a 57-bed not-for-profit safety net hospital  
located in rural southeast Georgia, entered into two settlement agreements to resolve its FCA liability.   
Three physician groups (Dublin Internal Medicine, Middle Georgia Urology, and Downtown Dublin 
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Wound Center) were also parties to one of the settlement agreements.  The investigation revealed that  
from 2012 to  2015,  MRMC allegedly violated the Stark  law (and, with some arrangements, also the anti-
kickback  statute) by paying physicians substantially more than the fair-market value of their services in 
exchange for patient referrals from the physicians to  MRMC.  The focus of the investigation and the 
settlements was MRMCs relationships with 12 physicians and their respective groups.   Two of the  
physicians were independent contractors of  MRMC, operated wound care centers, and were paid under  
medical director agreements. The remaining 10 physicians were employees of MRMC.   MRMC entered  
into one settlement agreement to resolve its FCA  liability related to the physician groups for $3.6  
million, but it could  increase up to $11.1 million contingent upon MRMCs  meeting certain financial  
thresholds, and a second  agreement  to resolve its liability related to two individual physicians for  $1.7  
million.   MRMC  also entered into a 5-year  CIA with an arrangements review.  
 
Hospice  
The following is an example of a hospice case:  
 
   Missouri   Chemed Corporation and various wholly-owned subsidiaries, including VITAS Hospice Services,  
LLC and Vitas Healthcare Corporation  entered into  a settlement agreement to resolve allegations that  
they submitted false claims to Medicare.  VITAS is the Nations largest for-profit provider of hospice 
services. The defendants  allegedly submitted false claims to Medicare for (1) services provided to  
patients who were ineligible for hospice benefits and (2) continuous home care services that were not  
medically necessary, not  provided, or not performed in accordance with Medicare requirements.  VITAS  
agreed to pay $75.5 million to resolve their FCA liability, and entered into  a 5-year CIA.   
Health Care Fraud  Prevention and Enforcement  
In  May 2009, the Secretary of Health and  Human Services  and the U.S.  Attorney General announced the 
creation of the Health Care Fraud Prevention and  Enforcement Action Team (HEAT), an interagency effort  
focused specifically on combating health care fraud.  HEAT  includes senior officials from  DOJ and HHS who are  
strengthening programs and investing in new resources and technologies  to prevent and combat fraud, waste,  
and abuse.   
 
HEAT Provider Compliance Training  
OIG provides free training on our website for health care providers, compliance professionals, and  
attorneys.  OIGs Provider Compliance Training was an initiative developed as part of HEAT in 2011 that  
continues to reach the health care community with OIGs message of compliance and prevention via  
free downloadable comprehensive training materials and podcasts.  OIGs  provider compliance training  
resources can be accessed at  https://oig.hhs.gov/compliance/compliance-guidance/index.asp.  
 
Medicare Fraud Strike Force Activities   
In 2007,  Medicare Fraud  Strike Force teams began an effort to combine resources of Federal, State,  and  
local law enforcement entities to prevent and combat health care fraud, waste, and abuse.  These 
partnerships among OIG and HHS, DOJ, U.S. Attorneys offices, FBI, and State and local law enforcement  
have a common goal: to  successfully analyze health care fraud data and investigative intelligence to  
quickly identify fraud and bring prosecutions.  Strike Force teams operate in nine  areas: Miami  and  
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Tampa, Florida; Dallas and Houston, Texas; Los Angeles, California;  Detroit,  Michigan; Brooklyn, New  
York;  Southern  Louisiana; and Chicago, Illinois.  
 
During this semiannual reporting period, Strike Force efforts resulted in the filing of charges against  77  
individuals or entities,  107  criminal actions, and more than $100.3  million  in investigative receivables.   
 
The following  are two  examples of Strike Force cases: 
 
   Michigan   Dr.  Johnny Trotter, II and Elaine Lovett, owners of a medical billing company,  
were involved in a $26 million scheme to fraudulently bill Medicare for nerve block injections  
that were never provided.   According to the evidence presented at trial, from May 2008 until 
May 2014, Trotter  and Lovett knowingly submitted fraudulent claims for services that they  
knew had not been provided, mainly nerve block injections.   Additionally, after Medicare  
imposed a requirement in 2009 that required Trotters claims to undergo a medical review  
prior to payment, Trotter and Lovett conspired to  circumvent Medicares fraud investigation 
of Trotter by creating sham medical practices.   To  continue to receive payment for services  
that were not provided, Trotter and Lovett concealed their involvement  in  these practices  
from Medicare, and instead recruited their family  members and employees to serve as straw  
owners of the companies.  Trotter and Lovett were both found guilty of conspiracy and  
health care fraud.  Trotter  was sentenced to 15  years in prison, Lovett was  sentenced to 10  
years in prison, and they  were both ordered to pay nearly $9.2 million in restitution, joint and  
several.    
 
   Florida   Five co-conspirators were convicted of charges resulting from their involvement in 
a scheme to defraud  Medicare.  In all, they were sentenced to a combined 13  years  and 7  
months in prison, and  ordered to pay  $27.5 million in restitution, joint and several.  The 
defendantsAntonio E. Alfonso-Ramos,  Dayan Vina Guerra,  Jose Ruiz-Dean, Jose Carlos 
Gonzalez, and Rosa  Marbella Patino-Gonzalezconspired to operate multiple fraudulent  
home health care agencies and a rehab facility.  According to court documents, from about 
January 2010 through about May 2015, the defendants were involved in a scheme to recruit  
patients to receive unnecessary home health visits.  Specifically, the defendants paid  
kickbacks and bribes to patient recruiters in exchange for the referrals of  Medicare 
beneficiaries to serve as  patients at the home health care agencies, which then billed  
Medicare for services that were not medically necessary, not provided, or both.  The 
defendants also paid kickbacks and bribes for home health prescriptions and plans of care,  
which falsely represented that Medicare beneficiaries qualified for home health services  
when, in fact, they did not.  Three defendants involved in the scheme were previously 
sentenced to a combined 13  years and 9 months in prison and ordered to  pay  $34.2 million 
in restitution, joint and several.  One additional defendant is a fugitive in Cuba.  
Other Criminal and Civil  Enforcement Activities   
 
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Special Assistant U.S. Attorney Program  
During this reporting period, DOJ and OIG continued their participation in a  program in which OIG 
attorneys, some of whom are Special Agents, serve as Special Assistant U.S. Attorneys.  These OIG 
attorneys are detailed full time to the Fraud  section of DOJs  Criminal Division for temporary  
assignments, including assignments to the Health Care Fraud  Strike Force.  Other attorneys prosecute 
matters on a case-by-case basis.  Both arrangements offer excellent litigation training for OIG attorneys  
and enhance collaboration between the departments in their efforts to fight fraud.  Under this program,  
OIG attorneys have successfully litigated important criminal cases relating to the fraudulent billing of  
medical equipment and supplies, infusion therapy, and physical therapy, as well as other types of  
Medicare and Medicaid fraud.  
 
The following case is an  example  of  Medicare fraud: 
 
   Texas   Patricia Ann Thomas owned and operated group homes in the Houston, Texas area.   
Thomas engaged in a scheme to defraud  Medicare by receiving kickbacks in exchange for referring 
her group home residents for home health services.  Thomas pleaded guilty to making  false  
statements to  Federal  agents and was sentenced to 6 months in prison.  
 
Most Wanted Fugitives Listed on OIGs Website 
The OIG Most Wanted Fugitives website continues to garner national and international attention and  
has greatly  assisted in helping to capture fugitives charged with defrauding Federal health care 
programs and stealing millions of taxpayer dollars.  The Most Wanted Fugitives website is continually 
updated and features a profile for each fugitive as  well as an  online tip form and a hotline number for  
individuals to report fugitive-related information to OIG, in English or Spanish, 24 hours a day,  365  days  
a year.  The Most  Wanted Fugitives list can be accessed at  https://oig.hhs.gov/fraud/fugitives/. 
 
The following is a case example involving a captured fugitive:  
 
   One of OIGs Most Wanted Deadbeat Parents, Joseph Stroup, was captured during this reporting  
period.   Joseph Stroup had been a fugitive for nearly 20  yearshe owes  more than $560,000 in 
child support.   He was recently located in Calgary, Canada, based on  a tip from a Canadian national  
who identified the fugitive on the OIG Child Support Enforcement website.   Stroup, who had been 
living in Canada under an assumed identity, was  detained by the Canadian Border Services Agency  
and transported to the  United States  on  February 15, 2018.   He is currently  in U.S. custody and will 
stand trial for his child support violation.  In August 1989,  Stroup was ordered to pay child support  
for his four children in the amount of  $100 per month.   However, as a result of telling the court he 
was unemployed  and medically disabled, his support was reduced to $14 per month.   In 1996, the 
court learned that Stroup was operating a successful Internet business, which he ultimately sold for  
more than $2 million.   The child support order was subsequently modified  to account for the 
unreported income.   From June 1996 to present,  Stroup failed to pay any further child support. An 
arrest warrant was issued in July 1998.  
 
Because of the success of OIGs Most Wanted Fugitives website, OIG launched its Most Wanted  
Deadbeat Parents website at  https://oig.hhs.gov/fraud/child-support-enforcement/index.asp.  The site 
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identifies parents whose failure to pay court-ordered child support for their children places unnecessary  
strain on the custodial parents and the children as  well as on agencies that enforce these matters.  The 
Human Services Reviews section of this Semiannual Report provides examples.   
OIG Hotline  
 
Part of OIGs Office of Investigations, the hotline is the public-facing division for OIGs intake and evaluation of  
fraud tips.  The mission of the OIG Hotline is to support OIGs oversight responsibilities in safeguarding the 
integrity of all programs  and personnel under HHSs purview and protecting them from fraud, waste, and  
abuse.  The hotline achieves its mission through its staffs dedication to timely intake and  analysis of  
information received from various sources, such as the Report Fraud link on the OIG website.  During this  
semiannual reporting period, the OIG Hotline reported expected  HHS  recoveries of more than $2  million  as 
a  direct result of cases originating from  hotline complaints.  
 
OIG Hotline Activity (10/01/1703/31/18)  
 
Contacts to 1-800-HHS-TIPS phone line,   53,969  
including callers seeking information   
Total tips evaluated   13,551  
Closed; no basis provided for  further action   178  
Tips referred for action   6,979  
   
Sources of  Tips  Referred for Action   
 
Phone   2,830  
OIG  website   3,327  
Letters/faxes   801  
Other   21  
State MFCUs  
OIG Oversight of State  MFCUs 
MFCUs  are key partners with OIG in the fight against fraud, waste,  and abuse in State Medicaid  
programs.  OIG has oversight responsibility for  MFCUs and administers grants that provide Federal  
funding for Unit operations.  The Federal Government reimburses  75 percent of the costs of operating  
all existing Units, which are in 49 States and the District of Columbia.  MFCUs investigate and prosecute 
Medicaid provider fraud  and patient abuse and neglect in health care facilities or board and care 
facilities.   
 
Medicaid  Fraud  Control Units  Fiscal Year  2017  Annual  Report  (OEI-09-18-00180), March  2018  
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This annual report highlights statistics on the accomplishments of the 50  MFCUs during FY 2017.   OIG 
found that the number of convictions in FY 2017 remained similar to those in recent years.  Just over 45  
percent of the 1,157 MFCU fraud convictions involved personal care services attendants.  Fraud cases  
accounted for 76 percent of the MFCU convictions, while 24 percent involved patient abuse or neglect.  
MFCUs reported 961 civil settlements and judgments, 44 percent of which involved pharmaceutical  
manufacturers.  MFCUs reported over  $1.8 billion in criminal and civil recoveries.    
 
In an appendix to the report, OIG summarizes beneficial practices by the MFCUs that were identified in 
onsite review reports published during FYs 20122017.  
OIG  Onsite Reviews of MFCUs   
In addition to an annual  recertification review of each MFCU, OIG conducts periodic reviews of a sample 
of MFCUs.  OIG evaluates MFCU operations  based on  12 performance standards and assesses 
compliance with laws, regulations,  and OIG policy guidance.  OIG may also make observations of Unit  
operations and practices, including identifying effective practices that may be useful to other Units.  In 
addition, OIG provides training and technical assistance to Units while onsite and on an ongoing basis.  
 
Medicaid Fraud Control Units: Investigation and Prosecution of Fraud and Beneficiary Abuse in Medicaid  
Personal Care Services  (OEI-12-17-00500), December 2017  
 
MFCUs  investigate and prosecute Medicaid provider fraud and patient abuse or neglect under State 
law.   We conducted this study to provide data on MFCU investigations, indictments, and convictions  
involving fraud and patient abuse in Medicaid personal care services (PCS).   We found that during the 
review period, PCS  fraud  cases were a substantial  and growing percentage of MFCU cases and  
outcomes.   In FY 2015, fraud cases involving PCS  providers or attendants constituted 12 percent of  total  
investigations.   From FY 2012 through FY  2015, fraud cases involving PCS  providers or attendants  
constituted 38 percent of indictments and 34 percent of convictions.   We also found that during this  
time, indictments increased 56 percent and convictions increased 33 percent.   We found that  MFCUs  
have made recommendations to States for strengthening PCS oversight. Finally, we found that, in 
MFCUs' efforts to protect beneficiaries receiving PCS services, they are constrained by their ineligibility  
to receive Federal funding to  investigate and prosecute complaints of beneficiary abuse or neglect in 
nonfacility  settings (such as beneficiaries' homes).   The findings suggest that PCS remain vulnerable to  
fraud and support the need for greater oversight  of Medicaid PCS.   CMS has made efforts in this area,  
but MFCUs report that States have generally not implemented the specific  recommendations that  
MFCUs made to them for strengthening program integrity.   The recommendations that MFCUs made to  
States align with recommendations that OIG  has  made previously to CMS  and which OIG continues to  
support.   In addition, to  protect beneficiaries from abuse and neglect, it is key that Federal funding  
authority be expanded so that MFCUs can investigate and prosecute cases of patient abuse and neglect  
in nonfacility settings.  
 
The following case is an example of OIGs joint efforts with MFCUs:  
 
   North Carolina   Justin Daniel, pharmacist and owner of Old Main Pharmacy, directed a scheme to  
defraud Medicare and Medicaid.  The investigation disclosed that from 2011 through 2015,  Daniel  
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instructed his staff to make a  compound pain cream using bulk Ketoprofen powder,  which was not  
reimbursable, while he billed insurance programs  as if the more expensive extended-release 
capsules, which are reimbursable, were used.   Daniel requested and received payment for the 
fraudulent claims from  Medicare and Medicaid.  Daniel pleaded guilty to conspiracy to commit 
health care fraud  and was sentenced to 12 months and 1 day in prison and ordered to pay $2.4  
million in restitution.  
Advisory  Opinions  and Other Industry Guidance   
As part of OIGs continuing efforts to promote the highest level of ethical and lawful conduct by the health care 
industry, we issue advisory opinions  and other guidance to educate industry and other stakeholders on how to  
avoid fraud, waste, and abuse.  Advisory opinions, which are developed in consultation with DOJ, are issued to  
requesting parties regarding the interpretation and applicability of certain statutes relating to Federal health 
care programs.  The Health Insurance Portability and Accountability Act of 1996 (HIPAA),  205,  allows OIG to  
provide case-specific formal guidance on the application of the anti-kickback statute and safe harbor  
provisions and other OIG health care fraud and abuse sanctions.  During this semiannual reporting period, OIG  
received  27  requests for  advisory  opinions and issued  5  advisory opinions  and no modifications of  advisory  
opinions.   OIG also issued one rescission of an advisory opinion.  
Sanction Authorities and  Other Administrative Actions   
Various Federal laws provide authorities the ability to impose administrative sanctions for fraud and abuse as  
well as other activities that pose a risk to  Federal  health care programs and their beneficiaries.  Sanctions  
include the exclusion of individuals and entities from Federal health care programs and the imposition of CMPs  
for submitting false and  fraudulent claims to a  Federal health care program  or for violating the anti-kickback  
statute, the Stark  law, or  the Emergency  Medical Treatment and Labor  Act  (EMTALA), also  known as the 
patient dumping statute.   Sanctions also include  referrals for suspension and debarment in cases of grant and  
contract fraud.  
 
During this semiannual reporting period, OIG imposed  1,678  administrative sanctions in the form  of program  
exclusions or administrative actions for alleged fraud or abuse or  other activities that posed a risk to Federal  
health care programs and their beneficiaries.    
 
Exclusion and penalty authorities are described in Appendix D and on our website at 
http://oig.hhs.gov/fraud/enforcement/cmp/index.asp.   
Program Exclusions  
During this semiannual reporting period, OIG excluded  1,588  individuals and entities from Medicare, Medicaid,  
and other Federal health care programs.   Most of  the exclusions resulted from convictions for crimes relating to  
Medicare or  Medicaid, patient abuse or neglect,  or as a result of license revocation.  OIG is also responsible for 
reinstating providers who apply and have met the requirements of their exclusions.  For a list of excluded  
individuals and entities, see https://exclusions.oig.hhs.gov/.   
 
The following  are examples of program exclusions:  
 
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   Illinois   Gwen Hilsabeck  was an administrator  at Passages Hospice, LLC.  According to court  
documents, from August 2009 to  September 2009, Hilsabeck altered patient files to make visits  
that were at the routine level appear to have been general inpatient services.  General inpatient  
services, which are reimbursed at a higher rate than routine care services, were not medically 
necessary and were not  provided. Hilsabeck pleaded guilty to conspiracy  to commit an offense 
against the United States and was sentenced to 2  years  and 4 months in prison and ordered to  
pay  $9.0 million in restitution, joint and several among other defendants.   OIG excluded  
Hilsabeck for a minimum period of 30 years.  
 
   Kentucky    Lonnie Hubbard was  a pharmacist who owned RX Discount  Pharmacy.   According to  
evidence presented at trial, from January 2010 through December  2015, Hubbard sold  
prescription pain pills without a legitimate medical purpose and sold pseudoephedrine, knowing 
or having reason to believe that it was being used to manufacture methamphetamine.  Many of  
Hubbards customers visited pain clinics in other states to obtain illegitimate prescriptions from  
irreputable clinics.   Hubbard would charge $600 to $1,000 to  fill the prescriptions, which 
included excessive amounts of oxycodone.   According to trial testimony, Hubbard also sold 
multiple boxes of pseudoephedrine at a time, for excessively high prices, to drug addicts and  
traffickers.  A jury convicted Hubbard on 71 counts involving the illegal dispensing of  
oxycodone, hydrocodone, and pseudoephedrine, and sentenced him to 30 years in prison.   OIG  
excluded Hubbard for a  minimum period of 50 years.   
 
Civil  Monetary Penalties  Law (CMPL)  
The CMPL authorizes OIG to impose administrative penalties, assessments, and exclusions against  a person 
who, among other things, submits, or causes to be submitted, claims to a Federal health care program that the 
person knows, or should  know, are false or fraudulent.  The exclusions  statute also authorizes OIG to exclude a  
person who violates the CMPL.  During this semiannual reporting period,  OIG concluded cases involving more 
than $35.5  million  in CMPs and assessments.  
 
Affirmative Litigation  
The CMPL authorizes OIG to use its administrative remedies to affirmatively pursue cases.   OIG may also  
exclude under the exclusions  statute for engaging  in conduct that violates the CMPL.  When OIG 
excludes under the exclusions  statute for engaging in conduct that violates the CMPL, it is known as an 
affirmative exclusion.    
 
The following is an example of an affirmative litigation  case under the CMPL:  
 
   Virginia   Nathan Guerette, M.D. (Guerette) and his medical practice, The Female Pelvic Medicine 
Institute of Virginia, P.C. (FPMI), agreed to pay more than $1.4 million and  enter into a 3-year  
CIA to resolve their  potential  liability under the CMPL for submitting claims to Federal health  
care programs for items  or services that FPMI knew or should have known were not provided as  
claimed or were false or fraudulent.  Specifically, OIG alleged that Guerette and FPMI submitted  
claims for pelvic floor therapy services that were provided by unqualified individuals; diagnostic  
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electromyography services under CPT Code 51784 that had not been performed pursuant to the 
indicated codes requirements; unbundled biofeedback procedures; and incident to services  
that lacked the  required  physician supervision level.  OIG also alleged that Guerette and FPMI  
submitted claims for electromyography services under CPT Code 51784  and anorectal  
manometry services under CPT Codes 91120  and  91122 that were not supported by the medical  
record.  This resolution resulted from OIGs collaboration with the Consolidated Data Analytics  
Center.  
 
Patient Dumping   
Some of the CMPL cases  that OIG resolved during this semiannual reporting period were pursued under  
EMTALA, a statute designed to prevent hospitals  from denying emergency care to patients and to  
ensure patient access to  appropriate emergency  medical services.    
 
The following  case examples relate to the EMTALA statute: 
 
   Massachusetts   Cambridge Health Alliance (CHA) agreed to pay $90,000 to resolve its potential  
liability under EMTALA.  OIG alleged that CHA violated EMTALA when it failed to screen a  
patient after she presented on hospital property in medical distress.   Specifically, OIG alleged  
that a patient who was experiencing a severe asthma attack presented to CHAs Somerville 
Hospital Campus, but was unable to gain entry to  the ambulance bay doors.   The patient called  
911, which  notified the hospitals responding nurse.   OIG alleged that CHA was negligent in its  
search for the patient, looking  only  briefly outside without leaving the ambulance bay door or  
searching the sidewalk located just steps from the doors.   The patient had  collapsed on a bench 
adjacent to the ambulance doors.   Ultimately, the 911 dispatchers sent emergency responders to 
the hospital who found the patient in full cardiac arrest and no longer breathing.   The patient  
was brought inside the hospital in grave condition, and 6 days later died of hypoxic brain injury.  
 
   Georgia   Piedmont Newton Hospital (PNH) agreed to pay  $52,414 to resolve its potential  
liability under EMTALA.   OIG alleged that PNH violated EMTALA when it failed to provide an 
appropriate medical screening exam and stabilizing treatment to a patient (TMK) and  
inappropriately transferred TMK to another hospital.   Specifically, OIG alleged that TMK arrived  
at PNH complaining of left-sided pleuritic chest pain and abdominal pain.   PNHs emergency  
department (ED) physician observed that her  abdomen was diffusely firm  with hypoactive bowel  
sounds, and ordered blood tests, which revealed that TMKs lactic acid and bleeding and clotting 
time were elevated beyond normal limits.   The ED physician learned that TMK had undergone 
dilation and curettage two days earlier.  The ED physician ordered an acute abdominal series  
with chest x-ray for TMK, which showed a large amount of intraperitoneal  air under her right  
diaphragm, suggesting bowel perforation.   The ED physician consulted with the on-call surgeon,  
who recommended transferring TMK to the other  hospital where she previously underwent the 
dilation and curettage  procedure.   The other hospital agreed to accept the transfer and asked  
that TMK be airlifted to their facility.   The ED physicians notes revealed that TMK had a  
perforated bowel and her condition was critical at the time of transfer.   Upon her arrival at the 
other hospital, TMK was in septic shock and appeared on the verge of a respiratory  
collapse.   She was immediately intubated and taken to the operating room for a resection and  
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colostomy.   TMKs condition worsened and she died later that day due to septic shock with 
multi-organ failure.  
 
Self-Disclosure Programs   
Health care providers, suppliers, or other individuals or entities subject to CMPs can apply for  
acceptance into the Provider Self-Disclosure  Protocol, a  program created in 1998 for voluntary  
disclosure of self-discovered evidence of potential fraud.  The self-disclosure program may give  
providers the opportunity to avoid costs or disruptions associated with Government-directed 
investigations and civil or administrative litigation.  
Application processes for two additional self-disclosure programs were recently added to the OIG 
website for HHS contractors and grantees.  The OIG contractor self-disclosure program provides  
contractors the opportunity to self-disclose when they have potentially violated the FCA or other  
Federal criminal laws prohibiting fraud, conflict of interest, bribery, or gratuity.  This self-disclosure  
process is available only to those with a Federal Acquisition Regulation-based contract with HHS.  The  
OIG Grant Self-Disclosure program is available for application by HHS grantees or HHS grant 
subrecipients and provides the opportunity for voluntary disclosure to OIG of potential fraud.  OIG 
evaluates the reported  results of each  internal investigation under the provider self-disclosure protocol  
to determine the appropriate course of action.  The self-disclosure guidelines are available on the OIG 
website at  https://oig.hhs.gov/compliance/self-disclosure-info/index.asp.  During this semiannual  
reporting period, provider self-disclosure cases resulted in more than $34.1  million  in HHS receivables.   
 
The following examples pertain to provider self-disclosure settlements: 
 
   Florida   After self-disclosing conduct to OIG, Shands Jacksonville Medical Center, Inc. d/b/a UF 
Health Jacksonville and  University of Florida Jacksonville Physicians, Inc. (collectively, 
Respondents), agreed to  pay more than $4.4 million to resolve its liability under the 
CMPL.   Specifically, OIG alleged that Respondents  presented false claims to Medicare and  
Medicaid for hospital and professional services associated with surgical procedures performed  
by ophthalmologist Kakarla Venkata  Chalam,  M.D., Ph.D., at UF Health Jacksonville, from April 8,  
2010, through April 7,  2016, when the record did  not support medical necessity for the 
procedures performed.  
 
   Maryland   After self-disclosing conduct to OIG,  St. Agnes Healthcare, Inc. (St. Agnes), agreed to 
pay more than $2.2  million to resolve its liability under the CMPL.   Specifically, OIG alleged that,  
from February  1, 2011, through July  1, 2017,  St. Agnes paid a physician excessive compensation 
in the forms of an inflated salary  and improper incentive and administrative payments to induce 
his referrals of  Federal health care program patients.  
CIAs   
Many health care providers elect to settle their cases before litigation.  As  part of the settlements,  
providers often agree to  enter into CIAs with OIG to avoid exclusions from  Medicare, Medicaid, and  
other Federal health care programs.  Under  a CIA, a provider commits to establishing a program  and 
taking other specified steps to ensure future compliance with Medicare and Medicaid rules.  The 
compliance programs are designed, in part, to prevent future fraud.  OIG monitors providers 
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compliance with these agreements and may impose penalties on entities  that fail to comply with the  
requirements of their CIAs.    
 
The following is a CIA enforcement example:  
 
   California   Chatsworth  Park Health Care Center (Chatsworth), Palm Terrace Care Center (Palm  
Terrace), and  Park Ridge Care Center (Park Ridge)skilled nursing facilities (SNFs) affiliated with  
North American Health Care, Inc. (NAHC)paid a  total of $843,106.04 to resolve their CMPL  
liability for employing  or  contracting with individuals who were excluded from participation in 
Federal health care programs to provide items or  services for which payment may be made 
under such programs.   Specifically, the settlement agreements resolve allegations that (1)  
Chatsworth employed an excluded individual from May 1,  2014, through December  19, 2016;  (2)  
Palm Terrace employed an excluded individual from January 24,  2006, through January 31, 2017;  
and (3) Park Ridge contracted with an excluded individual from May  20, 2012, through 
November  20,  2016.  NAHC disclosed this conduct to OIG pursuant to its obligations under its  
CIA with OIG.  NAHC entered into the CIA in 2016 in connection with its settlement of FCA  
liability based on the alleged provision of medically unnecessary rehabilitation therapy services  
provided to patients at SNFs that had service agreements with NAHC.  
 
Suspension and  Debarments  
Suspensions and debarments are administrative tools used by HHS  and other Federal agencies to  
protect the Government  from individuals and entities that have engaged in contract fraud, have 
misused grant funds,  or  are otherwise not presently responsible.  Because these are Government-wide  
sanctions, an individual or entity that has been suspended or debarred by  HHS or any  other agency is  
ineligible to participate in any future funding opportunities across the Federal Government for a  
specified period.   
 
OIG refers individuals and entities that have potentially engaged in grant  or contract fraud or  
misconduct to the HHS  official responsible for determining whether to impose a suspension or  
debarment.  OIG continues to develop  a robust  Suspension and  Debarment program and uses this tool  
to protect Government programs against fraud, waste, poor performance, and noncompliance with 
contract provisions or applicable law.  
 
The following examples  concern debarment of daycare providers:  
 
   Florida   Jacqueline Johnson, through her employment at the Childrens Home Society, engaged in 
a scheme to falsify and expedite applications to the Florida School Readiness Program.   According  
to the investigation, Johnson helped family  and friends receive subsidized daycare benefits they  
were not entitled to receive.   The referral forms Johnson completed designated the children as at-
risk and eligible to receive immediate placement  ahead of families already on a waiting list for  
these services.   Johnson entered into a plea agreement on five  felony charges of uttering forged  
instruments and was subsequently debarred  for  a 3-year period based on an OIG referral to the 
Department.   
 
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   Illinois   Bishop Herman Jackson was the owner and pastor of the Ark of Safety Apostolic Faith 
Temple.   He and his wife Jannette Faria operated three daycare centers  from 2002 to  2011 and  
received  childcare  subsidies from ACF  block  grants.  The investigation found that Jackson  and Faria 
enrolled children who did not financially qualify to receive subsidized daycare services.  Jackson and  
Faria also  falsely represented the names and number of children attending the daycare centers, the 
number of days the children attended, and whether the children attended full- or part-time to  
obtain subsidy payments they were not entitled to receive.   Jackson and Faria were found guilty  of  
mail fraud, wire fraud, and making false statements and were debarred for  a 3-year period based on  
an OIG referral to the Department.   
   
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Public Health Agencies   
Public  Health  Agencies  Reports  and  Reviews   
CDC  
 
Entities  Experiences  and  Perceptions  of  Reporting  the Theft,  Loss,  or  Release of  Select  Agents  or  
Toxins to  CDC  (OEI-04-15-00432), February 2018  
 
Congress and the media have devoted attention to several events at laboratories involving theft, loss, or  
release (TLR)  events  of select agents and toxins that have the potential to  pose severe threats to public  
health, such as anthrax or smallpox.  Entities that  work with select agents and toxins must report TLR  
events to the Federal Select Agent Program (FSAP), which is jointly managed by CDCs Division of Select  
Agents and Toxins and the U.S.  Department of Agricultures  Animal and Plant Health Inspection Service.    
 
We found that  all 21 entities in our review had been registered with FSAP for at least 6  years, and two-
thirds of them had reported at least 1 TLR event to  FSAP.   The remaining one-third had never reported  
a TLR event; however, we found no evidence that  any of the 21 entities were underreporting TLR events.   
In addition, we found that although entities are required to report TLR events to FSAP and  they  
identified benefits to reporting TLR events,  one-half of the entities in our review  reported  that obstacles  
to TLR events include a fear of negative consequences and a burdensome, restrictive reporting process.   
CDC may be able to better encourage reporting TLR events by addressing these obstacles,  improving  
entities training and guidance,  and further  fostering a culture of safety within FSAP that encourages  
such reporting.    
 
The findings identify potential actions that the CDC could take to encourage the reporting of TLR events  
and to increase entities compliance with FSAP.  This report contains no recommendations but offers  
suggestions that CDC could consider in its ongoing efforts to improve oversight of FSAP.  This is the 
second of three OIG reports on FSAP.     
 
The Association for Public Health  Laboratories Managed Global Health  Security Agenda Funds in  
Accordance With Federal Requirements  (A-04-17-02004),  February 2018  
 
The Association for Public Health Laboratories managed Global Health Security Agenda funds during  
the budget period July  1, 2015, through June 30, 2016, in accordance with Federal requirements.   
Accordingly, this report contained no recommendations.   
 
Presidents Emergency Plan for AIDS Relief  
The Presidents  Emergency Plan for AIDS Relief (PEPFAR) was authorized to receive $48 billion in 
funding for the 5-year period beginning October 1, 2008, to assist foreign countries in combating 
HIV/AIDS, tuberculosis, and malaria.  CDC awards PEPFAR funds to and works with ministries of health 
and other partners in 60 countries to combat HIV/AIDS  globally.  Additional funds were authorized to  
be appropriated through 2018.  
 
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During the semiannual reporting period, OIG issued one report  related to  PEPFAR funding:  
 
Aurum Institute Generally Managed and Expended  the Presidents Emergency Plan for AIDS Relief Funds  
in Accordance With Award Requirements  (A-04-17-01003), March 2018  
 
On the basis of our sample results, we concluded that Aurum Institute (Aurum) managed  and expended  
PEPFAR funds in accordance with the award requirements.  However, it did not always maintain  
segregation of duties  among different personnel  within the organization.   Additionally, Aurum used a 
procurement-management system that did not allow it to record an invoice with multiple items as  a 
single transaction  to  the general ledger. Finally, Aurum implemented corrective actions for all five 
recommendations from  our previous audit.   
 
The deficiencies we identified occurred because Aurum did not have the necessary financial staff to  
manage the extra duties  and responsibilities that  arose from its accelerated growth and because its 
procurement-management system had limited compatibility with its accounting system.  
 
Aurum agreed with our recommendation that it continue to (1) implement segregation of duties among  
different  key personnel and (2) upgrade its procurement and accounting systems to effectively track  
procurements.  
FDA  
 
Drug Supply  Chain  Security:  Dispensers  Received  Most  Tracing Information  (OEI-05-16-00550),  March  
2018  
 
Drug diversion, counterfeiting, and the importation of unapproved drugs  may result in potentially 
dangerous drugs entering the drug supply chain,  posing a threat to public  health and safety.  To  
enhance the security of this supply chain, the Drug Supply Chain Security  Act (DSCSA) requires trading  
partners in the drug supply chain to create a record of each drug product  transaction.   The FDA can  
then use such records to  investigate suspect and illegitimate drug products and potential diversion.  
 
This study is the second in a series of examinations of drug supply chain security, each following the  
implementation of various DSCSA provisions.  We found that all 40 selected dispensers received at least  
some drug product tracing information from their trading partners, and 26 of these dispensers received  
all required elements of this information.  The remaining 14 dispensers were missing a few of the 
required elements.  Two of these dispensers were unaware of  DSCSA and requirements for  drug 
product tracing.  DSCSA requires that dispensers receive complete tracing information before accepting 
ownership of a drug product. Although dispensers are generally implementing these requirements,  
missing information and  a lack of awareness of DSCSA requirements raise concerns that a complete 
tracing record for a drug  product may not  always  be available to support investigations of suspect and  
illegitimate drug products in the supply chain.  
 
To facilitate dispensers compliance with DSCSA,  we recommended that FDA offer educational outreach 
to dispensers where appropriate.  Specifically, we recommended that FDA provide education to ensure 
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dispensers understand their responsibilities to receive complete drug product tracing information from  
trading partners before taking ownership.  FDA concurred with our recommendation.  
NIH  
 
The National Institutes of  Health Did Not Always Administer Superfund Appropriations During Fiscal Year  
2015 in Accordance With  Federal Requirements  (A-04-16-04046),  February 2018  
 
During FY  2015, NIH did not always administer Superfund appropriations in accordance with applicable 
Federal requirements.   NIH generally obligated and disbursed Superfund appropriations.  However, NIH  
did not (1) always ensure that Superfund grantees complied with grant terms and conditions, (2)  
properly record  Superfund grant disbursements in NIHs  accounting system, and (3) always resolve 
audit findings contained  in grantee audit reports.  
 
NIH concurred with our recommendations that it formalize procedures for identifying and resolving  
improper account balances in NIHs accounting system and  that it  update guidance to require 
reconciliations between NIHs database for tracking audit reports and  audit report information that the 
National  External Audit Review Center generates.  NIH did not concur with our recommendations that it  
issue new or updated guidance related to grant monitoring  or  that it provide additional training  to  
grants management personnel.    
 
Legal  Actions and Investigations Related to  Public  Health Agencies  
Health Education Assistance Loan Program 
OIG excludes from Federal health care programs individuals who have defaulted on Health Education  
Assistance Loan (HEAL) loans.  Under the HEAL program, which stopped making loans in 1998, HRSA  
guaranteed commercial loans to students seeking education in health-related fields.  The students  can  
defer repayment of the loans until after they graduate and begin to earn income. Although HHSs  
Program Support Center  (PSC)  takes steps to ensure repayment, some loan recipients do not resolve 
their debt.   After  the PSC has exhausted efforts to  secure repayment of a debt, it declares an individual  
in default.  The Social Security Act  prevents  individuals  in default on their  HEAL loans from  receiving  
reimbursement under  Medicare, Medicaid, and all other Federal health care  programs.   
HEAL Exclusions    
During this semiannual reporting period,  28  individuals and related entities were excluded because of  a 
PSC  referral of their cases to OIG.  Individuals who have been excluded because of default may enter  
into settlement agreements whereby the exclusions are stayed while they  pay specified amounts each 
month to satisfy their debts.  If they default on these settlement agreements, they may be excluded  
until the entire debt is repaid, and they may not appeal the exclusions.   
 
After being excluded for nonpayment of their HEAL debts, 2,728  individuals chose to enter into  
settlement agreements or completely repay their debts.  That figure includes  46  individuals who  
entered into such settlement agreements or completely repaid their debts during this semiannual  
reporting period.  More than $215  million is being repaid through settlement agreements or through 
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complete repayment.  Of that amount, more than $3.7  million is attributable to this semiannual 
reporting period.   
 
The following are examples of settlement agreements.  These practitioners entered into settlement  
agreements  to repay the amounts indicated:  
   New York  Richard Maretzo, Jr., dentist - $412,929  
   Florida   Ana Maria Rodriguez,  dentist - $205,468  
 
Human  Services Agencies  Reviews  and  Enforcement  Activities  
 
ACF  
 
The Administration for Children and Families Region II Did Not Always Resolve Head Start Grantees  
Single Audit Findings in Accordance With Federal Requirements  (A-02-16-02009), February 2018,  
The Administration for Children and Families Region X Did Not Always Resolve Head Start Grantees  
Single Audit Findings in Accordance With Federal Requirements  (A-09-16-01004),  December 2017  
The Administration for Children and Families Did  Not Always Resolve American Indian and Alaska Native 
Head Start Grantees Single Audit Findings in Accordance With Federal Requirements  (A-06-17-07003),  
December 2017  
 
Head Start grantees are required to have single  audits conducted in accordance with Office of  
Management and Budget Circular A-133 (also known as A-133 audits) for fiscal years beginning before 
December 26, 2014.  For  Region II, Region X, and American Indian and Alaska Native Head Start  
grantees that submitted  audit reports to the Federal Audit Clearinghouse,  ACF did not always resolve 
recurring audit findings in accordance with Federal requirements and ACF  policies and procedures.  ACF  
did not issue letters transmitting management decisions within 6 months after receiving the reports, did  
not establish specific dates for grantees to correct deficiencies noted in the audit reports, or did not  
always follow up with grantees to ensure that they took corrective actions to resolve audit findings.    
 
ACF partly  agreed and partly disagreed with our recommendations to (1) review its staffing levels to  
ensure that the audit resolution process is conducted in accordance with Federal requirements,  
including the requirement to issue management decisions to grantees within 6 months; (2) provide 
training to Head Start grantees on implementing  corrective action plans; (3) include in the letters sent  
to Head Start grantees specific dates for correcting deficiencies; and (4) monitor Head Start grantees to  
ensure they  actually implement corrective actions.   
 
BCFS Health and Human  Services Did Not Always Comply With Federal Requirements Related to Less-
Than-Arms-Length Leases  (A-06-16-07007), January 2018  
 
While BCFS Health and Human Services (BCFS HHS) generally claimed only allowable expenditures, it  
did not comply with Federal regulations related to less-than-arms-length leases. A less-than-arms-
length lease is one under which one party to the lease agreement  can  control or substantially influence 
the actions of the other.   Of the 140 randomly selected transactions we reviewed, we determined that  
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138 were allowable, but  2 rental cost transactions for 1 less-than-arms-length lease were unallowable.   
We also identified additional rental costs on two less-than-arms-length leases that exceeded the 
amount allowable for such leases.  These unallowable rental costs on three less-than-arms-length 
leases totaled $658,248.   According to BCFS HHS  officials, they were unaware of the limitations on 
rental costs related to less-than-arms-length lease agreements.  
 
BCFS HHS did not concur with our recommendation  that it refund $658,248 to the  ACF  Office of 
Refugee Resettlement (ORR) for unallowable rental costs incurred under the less-than-arms-length 
lease agreements and limit future rental costs to  the amount that would be allowed  under  45 CFR part  
75.465(c).   
 
Office of Refugee Resettlement Unaccompanied Alien Children Grantee ReviewHis House   
(A-04-16-03566), December  2017  
 
His House Childrens Home, Inc. (His House), an Unaccompanied Alien Children (UAC) grantee 
responsible for caring for children in ORR custody, met safety standards for the care and release of  
children in its custody.   However, some UAC case files were missing evidence of sponsor background  
checks and other required documentation.   While His House claimed only allowable expenditures, we 
identified areas in which  His House lacked an efficient and effective system of internal controls when 
administering UAC program funds.  
 
As a result, His House (1) might not have followed ORR policies for 652 children regarding sponsor  
background checks, prompt medical care, provision of appropriate clothing, sponsor placement  
decisions, postrelease services, or the notification of the Department of Homeland Security of the childs  
release to a sponsor; and (2) might have placed Federal funds totaling  $9 million at risk of  
mismanagement or misappropriation.  
 
His House  did not agree with our findings; however, it  concurred with our recommendations that it  (1)  
develop a policy for maintaining UAC case file documentation that would ensure ORR policies and  
procedures were followed when releasing a child to a sponsor; (2) increase oversight of its reviewing 
process for UAC case files to ensure that all required documentation is maintained in the file; and (3)  
implement a financial management system that requires adequate identification of  the source and  
application of Federal funds and effective accountability of property and other assets.   We also made  
procedural recommendations aimed at addressing internal control deficiencies we identified, with  which  
His House also concurred.   
  
Pine Bluff Jefferson County Economic Opportunities Commission Did Not Always Operate Its Head Start  
Program in Accordance With Federal Requirements  (A-06-16-00013),   
December 2017  
 
Pine Bluff Jefferson County Economic Opportunities Commission (Pine Bluff) did not always claim Head  
Start grant costs that were allowable and allocable in accordance with Federal regulations.   Specifically,  
Pine Bluff claimed $392,094 of unsupported non-Federal share,  $214,372 in costs that did not meet 
procurement-related requirements, and $123,158  in costs that either did not or may not have benefited  
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the Head Start program.  In addition, Pine Bluff did not always manage the Head Start program in  
accordance with Federal requirements.   
 
Pine Bluff partly  agreed  with our  findings and associated  recommendations that it work with ACFs  
Office of Head Start to determine and refund the amount of grant funds  for which Pine Bluff would  not  
have been eligible because of the $392,094 of unsupported non-Federal  share;  refund $214,372 for  
procurement-related costs that that did not meet requirements; and refund costs that did not benefit 
the Head Start program and work with  the Office of Head Start  to determine what portion of costs  
allocated to the Head Start program should be allocated to its other programs.  We also made policy  
and procedural recommendations for  Pine Bluff to account for and manage Federal funds and to  
operate its Head Start program in accordance with Federal regulations.  For the findings and  
recommendations with which Pine Bluff did concur, it provided information on corrective actions  it has  
taken our plans to address them.   
 
Not All of Missouris Child Care Subsidy Program Payments Complied With Federal and State 
Requirements  (A-07-15-04226), November 2017  
 
Missouri did not always comply with Federal and State requirements when making payments under  its  
Child Care subsidy program for State  FYs 2014 and 2015.   Client attendance records were not  
adequately documented, and Missouri did not exercise sufficient oversight over its Child Care Subsidy  
program.  On the basis of our sample results, we estimated that at least $19.1 million (Federal share) of  
the Child Care Subsidy program payments that  Missouri made did not comply with Federal and State 
requirements.  
 
Missouri partly agreed  and partly disagreed with our recommendations that it refund the estimated  
$19.1  million (Federal share) of Child Care Subsidy program payments to the Federal Government,  
strengthen its controls and oversight activities to ensure that providers maintain required attendance 
documentation to support the childcare payment  amounts that they claim for reimbursement,  and  
develop policies and procedures to ensure that it obtains attendance records from providers that are no  
longer in business.   
 
Southeast Arkansas Community Action Corporation Did Not Always Operate Its Head Start Program  in  
Accordance With Federal Regulations  (A-06-16-00015), October 2017  
 
Southeast Arkansas Community Action Corporation (Southeast) did not always operate its Head Start  
program in accordance with Federal regulations  and did not always manage and account for Federal  
funds.   Specifically, Southeast (1) had ineffective controls and accountability over its assets, (2) used  
questionable methods to allocate shared costs, (3) did not have required fiscal or legal expertise on its  
governing board, and (4) claimed some unallowable costs.  
 
Southeast generally concurred with our recommendations that it (1) conduct a full physical inventory to  
ensure inventory asset records are accurate and complete, follow its existing purchasing policy to  
submit a purchase requisition one week in advance, and expand its purchasing policies to include 
review procedures for credit card purchases and  consequences for unauthorized purchases; (2) work  
with the Office of Head Start to ensure shared costs claimed during our audit period are allocated  
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correctly; (3) elect members to the board of directors who have legal and  financial expertise or hire a  
consultant or another individual with relevant expertise; and (4) refund  $4,784 in unallowable costs.  We 
also made other procedural  recommendations.    
 
Safety  of Children in Foster Care  
 
Some Massachusetts Group  Homes for Children in Foster Care Did Not Always Comply With  State Health  
and Safety Requirements  (A-01-16-02500), December  2017   
 
Some Ohio Group Homes Did Not Always Comply  With Foster  Care Health  and Safety Requirements  (A-
05-16-00049),  February 2018  
 
Some Washington State Group-Care Facilities for Children in Foster Care Did Not Always Comply With  
State Health and Safety Requirements  (A-09-16-01006),  March 2018  
  
Although Massachusetts  and Ohio conducted the required inspections at all 30 of the group homes  we 
reviewed in each State, and Washington performed required onsite monitoring at all 20 of the group 
homes we reviewed, this monitoring did not ensure that the  group homes that received funds under  
Title IV-E of the Act complied with State requirements related to the health and safety of children in 
foster care.  In Massachusetts, 27 group homes did not comply with 1 or more State requirements; in 
Ohio, 19 of the 30 homes we reviewed did not comply with 1 or more requirements; and in Washington,  
none of the 20 homes we reviewed  complied  with 1 or more requirements.   
 
Ohio  was in accordance  with our recommendations that it (1) ensure that all instances of  
noncompliance are documented and corrected; (2) ensure that the group homes adhere to all  
requirements for the health and safety of children by continuing onsite visits;  and (3) ensure that group 
homes obtain the required criminal record checks for all employees  who  provide direct care to children.   
It concurred with our fourth recommendation  to  consider additional outreach programs for the group 
homes, such as training and technical assistance in the areas identified as noncompliant.  
  
Massachusetts  concurred  with our recommendations that it (1) work with the State licensing agency to  
correct all instances of noncompliance; (2) increase the frequency of announced visits and consider  
including unannounced visits as part of its monitoring system; and (3) work with the State licensing 
agency to ensure that all group home employees  who have the potential for unsupervised contact  with 
children receive all of the required background record checks within a specific and reasonable 
timeframe.   It said it would take under consideration our recommendation to  consider adding a  
requirement in future contracts that the group homes conduct repairs and general upkeep within a  
specified timeframe.  
 
Washington concurred with our recommendations that it (1) ensure that all instances of noncompliance 
that we identified are documented and corrected; (2)  conduct unannounced visits for health and safety  
reviews of group care facilities; (3)  ensure that regional licensors perform  and document a site 
inspection during each health and safety visit at a group care facility; (4)  ensure that regional licensors  
and group care facilities have adequate training and guidance on the best practices for administering  
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medications and maintaining related documentation; (5)  provide regional licensors and group care 
facilities with adequate guidance and supervision regarding background check requirements; (6) ensure 
that the handbook  Minimum Licensing Requirements for Group  Care Facilities  is updated with the latest 
background check requirements; and (7) consider  requiring FBI fingerprint-based background checks  
for all group care facility employees, seeking additional legislative authority as needed.  
 
Oklahoma Did Not Always Comply With Requirements for Providing Health  Care Services to Children in  
Foster Care  (A-06-16-07006),  February 2018  
 
Oklahoma did not always ensure that there was documentation in the case files of Title IV-E eligible  
children supporting that they had received required health care services designed to protect their  
health and safety.  We found that 17 of the 70 case files we reviewed did not contain evidence to  
support that required health care services were provided.  For 7 of the 17 children whose case files  
lacked documentation, there were Medicaid claims in the MMIS to support that all required health  
services had been provided.  However, for 10 of these children, there was no Medicaid claim to support  
that dental care was provided during the year.     
 
Oklahoma did not follow its policies and procedures to ensure there was evidence in Title IV-E case files  
to support that all required health care services were provided to Title IV-E children in foster care.  Nor  
were there Medicaid claims in the States MMIS to support that all children whose case files lacked  
documentation received the required services.  These documentation failures demonstrate that Title IV-
E eligible children in foster care may not be receiving required health care services.  
 
Oklahoma  agreed with our recommendation that  it follow its policies and  procedures to ensure that  
Title IV-E eligible children in foster care receive required health care services and that the visits are 
documented in the childrens case files.    
 
HRSA  
 
Henry J. Austin Health Center, Inc., a Health Resources and Services Administration Grantee, Did Not  
Comply With Federal Grant Requirements  (A-02-17-02002), February 2018  
 
HRSA awarded Henry J.  Austin Health Center, Inc. (HJAHC), a not-for-profit organization, $8.3 million in  
grant funds through several Community Health Center Program grants to provide comprehensive 
primary care services in the Trenton, New Jersey,  area.  
  
HJAHC did not comply with Federal requirements  related to its Community Health Center Program  
grants. Specifically, HJAHC did not track and account for grant expenditures separately from other  
Federal and non-Federal operating expenses, did  not reconcile actual grant expenditures to its  
approved budgeted  amounts used to draw down Federal funds,  and did not maintain documentation 
that supported grant expenditures for certain activities.   As a result, we could not determine whether $8  
million in costs claimed by HJAHC for certain Community Health Center  Program grants were allowable.   
In addition, HJAHC claimed costs totaling $243,000 for certain activities that were unallowable.  
 
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HRSA concurred with our recommendations that it (1) require HJAHC to refund $8 million to the Federal  
Government or work with HJAHC to determine what portion of these costs claimed to the Community  
Health Center Program grants were allowable; and (2) require HJAHC to refund $243,000 to the Federal  
Government for unallowable costs.   We also made procedural recommendations.   
  
HRSA Complied With Federal and HHS Grant Policies When Awarding Zika Response and Preparedness  
Appropriations Act Funds  During Fiscal Year 2017  (A-04-17-02003), October  2017  
 
We reviewed all 30 grants that HRSA awarded from October 1, 2016, through March 15,  2017,  for Zika  
response activities.   For these 30 grants, HRSA awarded Zika Act funds in compliance with applicable 
Federal and HHS grant policies.   Accordingly, this  briefing  report contained no recommendations.    
 
Child Support Enforcement Activities  
 
OIG Investigations 
OIG investigates noncustodial parents who violate 18 U.S.C.  228 by failing to pay court-ordered child 
support.  OIG works with ACFs Office of Child Support Enforcement;  DOJ;  U.S. Attorneys offices; the 
U.S. Marshals Service; and Federal, State,  and local partners to address egregious child support  
enforcement cases with appropriate law enforcement and prosecutorial action.  During this semiannual  
reporting period, OIG investigations of child support enforcement cases nation-wide resulted in 
10  criminal actions and court-ordered restitution and settlements of  $595,294.   
 
The following is an example of a child support enforcement case: 
 
   North Dakota  In August 2001, Jay Harding was  ordered to pay $385 per  month for the support of  
his two children.  This amount of ordered support  was later raised to $822 in 2005.  Harding only  
occasionally made payments to the custodial parent of his children, and last made a payment in 
2013.  Harding was sentenced to  1  year of probation and ordered to pay restitution of $195,311.02  
after pleading guilty to failure to pay child support.   
 
Engaging the Public in Capturing Deadbeat Parents 
Because of the success of OIGs Most Wanted Fugitives website, OIG launched its Most Wanted  
Deadbeat Parents website.  The site identifies parents who fail to pay court-ordered child support for  
their children and thereby put an unnecessary strain on the custodial parents and the children as well as  
on agencies that enforce these matters.  The site,  which is updated frequently, includes information on 
OIGs role in pursuing parents who fail to pay court-ordered child support.  OIGs Most Wanted  
Deadbeat Parents website can be found at  https://oig.hhs.gov/fraud/child-support-
enforcement/index.asp.    
 
   
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  Department of Health and Human  Services Office of Inspector General  
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Other HHS-Related Reviews and Investigations  
Grants and Contracts   
 
HHS is the largest grant-making organization and one of the largest contracting agencies in the Federal  
Government.  In FY 2017, HHS awarded more than $481 billion in grants and over $24 billion in contracts  
across all program  areas.  OIGs direct annual discretionary  appropriation funding is used to conduct program  
integrity and enforcement activities  for  the more than 100 public health and human services programs carried  
out by more than 70,000  employees around the world.  The size and scope of departmental awards  make their  
operating effectiveness crucial to the success of programs designed to improve the health and well-being of  
the public.   
Reviews  
 
The following is a case example related to misuse of grant funds:  
 
   Montana  Former Rocky Boy Health  Board  (RBHB)  interim Chief Financial Officer (CFO)  Kathy  
Sutherland  devised  a scheme to  defraud  the RBHB clinic, a health  care benefit program  that 
provides a variety of medical services to residents of the Chippewa Cree Tribal community.  The  
RBHB receives Federal funding to operate the clinic, including  IHS self-governance compact funds.   
In her roles as cash and  grants manager  and interim  CFO, Sutherland was  responsible for  
administering RBHBs employee loan program.  From approximately November 2005 until May  
2015, Sutherland  fraudulently disbursed  over $111,902 in loans  from the RBHB to herself without  
the necessary approvals.  Sutherland pleaded guilty to wire fraud and was sentenced to a prison 
term of 12 months and 1  day and ordered to pay  restitution of $111,902.    
 
The following is a case example related to misuse of contract funds:  
 
   Georgia   Juan Carlos Bazantes and Cesar Arbelaez Tabares owned and operated IWES Contractors,  
Inc., a drywall labor supply company in  Norcross, Georgia.   The investigation disclosed that from 
January 2012 through April 2013, Bazantes and Tabares conspired to mislead  Government  
construction project managers at the CDC by submitting false payroll certifications.        Bazantes  
and Tabares  falsely certified to the CDC that they  were collecting Federal employment taxes from  
their workers when in fact no such taxes were being collected.  To carry out their scheme, Bazantes  
and Tabares  kept two sets of books. One set falsely certified to the Government  that taxes were  
being withheld from the workers pay, and  another accurately reflected that the workers' pay was  
not being taxed.   This scheme left the workers responsible for the entire tax liability. A jury found  
Bazantes and Tabares guilty of  making false statements and conspiracy to  defraud the United  
States.   Bazantes and Tabares were each sentenced to 8 years in prison and ordered to pay $75,000  
in fines.   
 
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Small Business  Innovation  Research Program   
The National Defense Authorization Act for Fiscal Year 2012,  5143, requires OIG to report annually on the 
number  of cases referred to OIG to fraud, waste, or abuse in the Small Business Innovation  Research/Small  
Business Technology  Transfer (SBIR/STTR) program.   OIG must also report on the actions taken in each case;  
justification for not taking action on a case; and an accounting of funds used  to address waste, fraud, and abuse in 
this program.  In  our November 2017 report delivered to the three congressional oversight committees, we 
reported that OIG spent approximately $446,016 in salaries on  oversight related to the SBIR/STTR  program.   In FY  
2017,  six  new SBIR/STTR  cases were referred to OIG.  
 
Recovery Act Retaliation Complaint  Investigations  
The Recovery Act,  1553, prohibits non-Federal employers that have received Recovery Act funding from  
retaliating against employees who disclose evidence of mismanagement of Recovery Act funds or any violation 
of law related to Recovery Act funds.  OIGs are required to include in their Semiannual Report the retaliation 
complaint investigations that they decided not to  conduct or continue during the reporting period.  During this  
semiannual  reporting period, OIG closed one  investigation, in which  no instances of whistleblower retaliation 
were identified.  
Contract Audits  
Pursuant to the National  Defense Authorization Act for FY 2008,  845, OIGs appointed under the Inspector  
General Act of 1978  (IG Act)  are required to submit, as part of their semiannual report, pursuant to section 5 of  
the IG Act, information on final completed contract audit reports issued to the contracting  activity during  the 
period.  This information must contain significant audit findings.  OIG issued no final reports meeting  845 
criteria during this semiannual period.    
OIG Reviews of  Non-Federal Audits   
OIG reviews audits conducted by non-Federal auditors of entities receiving Federal awards.   During this  
semiannual reporting period, OIGs National External Audit Review Center reviewed  882  reports covering 
$658.6  billion in audited  costs.  Federal dollars covered by these audits totaled $121.4  billion, of which about  
$66.2  billion were HHS funds.    
The regulation at 45 CFR, subpart F, establishes  audit requirements for certain State and local governments,  
colleges and universities, and nonprofit organizations receiving HHS awards.  Entities subject to part 75s  
single-audit requirements must conduct annual organization-wide single audits.  These audits are conducted  
by non-Federal auditors,  such as public accounting firms and State auditors.  OIG reviews the quality of these 
audits and assesses the adequacy of the entities management of Federal funds.    
OIGs oversight of non-Federal audit activity informs Federal managers about the soundness of management of  
Federal programs and identifies any significant areas of internal control weakness, noncompliance,  and  
questioned costs for resolution or  follow-up.   We identify entities for high-risk monitoring, alert program  
officials to any trends that could indicate problems in HHS programs, and  profile non-Federal audit findings of  
a particular program or activity over time to identify systemic problems.  We also provide training and technical  
assistance to grantees  and members of the auditing profession.  OIG maintains a process to assess  the quality  
of the non-Federal reports received and the audit work that supports the selected reports.    
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  Department of Health and Human  Services Office of Inspector General  
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The following table categorizes OIGs reports on non-Federal audits reviewed during this reporting period:  
Non-Federal Audits,  October 1, 2017, through March 31, 2018  
Number  of Non-Federal Audits    
Not requiring changes or having   830  
minor changes   
Requiring major changes   51  
Having significant technical  1  
inadequacies  
  Total   882  
The 882 reports included 1,657  recommendations for improving management operations.  In addition,  
these audit reports provided information for  26  OIG special memorandums that identified concerns for  
increased monitoring by  management.  
Other Reporting  Requirements  and Reviews  
 
Legislative and Regulatory Reviews   
Pursuant to the IG Act,   4(a)(2), OIG is required to review existing and proposed legislation and  
regulations relating to HHSs programs  and operations and make recommendations concerning their  
impact on  economy and efficiency or the prevention and detection of fraud and abuse.   Most audits  
and other reviews that we conduct are designed to test compliance with and/or assess the 
administration and oversight of existing laws and regulations.  Our reports  of such reviews describe 
findings, which include questioned costs, inefficiencies, vulnerabilities to fraud, inconsistencies, errors in 
application, or weaknesses in oversight or supporting systems.  Our corresponding recommendations  
tell HHS and its operating or staff divisions what  administrative, regulatory, or legislative actions we 
believe are needed to effectively respond to the findings.  Our regularly published core publications  
reflect the relationship between our work and laws and regulations.  
   Our  Semiannual Report to Congress  describes findings and recommendations from recently 
completed reviews, many of which focus on existing laws and regulations.    
   Our  Compendium of Unimplemented Recommendations  describes priority findings and  
recommendations from  past periods that remain to be implemented.    
   Our  Work Plan  provides  citations to laws and regulations that are the subject of ongoing or  
future reviews.  
We also review proposed legislation and regulations related to HHS programs and operations.  HHS  
routinely involves OIG and HHS  OPDIVs and other  STAFFDIVs  in the review and development of HHS  
regulations through a well-established HHS process.  Our audits, evaluations, and investigations are  
sometimes cited in regulatory preambles as influencing HHS regulations.  In addition, we provide 
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  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
independent, objective technical assistance on a bipartisan, bicameral basis to congressional  
committees and  Members  who request it.   
Health Insurance Marketplaces   
Key focus areas for  our oversight of the health insurance marketplaces  include payment accuracy,  
eligibility, management and administration, and security.  In developing our work plan, we coordinate 
with GAO and other Federal and State oversight  agencies.   
 
New York Did Not  Comply With Federal Grant  Requirements for Allocating and Claiming Marketplace 
Contract Costs  (A-02-15-02008),  December 2017  
 
New York did not always  follow Federal requirements for allocating and claiming contract costs to its  
grants for establishing New Yorks marketplace customer service center.   Specifically, New York may 
have misallocated costs totaling nearly  $19.6 million and claimed unallowable profit fees and other 
costs totaling nearly  $3.8 million.  
 
This occurred because New York did not have written policies that explained how to properly  allocate 
costs when it developed its original cost allocation plan.   Further, New York did not establish a basis for  
the profit fee rate with its contractor, Maximus, Inc., at the beginning of the contract; did not require 
Maximus to always use its final cost rate for general and administrative costs; and did not require 
Maximus to retroactively  adjust the calculation of its profit fee and general and administrative costs by  
removing project costs that should not have been subject to these charges.  
 
New York generally disagreed with our recommendations that it (1) refund to CMS  $19.6 million that  
may have been misallocated to the establishment grants or work with CMS  to determine the 
appropriate allocation to the grants; (2) refund to CMS  $797,096 in unallowable profit fees or work  with 
CMS to determine the appropriate amount that should have been claimed to the grants; (3) refund to  
CMS  $32,083 in unallowable general and administrative costs and related profit fees; and  (4) work with  
CMS to ensure that  Maximus contract costs claimed after our audit period are properly allocated.   
 
Review of The Department of Health and Human Services (HHS) Cancellation of Marketplace Enrollment  
Outreach Efforts  (OEI-12-17-00290), October 2017  
 
In response to a congressional request, the OIG conducted a descriptive, fact-finding review of HHSs  
cancellation of certain Marketplace enrollment outreach activities (outreach  activities) before the 
January 31st  end of the fourth open enrollment period.  
 
OIG determined that HHS canceled and then reinstated certain outreach activities on January  26  and 27,  
2017.  An official on the HHS Beachhead  team  orally instructed HHS officials to cancel Marketplace  
outreach, and that same official later provided updated instructions about  which outreach should  
remain canceled and which should resume.   However, we were unable to determine conclusively  
whether that individual made the decision to cancel outreach or merely conveyed the decisions made 
by someone else.  In addition, HHS officials conducted a preliminary assessment of costs and savings  
associated with canceling certain outreach activities, but reported that they did not perform any  
analyses of the impact that canceling outreach activities would have on Marketplace enrollment.   
53  
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Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
 
Information Security 
These summaries do not  include details of the vulnerabilities that we identified because of the sensitive nature 
of the information.   
Summary  Report for Fiscal Year  2016 OIG Penetration Testing of Four HHS Operating  Division Networks  
(A-18-17-08500),  December 2017  
 
We conducted a series of OIG audits at four HHS  OPDIVs using network and web application 
penetration testing to determine how well HHS systems were protected when subject to cyberattacks.   
 
Security controls across the four HHS OPDIVs needed improvement to  more effectively detect and  
prevent certain cyberattacks.   During testing, we identified configuration management and  access  
control vulnerabilities.   
 
We shared with senior-level information technology personnel the common root causes for the 
vulnerabilities we identified across the OPDIVs we tested.   We provided actionable information 
regarding HHSs cybersecurity posture, information on common vulnerabilities, recommendations and  
strategies to mitigate exploited weaknesses, key indicators to better identify signs of  attack or  
compromise, and lessons learned during testing.  
 
The four HHS OPDIVs that were part of the penetration testing generally concurred with our summary  
findings and conveyed that the vulnerabilities identified were corrected or were in the process of being 
corrected.    
 
 
 
   
54  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
 
Appendix  A: Questioned Costs  and Funds  To Be 
Put  to Better Use  
The following tables summarize OIGs monetary recommendations and HHS responses to them.  This  
information is provided in accordance with the IG  Act,  5(a)(8) and  (a)(9)  (5 U.S.C.  App.   5(a)(8)  and (a)(9)),  
and the Supplemental Appropriations and Rescissions Act of 1980.    
Audit Reports with Questioned Costs  
 
As defined by the IG Act, the term questioned cost means a cost that is questioned by the OIG because of (1)  
an alleged violation of  a provision of law, regulation, contract, grant, cooperative agreement, or other  
agreement or document  governing the expenditure of funds;  (2)  a cost that is not supported by  adequate 
documentation at the time of the audit; or (3) the expenditure of funds  for the intended purpose is  
unnecessary or  unreasonable.   Questioned costs that HHS program  officials have, in a management decision,  
sustained or agreed should not be charged to the Government are disallowed costs.    
 
 
   
55  
  Department of Health and Human  Services Office of Inspector General  
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Table 1  
      Dollar Value  
Unsupported  
ll   l 
Section 1        
Reports for which no management decisions had been made by   156   $547,757,000   18,792,000  
the beginning of the reporting period1  
Reports issued during the reporting  period   39   $680,031,000   20,007,000  
  Total Section 1   195   $1,227,788,000   $38,799,000  
       
Section 2        
Reports for which management decisions were  made  during the        
reporting period2,  3  
  Disallowed Cost*   108   $187,519,000   $0  
  Costs not disallowed   22   $57,524,000   $14,000  
  Total Section 2   130   $245,043,000   $14,000  
*Audit receivables (expected recoveries)        
Section 3        
Reports for which no management decisions had been made by   65   $982,745,000   $38,785,000  
the end of the reporting period2 (Section 1 minus Section 2)  
Section 4        
Reports for which no management decisions were made within  37   $361,725,000   $18,778,000  
6  months of issuance4  
 
   
56  
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Audit Reports  With  Funds Recommended To Be Put to Better Use   
The phrase recommendations that funds be put to better use means that funds could be used more 
efficiently if management  acted  to implement an OIG recommendation through reductions in outlays,  
deobligation of funds, and/or avoidance of unnecessary expenditures.  Table 2 reports HHS program officials  
decisions to  act  on these audit recommendations.    
 
Table 2  
  Reports   Dollar Value  
Section 1      
Reports for which no management decisions had been made by the beginning of  9   $17,760,976,000  
the reporting period1  
Reports issued during the reporting period   3   $156,476,000  
  Total Section 1   12   $17,917,452,000  
     
Section 2      
Reports for which management decisions were  made  during the reporting period      
Value of recommendations  agreed to       
by management  
  Based on proposed  management  action   4   $1,456,581,000  
  Based on proposed  legislative action   0   0  
     
Value of recommendations  not agreed to by management  
0   0  
  Total Section 2   4   $1,456,581,000  
     
Section 3      
Reports for which no management  decisions had been made by the end of the  8   $16,460,871,000  
reporting period2 (Section 1 minus  Section 2)  
 
Notes  to  Table  1  
1  The opening balance was adjusted upward by $36.2  million because of a reevaluation of previously issued  
recommendations.   
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2  Revisions to previously  reported management decisions:  
   Hoveround  Corporation Claimed Millions in Federal Reimbursement for Power Mobility Devices that Did  
Not Meet Medicare Requirements  (A-05-12-00057), December 2015.   A settlement agreement between 
CMS and Hoveround reduced overpayment cost of $14,731,534 to $2,000,000.   As  a  result, disallowed  
cost was reduced by $12,731,554.  
   Review of Practitioner  Compliance with the Requirements of the Hurricane Katrina Health-Care-Related  
Professional Workforce Supply Grant for the Greater New Orleans Area  (A-06-09-00051), July 2011.   
Subsequent review by CMS and the State determined that $8,317,791 of $13,629,287 in questioned  
cost, would be returned to the Federal  Government.   Disallowed cost was reduced by $5,311,496.  
   Florida Did Not Suspend  Medicaid Payments to Some Providers that had Credible Fraud Allegation  Cases  
in Accordance With the Social Security Act  (A-04-14-07046), April 2017.   CMS and  DOJs subsequent  
review of supporting documentation resulted in a settlement agreement with the State, reducing 
disallowed cost from $8,056,973 to $2,783,523.  Resulted  in the reduction of disallowed cost by  
$5,273,450.  
   Florida Managed Care Organizations  Received Medicaid Capitation Payments After Beneficiarys Death  
(A-04-15-06182),  November 2016.   State identified additional overpayment in subsequent review and  
refunded $4,984,642  to the Federal Government.  
   Not detailed are reductions to previously disallowed management decisions totaling $8.9 million.    
 
3 Included are management decisions to disallow $20.3  million in questioned costs that were identified by non-
Federal auditors in audits of State and local governments, colleges and universities, and nonprofit  
organizations receiving Federal awards conducted in accordance with Office of Management and Budget  
Circular A-133.  OIG is currently ensuring that work performed by these non-Federal auditors complies with 
Federal audit standards;  accordingly, OIG tracks, resolves, and reports on recommendations in these audits.  
4 Because of administrative delays, some  of which were beyond management control, resolution of the 
following  37  audits  was  not completed within 6 months of issuance of the reports; however, agency  
management has informed us that the agency is  working to resolve the outstanding recommendations before 
the end of the next semiannual reporting period:  
 
CIN: A-02-14-02017   NEW YORK MISALLOCATED  COSTS  TO ESTABLISHMENT GRANTS FOR A HEALTH      
INSURANCE MARKETPLACE, NOV  2016, $149,654,512  
 
CIN: A-09-16-02026      MEDICARE INAPPROPRIATELY PAID ACUTE-CARE HOSPITALS FOR OUTPATIENT 
SERVICES THEY PROVIDED TO BENEFICIARIES  WHO WERE INPATIENTS  OF  
OTHER FACILITIES, SEP 2017, $51,640,728  
 
CIN: A-01-02-00006      REVIEW OF  RATE SETTING METHODOLOGY MEDICAID SCHOOL-BASED  CHILD  
HEALTH PROGRAM COSTS  CLAIMED BY THE CONNECTICUT DEPARTMENT OF  
SOCIAL SERVICES, JULY  1997 THROUGH JUNE 2001, MAY  2003,  $32,780,146  
 
CIN: A-01-14-02503      MARYLAND MISALLOCATED  MILLIONS TO ESTABLISHMENT GRANTS FOR A 
HEALTH INSURANCE MARKETPLACE, MAR  2015,  $28,400,000  
 
58  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
CIN: A-07-13-01125      MEDICARE  IMPROPERLY PAID MEDICARE ADVANTAGE ORGANIZATIONS  
MILLIONS OF DOLLARS  FOR UNLAWFULLY PRESENT BENEFICIARIES FOR  2010  
THROUGH 2012, APR 2014, $26,150,043  
 
CIN: A-04-14-07050     KENTUCKY MISALLOCATED  MILLIONS TO ESTABLISHMENT GRANTS FOR  A  
HEALTH  INSURANCE MARKETPLACE,  FEB 2017, $25,530,429  
 
CIN: A-01-15-02500       VERMONT DID NOT  PROPERLY ALLOCATE MILLIONS TO ESTABLISHMENT 
GRANTS FOR A HEALTH  INSURANCE MARKETPLACE, SEP  2016, $11,243,006  
 
CIN: A-02-14-02024     NEWARK PRESCHOOL COUNCIL, INC., DID  NOT  ALWAYS COMPLY WITH  HEAD 
START REQUIREMENTS,  FEB 2017,  $9,950,556  
 
CIN: A-02-12-02012       NEW YORK IMPROPERLY CLAIMED  SOME CHILD CARE AND DEVELOPMENT  
TARGETED FUNDS, JUL  2015, $3,827,836  
 
CIN: A-02-14-02012      VISITING NURSE SERVICE OF NEW YORK BUDGETED  COSTS THAT WERE  NOT  
APPROPRIATE AND CLAIMED SOME UNALLOWABLE  HURRICANE SANDY  
DISASTER RELIEF ACT  FUNDS, NOV 2016,  $3,771,672  
 
CIN: A-05-13-00014       OHIO EXCEEDED THE 5-PERCENT LIMIT FOR CLAIMING CHILD CARE 
DEVELOPMENT FUND ADMINISTRATIVE EXPENDITURES, NOV 2013, $3,164,630  
 
CIN: A-05-14-00047      MEDICARE PAID HUNDREDS OF MILLIONS IN  ELECTRONIC HEALTH RECORD  
INCENTIVE PAYMENTS THAT DID NOT COMPLY  WITH FEDERAL REQUIREMENTS,  
JUN  2017, $2,635,902  
 
CIN: A-05-15-00026     MINNESOTA DID NOT  ALWAYS COMPLY  WITH FEDERAL AND STATE  
REQUIREMENTS FOR CLAIMS SUBMITTED FOR THE NONEMERGENCY MEDICAL 
TRANSPORTATION PROGRAM, SEP  2017, $1,871,457  
 
CIN: A-07-11-06013        THE UNIVERSITY  OF COLORADO DENVER  DID NOT ALWAYS CLAIM  SELECTED 
COSTS  CHARGED DIRECTLY TO DEPARTMENT OF  HEALTH AND HUMAN  
SERVICES AWARDS IN ACCORDANCE WITH  FEDERAL REGULATIONS, JUN  2013,  
$1,419,524  
 
CIN: A-05-14-00045      THE  MINNESOTA MARKETPLACE MISALLOCATED  FEDERAL FUNDS AND 
CLAIMED UNALLOWABLE  COSTS,  NOV 2016, $1,279,677  
 
CIN: A-07-16-04230       THE THREE AFFILIATED TRIBES  IMPROPERLY ADMINISTERED LOW-INCOME  
HOME ENERGY  ASSISTANCE  PROGRAM FUNDS FOR  FYS 2010 THROUGH  2014,  
JUL  2017, $1,221,425  
 
CIN: A-05-12-00089      THE COUNCIL ON RURAL  SERVICE PROGRAMS, INC., CLAIMED UNALLOWABLE  
HEAD START COSTS, NOV 2013,  $1,074,352  
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  Department of Health and Human  Services Office of Inspector General  
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CIN: A-09-14-01007       NEVADA MISALLOCATED COSTS FOR  ESTABLISHING A HEALTH INSURANCE  
MARKETPLACE TO ITS ESTABLISHMENT GRANTS,  FEB 2016,  $893,464  
 
CIN: A-04-15-04040      MEDICAL ACCESS UGANDA LIMITED GENERALLY  MANAGED THE PRESIDENT'S  
EMERGENCY  PLAN FOR  AIDS RELIEF  FUNDS IN ACCORDANCE WITH AWARD  
REQUIREMENTS, JUN 2016, $751,399  
 
CIN: A-02-15-02009       ECONOMIC OPPORTUNITY COMMISSION OF NASSAU COUNTY, INC.,  CLAIMED  
SOME UNALLOWABLE HURRICANE SANDY DISASTER RELIEF ACT FUNDS,  APR  
2017, $614,278  
 
CIN: A-07-16-04233      THE  TURTLE MOUNTAIN BAND  OF CHIPPEWA INDIANS IMPROPERLY  
ADMINISTERED SOME LOW-INCOME HOME ENERGY  ASSISTANCE PROGRAM  
FUNDS FOR FISCAL YEARS 2010 THROUGH 2013,  SEP 2017, $587,248  
 
CIN: A-09-11-01007        HAWAII CLAIMED  UNALLOWABLE COMMUNITY SERVICES BLOCK  GRANT COSTS  
FOR HONOLULU COMMUNITY ACTION PROGRAM, INC.'S EXPENDITURES  
UNDER THE RECOVERY  ACT, FEB  2013, $513,649  
 
CIN: A-04-16-04044      THE MINISTRY OF HEALTH AND SOCIAL WELFARE NATIONAL AIDS CONTROL 
PROGRAM DID  NOT ALWAYS MANAGE AND  EXPEND PEPFAR  FUNDS  IN  
ACCORDANCE WITH AWARD REQUIREMENTS, AUG  2017, $495,379  
 
CIN: A-04-13-01024       THE UNIVERSITY OF NORTH CAROLINA AT  CHAPEL HILL DID NOT  ALWAYS  
CLAIM SELECTED COSTS  CHARGED DIRECTLY TO  DEPARTMENT OF HEALTH AND  
HUMAN SERVICES AWARDS IN ACCORDANCE  WITH FEDERAL REQUIREMENTS, 
JUN  2014, $352,843  
 
CIN: A-02-11-02017        NEW JERSEY  CLAIMED UNALLOWABLE COMMUNITY SERVICES BLOCK  GRANT  
COSTS INCURRED BY CHECK-MATE INC., UNDER  THE RECOVERY ACT, AUG 2014,  
$246,359  
 
CIN: A-01-10-02505        RESULTS OF LIMITED SCOPE REVIEW OF CTE,  INC., MAY 2011,  $239,975  
 
CIN: A-04-15-04039       MILDMAY UGANDA DID NOT ALWAYS MANAGE  THE  PRESIDENTS EMERGENCY  
PLAN FOR AIDS RELIEF  FUNDS IN ACCORDANCE  WITH AWARD REQUIREMENTS,  
MAR  2017, $209,480  
 
CIN: A-05-12-00012       ROCKFORD HUMAN SERVICES DID NOT ALWAYS CHARGE  ALLOWABLE  COSTS  
TO THE COMMUNITY SERVICES BLOCK GRANT   RECOVERY  ACT PROGRAM, JUL  
2013, $205,296  
 
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  Department of Health and Human  Services Office of Inspector General  
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CIN: A-04-16-04045      MANAGEMENT  AND DEVELOPMENT FOR HEALTH  DID NOT ALWAYS  MANAGE  
THE PRESIDENTS EMERGENCY  PLAN FOR  AIDS RELIEF FUNDS IN ACCORDANCE 
WITH AWARD REQUIREMENTS, JUN 2017,  $180,820  
 
CIN: A-04-11-01004         NORTHEAST FLORIDA COMMUNITY ACTION AGENCY, INC.,  DID NOT ALWAYS  
CHARGE  ALLOWABLE COSTS TO THE COMMUNITY  SERVICES BLOCK GRANT  
RECOVERY  ACT PROGRAM, SEP 2012,  $165,795  
 
CIN: A-04-11-01008        CENTRAL FLORIDA  COMMUNITY ACTION AGENCY, INC., DID NOT  ALWAYS  
CHARGE  ALLOWABLE COSTS TO THE COMMUNITY  SERVICES BLOCK GRANT   
RECOVERY  ACT PROGRAM, APR  2013, $160,404  
 
CIN: A-07-11-02766       NOT ALL COMMUNITY SERVICES BLOCK GRANT  COSTS CLAIMED ON  BEHALF OF  
THE CARBON  COUNTY COMMUNITY ACTION COMMITTEE FOR THE PERIOD  
OCTOBER  1, 2008, THROUGH  SEPTEMBER 30, 2010, WERE ALLOWABLE,  AUG  
2013, $143,588  
 
CIN: A-09-11-01013         OREGON CLAIMED  SOME POTENTIALLY UNALLOWABLE COMMUNITY SERVICES  
BLOCK GRANT COSTS FOR MULTNOMAH COUNTY'S  EXPENDITURES UNDER  THE  
RECOVERY ACT, APR 2013, $115,911  
 
CIN: A-06-11-00058       CROWLEY'S RIDGE  DEVELOPMENT COUNCIL,  INC., CLAIMED UNALLOWABLE  
COSTS UNDER A RECOVERY ACT  GRANT, AUG 2012,  $115,420  
 
CIN: A-02-13-02005       PUERTO RICO'S CONTROLS FOR ITS CHILD  CARE  AND DEVELOPMENT 
PROGRAM CLAIMS WERE  NOT EFFECTIVE, JAN  2017, $82,544  
 
CIN: A-09-11-01014        HAWAII CLAIMED  UNALLOWABLE COMMUNITY SERVICES BLOCK GRANT COSTS  
FOR  HAWAII COUNTY ECONOMIC  OPPORTUNITY COUNCIL'S EXPENDITURES  
UNDER THE RECOVERY  ACT, JUL 2012, $22,602  
 
CIN: A-05-11-00053      THE COLUMBUS URBAN  LEAGUE CLAIMED SOME UNALLOWABLE  COSTS  TO 
HEAD START,  SEP 2012, $13,102  
 
TOTAL CINS:      37  
 
TOTAL AMOUNT:      $361,725,000  
 
Notes  to  Table  2  
1 The opening balance had no  prior period adjustments of previously issued recommendations.  
2  Because of administrative delays, some of which were beyond management control,  5  of the 8  audits open at 
the end of the period were not resolved within 6  months of issuance of reports.  OIG is working with 
management to reach resolution on these recommendations before the end of the next semiannual reporting  
period:  
61  
  Department of Health and Human  Services Office of Inspector General  
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CIN: A-05-12-00020   MEDICARE  AND BENEFICIARIES COULD SAVE BILLIONS IF CMS REDUCES  
HOSPITAL OUTPATIENT DEPARTMENT PAYMENT RATES FOR AMBULATORY  
SURGICAL CENTER-APPROVED PROCEDURES TO AMBULATORY SURGICAL 
CENTER PAYMENT  RATES, APR 2014,  $15,000,000,000  
 
CIN: A-03-16-00200   OHIOS AND MICHIGANS  SALES AND USE TAXES  ON MEDICAID MANAGED  
CARE ORGANIZATION SERVICES DID NOT MEET  THE BROAD-BASED  
REQUIREMENT  BUT NOW ARE IN COMPLIANCE, APR  2017, $797,000,000  
 
CIN: A-09-14-02033   HUNDREDS OF MILLIONS  IN MEDICARE PAYMENTS  FOR CHIROPRACTIC  
SERVICES  DID NOT COMPLY WITH MEDICARE REQUIREMENTS,  OCT 2016,  
$358,800,549  
 
CIN: A-09-16-02026   MEDICARE INAPPROPRIATELY PAID ACUTE-CARE  HOSPITALS FOR OUTPATIENT  
SERVICES THEY PROVIDED TO BENEFICIARIES  WHO WERE INPATIENTS  OF  
OTHER FACILITIES, SEP 2017, $99,149,320  
 
CIN: A-03-13-03002   HHS DID NOT IDENTIFY  AND REPORT ANTIDEFICIENCY ACT VIOLATIONS, MAY 
2017, $49,445,025  
 
TOTAL CINS:     5  
TOTAL AMOUNT:     $16,304,395,000  
 
   
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Appendix  B:  Peer-Review Results  
Peer-Review Results  
 
The IG Act, as amended, requires OIGs to report the results of peer reviews of their operations conducted by  
other OIGs, the date of the last peer review, outstanding recommendations from peer reviews, and  peer  
reviews conducted by  an OIG of other OIGs in the semiannual period.   Peer reviews are conducted by member  
organizations of the Council of the Inspectors General on Integrity and  Efficiency (CIGIE).  Recently  CIGIE has  
approved a new peer-review process for Inspection and Evaluations units within OIGs  across the Federal  
Government, including  at HHS OIG, the implementation of which will begin in 2018.  
 
Office  of  Audit  Services   
 
During this semiannual reporting period, one peer review involving OAS was completed.    
 
OAS   Date   Reviewing Office   Office Reviewed  
March 2018   United States Postal   HHS OIG, OAS  
Service  OIG  
 
The system of quality control for the audit organization of HHS OIG in effect for the 
year ending September 30,  2017, has been suitably designed and complied with to  
provide HHS OIG with reasonable assurance of performing and reporting in 
conformity with applicable professional standards in all material respects.  Federal  
audit organizations can receive a rating of pass, pass with deficiencies, or fail.  HHS  
OIG received a peer-review rating of pass.  
 
OAS   Date   Reviewing Office   Office Reviewed  
December 2015   HHS OIG, OAS   U.S. Department of Agriculture 
(USDA)  OIG  
 
The system of quality control for the audit organization of USDA OIG in effect for  
the year ending  March 31, 2015, has been suitably designed and complied with to  
provide USDA OIG with reasonable assurance of performing and reporting  in 
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conformity with applicable professional standards in all material respects.  Federal  
audit organizations can receive a rating of pass, pass with deficiencies, or fail.  USDA  
OIG received a peer-review rating of pass.  
 
Office  of  Investigations  
 
During this semiannual reporting period,  no  peer review  involving  the Office of Investigations (OI)  was  
completed. Listed below is information concerning OIs peer-review activities during prior reporting periods.  
 
OI   Date   Reviewing Office   Office Reviewed  
August 2017   HHS OIG, OI   U.S. Postal Service OIG  
 
The system of internal safeguards and management procedures for the investigative 
function of  USPS  OIG in effect for the year ending September 30, 2015,  was  in full 
compliance with the quality standards established  by CIGIE and the Attorney  
Generals guidelines.  
 
OI   Date   Reviewing Office   Office Reviewed  
August 2015   DOL  OIG   HHS OIG, OI  
 
The system of internal safeguards and management procedures for the 
investigative function of  HHS OIG  in effect through June 2014,  was  in full 
compliance with the quality standards established  by CIGIE and the Attorney  
Generals guidelines.  
 
 
 
Office  of  Evaluation and  Inspections   
 
During this semiannual reporting period, OEI conducted  a peer review of certain Department of  Defense (DoD)  
OIG Inspection and Evaluations  (I&E)  units at the request of DoD OIG.   Results of this peer review will be 
reported in May  2018.   
 
 
OEI   Date   Reviewing Office   Office Reviewed  
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September 2017   HHS OIG   DoD  OIG, I&E units  
 
 
 
 
   
65  
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Appendix  C:  Summary of Sanction Authorities  
The Inspector General Act of 1978, as amended, specifies requirements for semiannual reports to be made to  
the Secretary for transmittal to Congress.  A selection of other authorities appears below.  
Program Exclusions  
The Social Security Act,  1128  (42 U.S.C.  1320a-7), provides several grounds for excluding individuals and  
entities from participation in Medicare, Medicaid,  and other Federal health care programs.   Exclusions are 
required for individuals and entities convicted of the following types of criminal offenses:  (1) Medicare or  
Medicaid fraud;  (2) patient abuse or neglect; (3) felonies for other health care fraud;  and (4) felonies for illegal  
manufacture, distribution, prescription, or dispensing of controlled substances.    
OIG is authorized  (permissive exclusion)  to exclude individuals and entities on several other grounds, including  
misdemeanors for other  health care fraud  (other than Medicare or Medicaid); suspension or revocation of  
a  license to provide health care for reasons bearing on professional competence, professional performance, or 
financial integrity; provision of unnecessary or substandard services; submission of false or fraudulent claims to  
a Federal health care program; or engaging in unlawful kickback arrangements.  
The ACA added another  basis for imposing a permissive exclusion, that is, knowingly making, or causing to be 
made, any false statements or omissions in any application, bid, or contract to participate as a provider in a  
Federal health  care program, including managed care programs under Medicare and Medicaid, as well as  
Medicares prescription drug program.  
Providers subject to exclusion are granted due process rights.  These include a hearing before an administrative 
law judge and appeals to the HHS  Departmental Appeals Board  and Federal district and appellate courts  
regarding the basis for and the length of the exclusion.  
CMPL  
The CMPL of the Social Security Act, 1128A (42 U.S.C.  1320a-7a), imposes penalties, assessments,  and  
exclusion from participation in Federal health care programs for engaging in certain activities.  For example, a  
person who submits, or causes to be submitted, to a Federal health care program  a  claim for items  and services  
that the person knows, or should know, is false or  fraudulent is subject to a penalty of up to $15,270 for each 
item or service falsely or  fraudulently claimed, an assessment of up to  three  times the amount falsely or  
fraudulently claimed, and exclusion.  
For the purposes of the CMPL, should know is  defined to mean that the person acted in reckless  disregard or  
deliberate ignorance of the truth or falsity  of the claim.  The law and its implementing regulations also  
authorize actions for a variety of other violations, including submission of claims for items or services furnished  
by an excluded person; requests for payment in violation of an assignment agreement; violations of rules  
regarding the possession, use, and transfer of biological agents and toxins; and payment or receipt of  
remuneration  in violation of the anti-kickback statute (42 U.S.C.   1320a-7b (b)).    
The ACA added more grounds for imposing  CMPs.  These include, among other types of conduct, knowingly 
making, or causing to be made, any  false statements or omissions in any application, bid, or contract to  
participate as a provider  in a Federal health care program (including Medicare and Medicaid managed care 
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programs and Medicare Part  D); the ACA authorizes a penalty of up to $55,262 for each false statement, as well  
as activities relating to fraudulent marketing by managed care organizations, their employees,  or their agents.    
The 21st Century Cures Act (enacted on December 13,  2016) added more grounds for imposing CMPs,  
assessments, and exclusion from Federal health care programs for fraudulent conduct in an HHS grant,  
contract, or other agreement.  OIG  may assess CMPs  of up to  $10,000 per claim and assessments of up to  three  
times the amount claimed for knowingly presenting a false or fraudulent claim.  In addition, OIG may impose a  
penalty of  up to $50,000  and assessments  of up to  three  times the amount of funds at issue for  (1)  knowingly  
making a false statement in a document required to be submitted in order to receive funds under an HHS  
contract, grant, or other  agreement; (2) knowingly making or using a false record or statement that is material  
to  a false or fraudulent claim; and (3) knowingly making or using a  false record or statement material to an 
obligation to pay or transmit funds or property owed to HHS.  OIG may impose a penalty of up to $10,000 per  
day  and assessments of up to  three  times the amount at issue for  knowingly concealing, or knowingly and  
improperly avoiding or decreasing, an obligation owed to HHS with respect to an HHS grant, contract, or other  
agreement. Finally, OIG may impose a penalty  of  up to $15,000 per day for failing to grant timely access to  
OIG upon reasonable request for audits or to carry out other statutory functions in matters involving an HHS  
grant, contract, or other  agreement.    
Patient Dumping 
The Social Security Act,   1867  (42 U.S.C.  1395dd), provides that when an individual goes to the emergency  
room of a  Medicare-participating hospital, the hospital must provide an appropriate medical screening  
examination to determine whether that individual has an emergency medical condition.  If  an individual has 
such a condition, the hospital must provide either treatment to stabilize the condition or an appropriate 
transfer to another medical facility.   
If a transfer is ordered, the transferring hospital must provide stabilizing treatment to minimize the risks  of  
transfer and must ensure that the receiving hospital agrees to the transfer  and has available space and  
qualified personnel to treat the individual.   In addition, the transferring hospital must effect the transfer  
through qualified personnel and transportation equipment.   Further, a participating hospital with specialized  
capabilities or facilities may not refuse to accept an appropriate transfer  of  an individual who needs services if  
the hospital has the capacity to treat the individual.   
OIG is authorized to collect CMPs of up to $52,414 against small hospitals  (fewer than 100 beds) and up to  
$104,826 against larger hospitals (100 beds or more) for each instance in which the hospital negligently 
violated any  of the section 1867 requirements.   In addition, OIG may collect a penalty of up to $104,826 from  a  
responsible physician for each negligent violation of any of the section 1867 requirements and, in some 
circumstances, may exclude a  responsible physician.   
Anti-Kickback Statute and  Civil False Claims Act  Enforcement Authorities  
Anti-Kickback StatuteThe anti-kickback statute authorizes penalties against anyone who knowingly and  
willfully solicits, receives,  offers, or pays remuneration, in cash or in kind, to  induce or in return for (1) referring 
an individual to a person or an entity for the furnishing, or arranging for the furnishing, of any item  or service 
payable under the Federal health care programs or (2) purchasing, leasing, or ordering, or  arranging for or  
recommending the purchasing, leasing, or ordering, of any good,  facility,  service, or item payable under the 
Federal health care programs  (Social Security Act,   1128B(b)  (42 U.S.C.  1320a-7b(b)).  
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Individuals and entities that engage in unlawful referral or kickback schemes may be subject to  criminal 
penalties under the general criminal  anti-kickback statute; a CMP under OIGs authority pursuant to the Social  
Security Act,  1127(a)(7)  (42 U.S.C.   1320a-7a);  and/or program exclusion under OIGs permissive exclusion 
authority under the Social  Security Act,    1128(b)(7) (42 U.S.C.  1320a-7(b)(7)).  
False Claims Act  (FCA)Under the FCA, as  amended by the False Claims Amendments Act of 1986 (31 U.S.C.  
 37293733), a person or an entity is liable for up to treble damages and  a penalty between $11,181  and 
$22,363  for each false claim it knowingly submits, or causes to be submitted, to a Federal program.   Similarly, a  
person or an entity is liable under FCA if it knowingly makes  or uses, or causes to be made or used,  a false 
record or statement to have a false claim paid.  FCA defines knowing to  include not only the traditional  
definition but also instances in which the person acted in deliberate ignorance or reckless disregard of the truth 
or falsity of the information.  Under FCA, no specific intent to defraud is required.  Further, FCA contains a qui  
tam, or whistleblower, provision that allows a private individual to file a lawsuit on behalf of the United States  
and entitles that whistleblower to a percentage of  any fraud recoveries.  FCA was again amended in 2009 in  
response to recent Federal court decisions that narrowed the laws applicability.  Among other things, these 
amendments clarify the reach of FCA to false claims submitted to contractors or grantees  of the Federal  
Government.    
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Appendix  D:  Reporting Requirements  in the 
Inspector  General  Act  of 1978   
The following table lists the  reporting requirements of the IG  Act, as amended, along with the location of the 
required information.  
Section   Requirement   Location  
Section 4      
(a)(2)   Review of legislation  and regulations   Other HHS-Related Reviews and  
Investigations section   
Section 5      
(a)(1)   Significant problems, abuses, and deficiencies   Throughout this report  
(a)(2)   Recommendations with respect to significant   Throughout this report  
problems, abuses, and deficiencies  
(a)(3)   Prior significant recommendations on which  OIG  Compendium of Unimplemented  
corrective action has not been completed   Recommendations  (Compendium)  
(a)(4)   Matters referred to prosecutive authorities   Legal and Investigative Activities  
Related to the Medicare and  
Medicaid  Programs section  
(a)(5)   Summary of instances in which information  None for this reporting period  
requested by OIG was refused  
(a)(6)   List of audit reports   Submitted to the Secretary  of Health  
and Human Services under separate 
cover  
(a)(7)   Summary of significant reports   Throughout this report  
(a)(8)   Statistical Table 1Reports with  Questioned Costs   Appendix A  
(a)(9)   Statistical Table 2Funds Recommended To Be Put   Appendix A  
to Better Use  
(a)(10)   Summary of previous audit reports without   Appendix A  
management decisions, in which no establishment  
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Section   Requirement   Location  
comment was returned  within 60 days, and in 
which there are any outstanding  unimplemented  
recommendations  
(a)(11)   Description and explanation of revised   Appendix A  
management decisions  
(a)(12)   Management decisions with which the Inspector   None for this reporting period  
General disagrees  
(a)(13)   Information required by the Federal Information  Reported annually in the spring  
Security Management Act.    Semiannual Report, Other HHS-
Related Reviews and Investigations  
section  
(a)(14)-(16)   Results of peer reviews of HHS OIG conducted by   Appendix  B  
other OIGs or  the date of the last peer review,  
outstanding recommendations from peer  reviews,  
and peer reviews conducted by HHS OIG of other  
OIGs  
(a)(17)   Investigative statistical tables   Appendix  F  
(a)(18)   Metrics description for statistical tables   Appendix  F  
(a)(19)   Investigations on senior Government  employees   Appendix  F  
(a)(20)   Description of whistleblower retaliation instances   Appendix  F  
(a)(21)   Description of attempts to interfere with OIG  Appendix  F  
independence  
(a)(22)   Description of closed and  nondisclosed  reports and   Appendix  F  
investigations regarding senior Government  
employees  
 
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Other Reporting  Requirements  
Section   Requirement   Location  
845   Significant contract audits required to be reported   Other HHS-Related Reviews and  
pursuant to the National  Defense Authorization Act   Investigations section  
for  FY 2008 (P.L.  No.  110-181),   845.  
 
205   Pursuant to HIPAA (P.L. No.  104-191),   205, the   Reported annually in the fall  
Inspector General is required to solicit proposals   Semiannual Report, Appendix  G  
annually via  a Federal  Register notice for 
 
developing new and modifying existing safe 
harbors to the anti-kickback statute of the Social  
Security Act,   1128(b), and for developing special  
fraud alerts.  The Inspector General is also required  
to report annually to Congress on the status of the  
proposals received related to new or modified safe 
harbors.  
 
1553   Pursuant to the American Recovery and   Other HHS-Related Reviews and  
Reinvestment Act of 2009,  P.L. No. 111-5,    1553,   Investigations section  
OIG reports to Congress the retaliation complaint  
investigations it decided not to conduct or  
continue during the period.  
   
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Appendix  E:  Reporting Requirements  in the  
Inspector  General Empowerment Act of  2016  
The Inspector General Empowerment Act of 2016 establishes new reporting requirements for the Semiannual  
Reports.  These requirements amend portions  of  5 of the IG  Act.  The requirements are below in italics,  
followed by OIGs responses.   
Each Inspector General  shall, not later than  April 30 and October 31 of each year, prepare semiannual  
reports summarizing the activities of the Office during the immediately preceding six-month periods  
ending March  31 and September 30.  Such reports shall include, but need not be limited to- 
(10) A  summary of audit, inspection, and evaluation  reports  issued  before the commencement of  
the reporting period- 
(A)  for which no management decision has been made  by the end of the reporting period 
(including the date and  title  of each such report), an explanation of the reasons such 
management decision  has not been made, and a statement concerning the desired 
timetable  for achieving a management decision on each such report;  
For audit, inspection, and evaluation reports issued  from  FY 2011  through FY  2018, OIG had  122  
reports with  overdue final management decisions.1    
OIG is unable to provide reasons and timetables for each of these overdue management  
decisions due to the volume and that OIG did not historically track this  information.  
(B) for which no establishment comment was returned within 60 days  of providing the  
report to  the establishment; and  
For  draft reports that include recommendations,  OIG typically requests establishment comments  
within 30 days.  In some instances, OIG grants extensions when requested  and appropriate.   
When OIG does not receive establishment comments or a request for extension within the 30-
day timeframe, OIG  typically  issues the report  and notes the lack of establishment comments.    
For this semiannual reporting period, OIG had no reports with comments exceeding 60 days.    
(C) for which there  are any outstanding unimplemented recommendations, including the  
aggregate  potential cost savings of those recommendations.  
OIG is actively tracking  1,240  unimplemented open recommendations made in reports issued  
since FY 2011.  Given the volume of recommendations OIG makes each year, the table below  
reflects  summary  data by  fiscal year:  
 
 
1  OIG is able to track the status of management decisions for all reports back to FY  2011.  OIG can track the status of management decisions 
for audit reports back to FY 1990.  We have identified 10 additional audit reports with overdue management decisions from FY 1990 through  
FY  2010.    
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FY (2011  Number of Reports  Number of  Dollar  Value of  
2018)   with  Unimplemented  Aggregate   
Unimplemented  Recommendations   Potential Cost 
 
Recommendations   Savings  
  2011   17   30   $435,349,613  
  2012   34   43   $342,029,256  
  2013   45   88   $267,498,939  
2014   48   98   $15,158,930,599  
 
2015   54   113   $529,509,088  
 
2016   79   215   $309,327,014  
 
2017   105   417   $2,116,342,503  
 
2018   67   236   $715,220,191  
    Total   449   1,240   $19,874,207,203  
 
 
OIG annually produces a  Compendium of Unimplemented  Recommendations, which constitutes OIGs response 
to a specific requirement of the IG  Act, as amended ( 5(a)(3)).  It identifies significant recommendations with 
respect to problems, abuses, or deficiencies for which corrective actions have not been taken  or completed.   
The Compendiums  appendix  is a list of OIGs significant unimplemented recommendations, which  represent  
opportunities to achieve expected impact through cost savings, improvements in program effectiveness and  
efficiency,  or increase  quality  of care and safety of beneficiaries.  In OIGs view, these recommendations would  
most positively impact HHS programs in terms of  cost savings and/or quality improvements and should 
therefore be prioritized for implementation.    
(17) Statistical  tables showing- 
  (A) the total number of investigative reports issued during the reporting period;  
(B)the total number of  persons referred  to the Department of Justice for criminal  
prosecution during the reporting period;  
(C) the total number of persons  referred  to State and local prosecuting  authorities for 
criminal prosecution during the reporting  period; and  
(D)the total number of indictments  and criminal informations during the reporting period 
that resulted from  any prior referral  to prosecuting authorities;  
Total number of investigative reports issued during the reporting period,   0  
including  Management Implication Reports  and Investigative Advisories  
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Total number of persons  referred2  to  Federal  prosecuting authorities for   1,185    
criminal prosecution  during the reporting period3  
 
Total number of persons  referred to State and local prosecuting  160  
 
authorities for criminal prosecutions during the reporting period  
 
Total number of Federal indictments and criminal informations during the  340  
reporting  period that resulted from any prior referral to prosecuting   
authorities  
 
Total number of  State and local  indictments and criminal informations   96  
 
during the reporting period that resulted from  any prior referral to  
prosecuting authorities    
 
(18) A  description of the metrics used for developing the data for the statistical  tables under  
paragraph (17);  
Regarding (17)(A), OIG considers Investigative Reports as Management Implication Reports and  
Investigative Advisories.   A Management Implication  Report  identifies systemic weaknesses or  
vulnerabilities within HHS programs, which are generally identified during the course of an OIG 
investigation and could lead to fraud, waste, or abuse.  It provides recommendations to correct or  
minimize the problem.  Corrective actions may require administrative, procedural, policy, regulatory,  or  
legislative change.  When a Management Implication Report  is issued to an HHS  OPDIV  or STAFFDIV, it  
is generally signed by the Inspector General.  Investigative Advisories are  similar documents  that  bring 
renewed attention to  an identified HHS  issue and are generally signed by the Deputy Inspector General  
for Investigations.  
Regarding (17)(B) and (C), OIG  defines  this measure as the term presentations to both Federal and  
State/local prosecuting jurisdictions as the representation of the work we do.  For example, when OIG 
opens an investigation, it evaluates the complaint  and  decides  whether to present the matter for  
prosecution.  Generally, if the case has prosecutorial  merit, and is accepted for Federal prosecution,  OIG 
works with DOJ as the primary investigative agency, as opposed to referring the matter to DOJ without  
further involvement on OIGs  part.  OIG works with State and local prosecutorial authorities  in addition  
to working with DOJ.    
Regarding (17)(D), the table above provides the number of indictments/criminal informations during  
the semiannual reporting period, including sealed indictments/criminal informations.   However, the 
information cannot be limited to only those that  occurred as a result of a  presentation in a previous  
period.  In certain situations, the presentation and charging dates are in the same reporting period.    
(19) A  report on  each investigation conducted by the Office involving a senior Government  
employee where  allegations of misconduct were substantiated, including a detailed description  
of- 
(A) the facts and circumstances of the investigation;  and  
 
 
2  A referral includes OIG presentations to  DOJ and/or State/local prosecutorial authorities.   
3   OIG counts persons as both individuals and  entities.   
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(B)the status and disposition of the  matter, including- 
(i)if the matter was referred to  the Department of Justice,  the date of the referral;  
and  
(ii) if the Department of Justice  declined the referral,  the  date of the declination;  
 
To respond fully to this subparagraph, OIG would need to make a  finding of misconduct.  However, OIG 
does not make findings  regarding  its investigations relating to substantiated allegations of  
departmental employee misconduct.  Our reports relay the facts obtained  during the investigations  
(e.g., parties involved, dates of events) related to any substantiated allegations.  At the conclusion of an 
OIG investigation related to substantiated allegations concerning possible employee misconduct, OIG 
provides a report to management in the employing agency.  The agency management makes  
determinations of employee misconduct.  The disposition of the matter and any resulting administrative 
actions are taken by the agency.    
However, we request from the agency a copy of an SF-50 documenting  a  personnel action, if one is  
taken.  To the extent that we have information regarding subsequent administrative action, OIG can  
provide that information.  However, because there are sometimes settlement agreements that may  
impact the final action, OIG may not have a complete record of the disposition of the investigation.   
Accordingly, such  information might be more efficiently and effectively provided directly  by  the 
employing agency.    
For this section, OIG describes investigations,  both criminal and administrative, conducted  during this  
reporting period, involving senior Government employees  for whom  allegations of misconduct were 
substantiated.  The descriptions below include a level of detail appropriate for each investigation,  
depending on whether the case details were available in public documents.  During this reporting  
period, OIG did  not investigate  any  senior Government employees for misconduct.  
20)  A  detailed description of any instance  of whistleblower retaliation, including information  
about the official found to have engaged in retaliation  and what, if any, consequences the  
establishment imposed to hold that official accountable;  
 
For departmental agencies, OIG conducts investigations and gathers facts related to whistleblower  
complaints.   Before 2015, OIG made  no  determinations as to whether retaliatory  action had been taken.   
However, to better facilitate the report review process, OIG changed its  process in 2015 to include 
findings in its reports as to whether it was more likely than not that whistleblower retaliation had  
occurred.  While OIG now includes these findings in its reports, it does not make recommendations as  
to what, if any, corrective action(s) should be taken.    
During the time period from October 1, 2017, through March 31,  2018, OIG did not issue any reports  
that included findings of retaliation.  
When determining the level of detail to provide for a description of any instance of  whistleblower  
retaliation, OIG is always  mindful of the risk that  a detailed description of the allegation could  
inadvertently reveal the whistleblowers identity, thus having a chilling effect on future whistleblowers.  
 
(21) A  detailed description of any attempt  by  the establishment to interfere with the 
independence of the Office, including- 
(A) with  budget constraints designed to limit the capabilities of the  Office; and  
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(B)incidents where the establishment has resisted or objected to oversight activities  of the 
Office or restricted or significantly delayed access to information, including the  
justification of the establishment for such action; and  
 
Although there have been instances in which HHS agencies have questioned OIG oversight activities or  
have not provided all information in the precise content, format, and timeline as requested, OIG has not  
identified any instances in which the Department  interfered with the independence of OIG during this  
reporting period.  OIG would immediately notify  Congress if it were unable to resolve these issues  
within the Department.    
 
(22) Detailed descriptions of the particular circumstances of each- 
(A)  inspection,  evaluation,  and audit conducted by the Office  that is closed and was not 
disclosed to the  public; and  
 
The table below lists evaluation and audit reports  for this semiannual reporting period that did not  
result in public reports.  However, in some circumstances, a public summary of these nonpublic reports  
was published. 
   
Nonpublic Reports by Category,  October  1, 2017, to  March 31, 2018  
Number  
Category/Description   of 
Reports  
IT  security reviews (involve IT  systems, e.g.,  penetration test audits)   2  
Reimbursable audits performed for other Federal  agencies (primarily contract audits)   1  
Other   2  
  Total   5  
 
(B)Investigation conducted by the  Office involving a senior Government employee that is  
closed and was not disclosed to the public.  
 
In section 5(a)(19), we detail investigations of senior Government employees in which  allegations were 
substantiated.  Those investigations are all closed and none have been disclosed to the public.  OIG 
interprets  section  5(a)(22)(B)  as requiring reporting on investigations with either substantiated or  
unsubstantiated allegations.  As such, we refer to our section 5(a)(19) response to address  investigations  
of senior Government employees in which allegations were substantiated  that were closed and not  
disclosed to the public.   Our section 5(a)(22)(B) response describes investigations, both criminal and  
administrative,  conducted during this reporting period involving a senior  Government employee in 
which OIG did not substantiate allegations of misconduct.    
 
When determining the level of detail to provide for the investigations described above, OIG is mindful  
of the risk that a detailed description of the investigation could inadvertently reveal the subjects  
identity.  During  this reporting period, OIG investigated  two  senior Government employees for  
misconduct, but OIG determined the allegations to be unsubstantiated.  Descriptions of the 
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investigations are below.   
 
 
Description of Investigation   Status   Disposition     DOJ     DOJ  
DOJ   Referral   DOJ   Declination  
Referral   Date   Declination   Date  
A senior Government employee  No evidence 
was alleged to have been  Closed   to support  No   N/A   N/A   N/A  
involved in misconduct.   allegations.  
A former senior Government  
No evidence 
employee was alleged to  have 
Closed   to support  No   N/A   N/A   N/A  
engaged in unethical post-
allegations.  
employment activities.  
   
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APPENDIX  F:  Anti-Kickback Statute  Safe 
Harbors  
Anti-Kickback Statute   Safe Harbors  
Pursuant to HIPAA,  205, the Inspector General is required to solicit proposals annually via a Federal Register  
notice for developing new and modifying existing safe harbors to the anti-kickback statute, section  1128B(b) of  
the Social Security Act, and for developing special fraud alerts.  The Inspector General is also required to report  
annually to  Congress  on the status of the proposals received related to new or modified safe harbors.   
 
In crafting safe harbors for a criminal statute, it is incumbent upon the OIG to engage in a complete and careful  
review of the range of  factual circumstances that may fall within the proposed safe harbor subject area to  
uncover all potential opportunities for fraud and abuse by unscrupulous providers.  Having done so, OIG must  
then determine, in consultation with DOJ, whether it can develop effective regulatory limitations and controls 
not only to foster beneficial or innocuous arrangements but also to protect Federal health care programs and  
their beneficiaries from abusive practices.   
Public  Proposals for  New and  Modified  Safe  Harbors   
In response to the 2016  annual solicitation, OIG received the following proposals related to safe harbors.  
Proposal   OIG Response  
A new safe harbor that would protect   OIG is not adopting this suggestion at this time, as it 
value-based payment arrangements that  requires further study.  In the meantime, questions  
bundle products and related services and  about the application of  the anti-kickback  statute to  
allow for price adjustments if a measurable   such arrangements should be addressed on a case-
clinical and/or cost outcome is not achieved.     by-case basis, such as under the advisory opinion 
process.  
A new safe harbor that would protect value- OIG is not adopting this suggestion at this time, as it 
based warranties offered by manufacturers or  requires further study.  In the meantime, questions  
suppliers of products that provide certain  about the application of  the anti-kickback  statute to  
assurances about clinical and/or cost   such arrangements should be addressed on a case-
outcomes and appropriate remedies where  by-case basis, such as under the advisory opinion 
such outcomes are not achieved.      process.  
   
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A new safe harbor that would protect   OIG is not adopting this suggestion at this time, as it 
value-based payment arrangements generally.   requires further study.  In the meantime, questions  
about the application of  the anti-kickback  statute to  
such arrangements should be addressed on a case-
by-case basis, such as under the advisory opinion 
process.  
A new safe harbor that would protect  OIG is not adopting this suggestion at this time, as it 
arrangements that support patient adherence  requires further study.  In the meantime, questions  
to a treatment regimen that has been  about the application of  the anti-kickback  statute to  
recommended by the patients health care  such arrangements should be addressed on a case-
provider.     by-case basis, such as under the advisory opinion 
process.  
A new safe harbor that would protect  OIG is not adopting this suggestion at this time, as it 
arrangements  that pay for, or provide, data   requires further study.  In the meantime, questions  
analytics.    about the application of  the anti-kickback  statute to  
such arrangements should be addressed on a case-
by-case basis, such as under the advisory opinion 
process.  
The modification of the personal services and   OIG is not adopting this suggestion at this time, as it 
management contracts safe harbor, 42 C.F.R.  requires further study.  In the meantime, questions  
  1001.952(d), to protect  personal services   about the application of  the anti-kickback  statute to  
arrangements involving part-time or periodic   such arrangements should be addressed on a case-
services that lack an exact schedule of services   by-case basis, such as under the advisory opinion 
or precise length of intervals.     process.  
The modification of the discounts safe harbor,   OIG is not adopting this suggestion at this time, as it 
42 C.F.R.  1001.952(h),  to include exceptions   requires further study.  In the meantime, questions  
for value-based arrangements within the  about the application of  the anti-kickback  statute to  
existing definition of discount; to protect  such arrangements should be addressed on a case-
certain discounts offered in connection with  by-case basis, such as under the advisory opinion 
value-based  arrangements; and to define  process.  
value-based arrangement to capture 
appropriate and beneficial arrangements while 
excluding arrangements  that are abusive or  
result in inappropriate financial incentives.    
The modification of the discounts safe harbor,   OIG is not adopting this suggestion at this time, as it  
42 C.F.R.  1001.952(h), to expand upon the  requires further study.  In the meantime, questions  
subcategories of buyers  potentially protected  about the application of  the anti-kickback  statute to  
by the safe harbor; to specify under what   such arrangements should be addressed on a case-
circumstances a discount or rebate  by-case basis, such as under the advisory opinion 
arrangement may involve the performance of   process.  
services or activities; and to clarify the 
disclosure obligations that arise under the safe 
harbor.     
The modification of the warranties safe harbor,   OIG is not adopting this  suggestion at this time, as it 
42 C.F.R.  1001.952(g), to protect   requires further study.  In the meantime, questions  
79  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
remuneration paid to cover certain services   about the application of  the anti-kickback  statute to  
and items that are related to the item that is   such arrangements should be addressed on a case-
the subject of the warranty in the context of   by-case basis, such as under the advisory opinion 
value-based arrangements.   process.  
The modification of the warranties safe harbor,   OIG is not adopting this suggestion at this time, as it 
42  C.F.R.  1001.952(g), to protect  requires further study.  In the meantime, questions  
manufacturer-issued refunds in circumstances   about the application of  the anti-kickback  statute to  
in which the manufacturers products do not  such arrangements should be addressed on a case-
work as specified for individual patients or   by-case basis, such as under the advisory opinion 
patient populations, particularly in outcomes   process.  
or  value-based arrangements.    
The modification of the price reductions   OIG is not adopting this suggestion at this time, as it 
offered to health plans, price reductions   requires further study.  In the meantime, questions  
offered to eligible managed care  about the application of  the anti-kickback  statute to  
organizations, and price reductions offered by  such arrangements should be addressed on a case-
contractors with substantial financial risk to   by-case basis, such as under the advisory opinion 
managed care organizations safe harbors,  process.  
42  C.F.R.  1001.952(m), (t), and (u), to clarify  
the circumstances under which drug 
manufacturer rebate agreements with 
managed care organizations or pharmacy  
benefit managers would  be protected.  
 
   
80  
  Department of Health and Human  Services Office of Inspector General  
Semiannual Report to CongressOctober 1, 2017, through March 31, 2018 
 
 
 
81  
  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-01-15-00515  Wisconsin Physicians Service Paid Providers for Hyperbaric Oxygen  $300,789  $42,329,336 2 
Therapy Services That Did Not Comply With Medicare Requirements 
A-01-16-01502  The Food and Drug Administration's Food-Recall Process Did Not  14 
Always Ensure The Safety Of The Nation's Food Supply 
A-01-18-31475  HEALTH REINSURANCE ASSOCIATION (CONNECTICUT) 1 
A-01-18-31913  GBAPP, INC. 0 
A-01-18-31975  AIDS CARE OCEAN STATE INC. 2 
A-01-18-31977  NORTH SHORE COMMUNITY HEALTH INC. 3 
A-01-18-32011  CENTER FOR HEALTH POLICY DEVELOPMENT NATIONAL ACAD 2 
A-01-18-32105  CARE NEW ENGLAND HEALTH SYSTEM & AFFILIATES 1 
A-01-18-32148  MITRE CORP. 0 
A-01-18-32222  COMMUNITY HEALTH CENTER ASSOCIATION OF CONNECTICUT 0 
A-01-18-32230  CENTER FOR SOCIAL INNOVATION, LLC 0 
A-01-18-32287  HOULTON BAND OF MALISEET INDIANS 0 
A-01-18-32288  PENOBSCOT INDIAN NATION 0 
A-01-18-32330  INDIAN STREAM HEALTH CENTER INC. 3 
A-01-18-32377  KATAHDIN VALLEY HEALTH CENTER 1 
A-01-18-32539  HEALTH ACCESS NETWORK INC. 3 
A-01-18-32593  TETRAGENETICS, INC. 2 
A-01-18-32623  HIGHLAND INSTRUMENTS, INC. 0 
A-01-18-32638  ETIOMETRY INC. 3 
A-01-18-32639  SYMBIOTIX BIOTHERAPIES, INC. 1 
A-01-18-32685  SAVE THE CHILDREN FEDERATION, INC. & RELATED ENTIT 1 
A-01-18-32686  NARRAGANSETT INDIAN TRIBE 8 
A-01-18-32728  NETWORK FOR REGIONAL HEALTHCARE IMPROVEMENT 2 
A-01-18-32747  INDIAN TOWNSHIP TRIBAL GOVERNMENT 7 
A-01-18-32771  MINUTEMAN HEALTH INC. 1 
A-01-18-32793  THAMES VALLEY COUNCIL FOR COMMUNITY ACTION INC & S 1 
A-01-18-32794  PLEASANT POINT PASSAMAQUODDY TRIBAL COUNCIL 2 
A-01-18-32914  BROAD INSTITUTE, INC. 0 
A-01-18-32915  YALE UNIV. 0 
A-01-18-32927  DIMAGI INC. & SUBSIDIARIES 0 
A-01-18-32940  PATHFINDER INTERNATIONAL & SUBSIDIARIES 1 
A-01-18-32951  GOODWIN COMMUNITY HEALTH & SUBSIDIARY 1 
A-01-18-32969  PLANNED PARENTHOOD LEAGUE OF MASSACHUSETTS, INC. & 1 
A-01-18-33008  MANCHESTER COMMUNITY HEALTH CENTER 3 
A-01-18-33025  FOUNDATION OF MASSACHUSETTS EYE & EAR INFIRMARY IN 1 
A-01-18-33026  ST. JOSEPHS COLLEGE 0 
A-01-18-33078  ACTION FOR BOSTON COMMUNITY DEVELOPMENT INC. 0 
A-01-18-33079  DARTMOUTH COLLEGE 0 
A-01-18-33122  COMMUNITY HEALTH CENTER INC. 1 
A-01-18-33174  GREATER LAWRENCE FAMILY HEALTH CENTER INC. 1 
A-01-18-33175  SOUTH END COMMUNITY HEALTH CENTER, INC. 1 
A-01-18-33282  MOHEGAN TRIBE OF INDIANS OF CONNECTICUT SPECIAL RE 0 
A-02-15-01010  New Jersey Claimed Hundreds of Millions in Unallowable or  $300,452,930 1 
Unsupported Medicaid School-Based Reimbursement 
A-02-15-01014  New York Did Not Comply with Federal Grant Requirements for  $954,521 0 
Claiming Marketplace Contract Costs to Medicaid and the Childrens 
Health Insurance Program 
A-02-15-01015  New Yorks Medicaid Eligibility Determinations for Newly Eligible  2 
Beneficiaries Did Not Always Meet Federal and State Requirements 
A-02-15-01024  New York Did Not Always Verify Correction of Deficiencies Identified  1 
During Surveys of Nursing Homes Participating in Medicare and 
Medicaid 
A-02-15-02008  New York Did Not Comply with Federal Grant Requirements for  $20,415,344  1 
Allocating and Claiming Marketplace Contract Costs 
A-02-16-01008  New Jersey Claimed Federal Medicaid Reimbursement for Childrens  $54,732,002 5 
Partial Hospitalization Services That Did Not Meet Federal and State 
Requirements 
4/19/2018 8:38:04AM  Page 1 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-02-17-02002  Henry J. Austin Health Center, Inc., a Health Resources and  $8,243,519  1 
Services Administration Grantee, Did Not Comply With Federal Grant 
Requirements 
A-02-18-31487  JEWISH RENAISSANCE MEDICAL CENTER INC.  5 
A-02-18-31661  MOROVIS COMMUNITY HEALTH CENTER, INC. 0 
A-02-18-31752  HEALTH REPUBLIC INSURANCE OF NEW YORK, CORP. 2 
A-02-18-31847  MUNICIPALITY OF PONCE PUERTO RICO 4 
A-02-18-31849  MUNICIPALITY OF SAN JUAN PUERTO RICO 3 
A-02-18-31850  CONCILIO DE SALUD INTEGRAL DE LOIZA INC. 4 
A-02-18-31866  MERCY COLLEGE 0 
A-02-18-31867  COLLEGE OF NEW ROCHELLE 2 
A-02-18-31868  CATHOLIC CHARITIES NEIGHBORHOOD SERVICES INC. 4 
A-02-18-31873  SISTEMA UNIVERSITARIO ANA G. MENDEZ, INC. 0 
A-02-18-31889  FAIRLEIGH DICKINSON UNIV. 0 
A-02-18-31968  NORTHWEST BUFFALO COMMUNITY HEALTH CARE CENTER INC 2 
A-02-18-32018  HARLEM UNITED COMMUNITY AIDS CENTER INC. & AFFILIA 5 
A-02-18-32203  GOVERNMENT OF THE VIRGIN ISLANDS OF THE UNITED STA 25 
A-02-18-32355  CHAUTAUQUA CENTER INC. 4 
A-02-18-32358  NATIONAL DEVELOPMENT & RESEARCH INSTITUTES INC. 2 
A-02-18-32387  CENTER FOR COMMUNITY ALTERNATIVES 3 
A-02-18-32389  MT. VERNON NEIGHBORHOOD HEALTH CENTER INC. 0 
A-02-18-32401  REPRIXYS PHARMACEUTICALS CORP. 0 
A-02-18-32416  BROOME COUNTY NEW YORK 0 
A-02-18-32474  DELAWARE COUNTY NEW YORK 0 
A-02-18-32476  COLD SPRING HARBOR LABORATORY 0 
A-02-18-32521  SCHENECTADY FAMILY HEALTH SERVICES INC. & AFFILIAT 1 
A-02-18-32538  JEWISH RENAISSANCE MEDICAL CENTER INC. 6 
A-02-18-32645  NANOMETICS, LLC 1 
A-02-18-32679  CHILDREN'S FUTURES, INC. & CHILDREN'S FUTURES SUPP 1 
A-02-18-32683  SCHC COMPANIES INC. & AFFILIATES 1 
A-02-18-32684  BETANCES HEALTH CENTER 5 
A-02-18-32740  NEWARK COMMUNITY HEALTH CENTERS, INC. 1 
A-02-18-32744  MIDDLETOWN COMMUNITY HEALTH CENTER INC. 1 
A-02-18-32745  NASSAU COUNTY NEW YORK 1 
A-02-18-32746  BROOKLYN PLAZA MEDICAL CENTER INC. 1 
A-02-18-32769  ALBERT EINSTEIN COLLEGE OF MEDICINE, INC. 0 
A-02-18-32777  RESEARCH FOUNDATION FOR MENTAL HYGIENE INC. 0 
A-02-18-32778  ICAHN SCHOOL OF MEDICINE AT MT. SINAI 0 
A-02-18-32779  PUBLIC HEALTH SOLUTIONS 0 
A-02-18-32780  MEMORIAL SLOAN KETTERING CANCER CENTER & AFFILIATE 0 
A-02-18-32808  COLLEGE OF NEW ROCHELLE 0 
A-02-18-32893  AHRC HEALTH CARE, INC. (D/B/A ACCESS COMMUNITY HEA 4 
A-02-18-32894  MT. VERNON NEIGHBORHOOD HEALTH CENTER INC. 3 
A-02-18-32946  HUDSON COUNTY NEW JERSEY 0 
A-02-18-32971  BEACON CHRISTIAN COMMUNITY HEALTH CENTERS, INC. 5 
A-02-18-32987  TRI-COUNTY COMMUNITY ACTION AGENCY INC. 0 
A-02-18-33022  AMERICAN INDIAN COMMUNITY HOUSE, INC. 6 
A-02-18-33023  STATE OF NEW YORK 19 
A-02-18-33031  CALADRIUS BIOSCIENCES 2 
A-02-18-33057  HOUSING WORKS INC. & AFFILIATES 2 
A-02-18-33206  RESEARCH FOUNDATION FOR THE STATE UNIV. OF NEW YOR 0 
A-02-18-33281  ONEIDA INDIAN NATION 0 
A-03-14-00010  CMS Did Not Adequately Address Discrepancies in the Coding  $102,000,000  1 
Guidelines for Kwashiorkor 
A-03-16-00201  The District of Columbia Claimed Some Day Treatment Program  $4,588,756  0 
Services That Were Not in Compliance With Federal or District 
Requirements 
4/19/2018 8:38:04AM  Page 2 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-03-18-00352  Independent Attestation Review: National Institutes of Health Fiscal   0 
Year 2017 Detailed Accounting Submissions and Performance 
Summary Report for National Drug Control Activities and 
Accompanying Required Assertions 
A-03-18-00353  Independent Attestation Review: Substance Abuse and Mental   0 
Health Services Administration Fiscal Year 2017 Detailed Accounting 
Submission and Performance Summary Report for National Drug 
Control Activities and Accompanying Required Assertions 
A-03-18-00354  Independent Attestation Review: Health Resources and Services  0 
Administration Fiscal Year 2017 Detailed Accounting Submission and 
Performance Summary Report for National Drug Control Activities 
and Accompanying Required Assertions 
A-03-18-00355  Independent Attestation Review: Centers for Disease Control and  0 
Prevention Fiscal Year 2017 Detailed Accounting Submission and 
Performance Summary Report for National Drug Control Activities 
and Accompanying Required Assertions 
A-03-18-31482  CITY OF NORFOLK VIRGINIA 0 
A-03-18-31496  TRI-AREA COMMUNITY HEALTH 0 
A-03-18-31524  TRI-AREA COMMUNITY HEALTH 1 
A-03-18-31635  CITY OF PHILADELPHIA 1 
A-03-18-31674  SALUS UNIV. & ITS FOUNDATION 0 
A-03-18-31759  NORTHSIDE CHRISTIAN HEALTH CENTER 3 
A-03-18-31760  HEALTHY START INC. 2 
A-03-18-31855  HOWARD UNIV. 4 
A-03-18-31864  GAUDENZIA INC. & GAUDENZIA FOUNDATION INC. 8 
A-03-18-31865  NEIGHBORHOOD HEALTH CENTERS OF THE LEHIGH VALLEY 3 
A-03-18-31880  CATHOLIC RELIEF SERVICES - UNITED STATES CONFERENC 1 
A-03-18-31883  LEHIGH VALLEY HEALTH NETWORK INC. 0 
A-03-18-31903  CROZER-KEYSTONE HEALTH SYSTEM 1 
A-03-18-31923  AMERICAN IMMUNIZATION REGISTRY ASSOCIATION 1 
A-03-18-31971  ELAINE ELLIS CENTER OF HEALTH INC. 2 
A-03-18-32014  AFRICARE 3 
A-03-18-32021  CITY OF BALTIMORE MARYLAND 7 
A-03-18-32032  COVENANT HOUSE INC. 1 
A-03-18-32051  INSTITUTE FOR CLINICAL RESEARCH INC. 2 
A-03-18-32058  AMERICAN ASSOCIATION OF POISON CONTROL CENTERS 1 
A-03-18-32095  AMMFT RESEARCH & EDUCATION FOUNDAITON 1 
A-03-18-32104  SCRANTON PRIMARY HEALTH CARE CENTER INC. 1 
A-03-18-32152  ASSOCIATION OF STATE & TERRITORIAL HEALTH OFFICIAL 1 
A-03-18-32156  HENRY M. JACKSON FOUNDATION FOR THE ADV. OF MILITA 2 
A-03-18-32205  AMERICAN INTERNATIONAL HEALTH ALLIANCE, INC. 8 
A-03-18-32307  DISTRICT OF COLUMBIA PRIMARY CARE ASSOCIATION 3 
A-03-18-32348  POPULATION SERVICES INTERNATIONAL 2 
A-03-18-32376  PRIMARY CARE HEALTH SERVICES, INC. 3 
A-03-18-32382  NATIONAL ALLIANCE OF STATE & TERRITORIAL AIDS DIRE 2 
A-03-18-32408  AMERICAN ASSOCIATION OF BLOOD BANKS 2 
A-03-18-32505  STO-ROX NEIGHBORHOOD HEALTH COUNCIL INC. 6 
A-03-18-32535  WILLIAMSON HEALTH & WELLNESS CENTER, INC. 1 
A-03-18-32537  MISSION WEST VIRGINIA, INC. 1 
A-03-18-32559  CIRCULOMICS INC. 1 
A-03-18-32566  KEYSTONE NANO, INC. 1 
A-03-18-32585  PROTEIN POTENTIAL, LLC 1 
A-03-18-32633  AZEVAN PHARMACEUTICALS, INC. 1 
A-03-18-32673  FAMILY & MEDICAL COUNSELING SERVICE INC. 1 
A-03-18-32681  WELSH MOUNTAIN MEDICAL & DENTAL CENTER INC. 3 
A-03-18-32708  CITY OF BALTIMORE MARYLAND 6 
A-03-18-32709  AMERICAN COLLEGE OF MEDICAL GENETICS & GENOMICS 2 
A-03-18-32719  HEMOSONICS, LLC 1 
A-03-18-32738  GEISINGER HEALTH SYSTEM 1 
A-03-18-32739  HAMILTON HEALTH CENTER INC. & SUBSIDIARY 1 
4/19/2018 8:38:04AM  Page 3 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-03-18-32762  NATIONAL INDIAN HEALTH BOARD 2 
A-03-18-32764  SOUTHBRIDGE MEDICAL ADVISORY COUNCIL, INC. 1 
A-03-18-32770  HIGHMARK HEALTH 1 
A-03-18-32776  HEALTH INTEGRITY, LLC 0 
A-03-18-32878  PENNSYLVANIA MOUNTAINS HEALTHCARE RESOURCE DEVELOP 2 
A-03-18-32885  KENNEDY KRIEGER INSTITUTE INC. & AFFILIATES 1 
A-03-18-32912  WEST VIRGINIA UNIV. RESEARCH CORP. 0 
A-03-18-32918  DEVELOPMENT SERVICES GROUP INC. 1 
A-03-18-32942  FAMILY HEALTH CENTERS OF BALTIMORE INC. 2 
A-03-18-32968  SUSQUEHANNA COMMUNITY HEALTH & DENTAL CLINIC, INC. 3 
A-03-18-33015  CITY OF RICHMOND VIRGINIA 0 
A-03-18-33076  UPMC 0 
A-03-18-33077  CHILDREN'S HOSPITAL OF PHILADELPHIA FOUNDATION & C 0 
A-03-18-33144  BOARD OF EDUCATION OF PRINCE GEORGE'S COUNTY 3 
A-03-18-33155  ST. CHARLES HEALTH COUNCIL INC. 2 
A-03-18-33166  BALTIMORE HEALTHY START, INC. 1 
A-03-18-33261  THOMAS JEFFERSON UNIV. & CONTROLLED AFFILIATES 2 
A-03-18-33304  STATE OF WEST VIRGINIA 11 
A-04-15-06190  Tennessee Managed Care Organizations Received Medicaid  $1,814,761 3 
Capitation Payments After Beneficiry's Death 
A-04-16-04046  The National Institutes of Health Did Not Always Administer  4 
Superfund Appropriations During Fiscal Year 2015 in Accordance 
With Federal Requirements 
A-04-16-04049  Medicare Compliance Review of Carolinas Medical Center for Claims  $1,659,619  2 
Paid From January 1, 2014, Through December 31, 2015 
A-04-16-04054  North Carolina Did Not Comply With Federal and State Requirements  $41,188,318 1 
When Making Medicaid Cost-Sharing Payments for Professional 
Medical Services 
A-04-16-07061  Managed Care Payments for Benes with Multiple Medicaid IDs in GA  $667,472  1 
A-04-16-08049  Ohio Received Millions in Unallowable Bonus Payments  $29,524,741 0 
A-04-16-08050  Kansas Received Millions in Unallowable Bonus Payments  $17,796,598 0 
A-04-17-01003  Aurum Institute Generally Managed and Expended the President's  2 
Emergency Plan for AIDS Relief Funds in Accordance With Award 
Requirements 
A-04-17-02003  HRSA Complied With Federal and HHS Grant Policies When Awarding  0 
Zika Response and Preparedness Appropriations Act Funds During 
Fiscal Year 2017 
A-04-17-02004  CDC Domestic Recipients Receiving Global Health Security Agenda  0 
(GHSA) Funds 
A-04-17-02500  North Carolina Did Not Always Verify Correction of Deficiencies  2 
Identified During Surveys of Nursing Homes Participating in Medicare 
and Medicaid 
A-04-17-08055  Compliance Review of Selected Medicare Claims at Memorial  $1,455,892  2 
University Medical Center for CY 2015 and 2016 
A-04-17-08056  Idaho Received Millions in Unallowable Bonus Payments  $3,103,167 0 
A-04-18-31427  OCRACOKE HEALTH CENTER 0 
A-04-18-31670  CLAIBORNE COUNTY FAMILY HEALTH CENTER INC. 2 
A-04-18-31671  BAKERSVILLE COMMUNITY MEDICAL CLINIC, INC. 1 
A-04-18-31746  CENTER FOR BLACK WOMEN'S WELLNESS, INC. 1 
A-04-18-31854  SHAW UNIV. INC. 0 
A-04-18-31874  TRIAD ADULT & PEDIATRIC MEDICINE, INC. 0 
A-04-18-31875  TRIAD ADULT & PEDIATRIC MEDICINE, INC. 2 
A-04-18-31952  MONTGOMERY COUNTY NORTH CAROLINA 1 
A-04-18-31963  ACCESS FAMILY HEALTH SERVICES INC. 1 
A-04-18-31970  FAMILY HEALTH CENTERS, INC. 1 
A-04-18-31972  FOOTHILLS COMMUNITY HEALTH CARE INC. 3 
A-04-18-32009  G.A. CARMICHAEL FAMILY HEALTH CENTER, INC. 2 
A-04-18-32048  BAPTIST HEALTHCARE SYSTEM, INC. & AFFILIATES 2 
A-04-18-32059  UNITED HEALTH CENTERS 2 
A-04-18-32097  PARK DUVALLE COMMUNITY HEALTH CENTER, INC. 1 
A-04-18-32102  FOOTHILLS COMMUNITY HEALTH CARE INC. 0 
4/19/2018 8:38:04AM  Page 4 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-04-18-32111  UNIV. OF ALABAMA 1 
A-04-18-32113  PINELLAS COUNTY FLORIDA 1 
A-04-18-32114  CENTRAL FLORIDA FAMILY HEALTH CENTER, INC. 1 
A-04-18-32172  TOMBIGBEE HEALTHCARE AUTHORITY 2 
A-04-18-32273  MICCOSUKEE CORP. 0 
A-04-18-32290  UNIV. OF ALABAMA AT BIRMINGHAM 0 
A-04-18-32304  MISSISSIPPI FAMILIES AS ALLIES FOR CHILDRENS MENTA 0 
A-04-18-32305  BAKERSVILLE COMMUNITY MEDICAL CLINIC, INC. 1 
A-04-18-32306  CHARLOTTE-MECKLENBURG HOSPITAL AUTHORITY 1 
A-04-18-32354  CAHABA MEDICAL CARE FOUNDATION 1 
A-04-18-32371  POARCH BAND OF CREEK INDIANS 2 
A-04-18-32384  METROPOLITAN COMMUNITY HEALTH SERVICES INC. 7 
A-04-18-32406  AMITE COUNTY MEDICAL SERVICES INC. 1 
A-04-18-32407  EAST CENTRAL MISSISSIPPI HEALTH CARE, INC. 1 
A-04-18-32432  FLORIDA ASSOCIATION OF COMMUNITY HEALTH CENTERS, I 1 
A-04-18-32433  CATAWBA INDIAN NATION 3 
A-04-18-32458  HIGH COUNTRY COMMUNITY HEALTH, INC. 1 
A-04-18-32464  HEALTH SERVICES INC. 4 
A-04-18-32465  GOSHEN MEDICAL CENTER INC. 1 
A-04-18-32520  CHRIST COMMUNITY HEALTH SERVICES AUGUSTA INC. 2 
A-04-18-32525  EPICYPHER, INC. 3 
A-04-18-32534  SOUTHEAST ALABAMA RURAL HEALTH ASSOCIATION 1 
A-04-18-32670  COLUMBUS DEPT. OF PUBLIC HEALTH 1 
A-04-18-32703  HEALTH SERVICES CENTER INC. 4 
A-04-18-32705  SOUTHERN RESEARCH INSTITUTE 1 
A-04-18-32706  FULTON COUNTY GEORGIA 2 
A-04-18-32707  FURMAN UNIV. 1 
A-04-18-32715  AGILE SCIENCES INC. 1 
A-04-18-32736  SHAWNEE CHRISTIAN HEALTHCARE CENTER 2 
A-04-18-32750  SOUTH CAROLINA PRIMARY HEALTH CARE ASSOCIATION 1 
A-04-18-32759  MORE THAN CONQUERORS, INC. 1 
A-04-18-32768  BROWARD REGIONAL HEALTH PLANNING COUNCIL INC. 0 
A-04-18-32785  CARE NET OF LANCASTER 6 
A-04-18-32791  RURAL HEALTH SERVICES INC. D/B/A MARGARET J. WESTO 1 
A-04-18-32805  NEIGHBORHOOD MEDICAL CENTER INC. 4 
A-04-18-32859  ST. JUDE CHILDREN'S RESEARCH HOSPITAL, INC. & SUBS 0 
A-04-18-32865  NEW HORIZON FAMILY HEALTH SERVICES INC. 4 
A-04-18-32866  ANSON REGIONAL MEDICAL SERVICES INC. 1 
A-04-18-32883  CENTRAL NORTH ALABAMA HEALTH SERVICES INC. 1 
A-04-18-32938  CATAWBA INDIAN NATION 1 
A-04-18-32939  WAKE HEALTH SERVICES INC. 2 
A-04-18-32978  CATAWBA COUNTY NORTH CAROLINA 0 
A-04-18-32981  WAKE FOREST UNIV. 0 
A-04-18-33000  RURAL HEALTH MEDICAL PROGRAM INC. 1 
A-04-18-33013  FAMILY HEALTH CENTERS OF GEORGIA INC. 1 
A-04-18-33020  VANDERBILT UNIV. MEDICAL CENTER 1 
A-04-18-33050  CHEROKEE HEALTH SYSTEMS 2 
A-04-18-33051  BOND COMMUNITY HEALTH CENTER INC. 3 
A-04-18-33052  TRIAD ADULT & PEDIATRIC MEDICINE, INC. 1 
A-04-18-33068  CALDWELL COUNTY 0 
A-04-18-33086  FAMILY & CHILDRENS SERVICE TENNESSEE 1 
A-04-18-33113  EMPOWER 'U', INC. 3 
A-04-18-33141  SOUTHEAST CLINICAL ONCOLOGY RESEARCH CONSORTIUM IN 1 
A-04-18-33142  MOREHOUSE SCHOOL OF MEDICINE INC. & AFFILIATE 1 
A-04-18-33189  SHELBY COUNTY TENNESSEE 0 
A-04-18-33190  POLK COUNTY DISTRICT SCHOOL BOARD 0 
A-04-18-33193  MEDICAL UNIV. OF SOUTH CAROLINA 0 
A-04-18-33196  ROCKINGHAM COUNTY 0 
4/19/2018 8:38:04AM  Page 5 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-04-18-33223  MOUNTAIN PROJECTS INC. 0 
A-04-18-33256  EASTERN BAND OF CHEROKEE INDIANS 9 
A-04-18-33291  MEHARRY MEDICAL COLLEGE 0 
A-04-18-33294  LUTHERAN SERVICES FLORIDA INC. & SUBSIDIARIES 0 
A-05-14-00041  Physical Therapists Nationwide Claimed Unallowable Medicare Part B  3 
Reimbursement for Outpatient Therapy Services 
A-05-14-00049  CMS Generally Met Requirements in Round 2 of the DMEPOS  3 
Competitive Bidding Program 
A-05-16-00013  Ohio Claimed Unallowable Federal Reimbursement for Some Medicaid  $2,325,552  $20,007,447  2 
Physician-Administered Drugs 
A-05-16-00044  Review of Health and Safety Standards for Family Adult Foster  4 
Homes in Minnesota 
A-05-16-00056  Indiana Did Not Always Comply With Maternal, Infant, and Early  4 
Childhood Home Visiting Program Requirements 
A-05-16-00059  Hospitals Did Not Always Comply With Medicare Requirements for  $4,410,568  3 
Reporting Cardiac Device Credits 
A-05-16-00062  Medicare Compliance Review of Rush University Medical Center  $10,158,611  2 
A-05-16-00064  Medicare Compliance Review of the University of Michigan Health  $6,162,201  2 
System for 2014 and 2015 
A-05-18-31756  YOUTH NETWORK COUNCIL D/B/A ILLINOIS COLLABORATION 2 
A-05-18-31861  FAMILY CHRISTIAN HEALTH CENTER 4 
A-05-18-31862  TCA HEALTH INC. 4 
A-05-18-31901  COMMUNITY HEALTH SYSTEMS, INC. 8 
A-05-18-31908  FAMILY HEALTH CENTER INC. 1 
A-05-18-31914  FOND DU LAC BAND OF LAKE SUPERIOR CHIPPEWA 0 
A-05-18-31973  AUNT MARTHA'S YOUTH SERVICE CENTER INC. & SUBSIDIA 1 
A-05-18-31974  CIRCLE HEALTH SERVICES 1 
A-05-18-31976  SOUTHERN ILLINOIS HEALTHCARE FOUNDATION INC. 3 
A-05-18-32012  IIT RESEARCH INSTITUTE 2 
A-05-18-32017  UNITED FAMILY PRACTICE HEALTH CENTER & SUBSIDIARIE 3 
A-05-18-32030  FAMILY HEALTH CENTER OF MARSHFIELD INC. 2 
A-05-18-32052  CITY OF DETROIT 2 
A-05-18-32053  KNOX COUNTY, ILLINOIS 3 
A-05-18-32116  OPEN DOOR HEALTH CENTER 2 
A-05-18-32118  WESTERN WAYNE FAMILY HEALTH CENTERS 1 
A-05-18-32146  LAKES COMMUNITY HEALTH CENTER, INC. 2 
A-05-18-32151  BATTELLE MEMORIAL INSTITUTE & SUBSIDIARIES 1 
A-05-18-32159  SAGINAW COUNTY COMMUNITY MENTAL HEALTH AUTHORITY 3 
A-05-18-32176  NATIONAL AHEC ORGANIZATION, INC. 3 
A-05-18-32277  WHITE EARTH RESERVATION 0 
A-05-18-32278  LOWER SIOUX INDIAN COMMUNITY SERVICES DEPT. 2 
A-05-18-32279  GRAND PORTAGE RESERVATION TRIBAL COUNCIL 0 
A-05-18-32280  BOIS FORTE BAND OF CHIPPEWA 1 
A-05-18-32281  FOREST COUNTY POTAWATOMI COMMUNITY 0 
A-05-18-32282  GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS 1 
A-05-18-32283  KEWEENAW BAY INDIAN COMMUNITY 0 
A-05-18-32285  SAULT STE. MARIE TRIBE OF CHIPPEWA INDIANS 1 
A-05-18-32351  NEIGHBORHOOD HEALTHSOURCE 2 
A-05-18-32352  LAC COURTE OREILLES BAND OF LAKE SUPERIOR CHIPPEWA 8 
A-05-18-32353  AXESSPOINTE COMMUNITY HEALTH CENTER INC. 2 
A-05-18-32374  MILWAUKEE HEALTH SERVICES INC. 4 
A-05-18-32375  HEART OF OHIO FAMILY HEALTH CENTERS 2 
A-05-18-32385  DETROIT HEALTH CARE FOR THE HOMELESS 0 
A-05-18-32386  CITY OF CHICAGO  $11,931  1 
A-05-18-32415  LITTLE TRAVERSE BAY BANDS OF ODAWA INDIANS 0 
A-05-18-32436  HENDERSON COUNTY RURAL HEALTH CENTER INC. 4 
A-05-18-32448  NDI MEDICAL, LLC 2 
A-05-18-32490  DELPHINUS MEDICAL TECHNOLOGIES, INC. 1 
A-05-18-32517  DETROIT COMMUNITY HEALTH CONNECTION, INC. 1 
A-05-18-32567  TSRL, INC. 1 
4/19/2018 8:38:04AM  Page 6 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-05-18-32582  CARECHOICE COOPERATIVE HEALTH CARE INNOVATION AWAR 4 
A-05-18-32622  NAVIDEA BIOPHARMACEUTICALS INC. 1 
A-05-18-32678  ERIE COUNTY GENERAL HEALTH DISTRICT 2 
A-05-18-32699  OAKLAND PRIMARY HEALTH SERVICES, INC. 0 
A-05-18-32731  CEDAR RIVERSIDE PEOPLE'S CENTER 1 
A-05-18-32732  WELLNESS PLAN MEDICAL CENTERS 2 
A-05-18-32734  NORTHEAST OHIO NEIGHBORHOOD HEALTH SERVICES INC. 2 
A-05-18-32742  PARTNERSHIP COMMUNITY HEALTH CENTER, INC. 1 
A-05-18-32752  BAY MILLS INDIAN COMMUNITY 1 
A-05-18-32753  OPEN DOOR CLINIC OF GREATER ELGIN 2 
A-05-18-32754  SOUTHSIDE COMMUNITY HEALTH SERVICES INC. 4 
A-05-18-32772  RED LAKE BAND OF CHIPPEWA INDIANS 0 
A-05-18-32790  DETROIT HEALTH CARE FOR THE HOMELESS 10 
A-05-18-32803  MIDWESTERN UNIV. 1 
A-05-18-32847  LAC VIEUX DESERT BAND OF LAKE SUPERIOR CHIPPEWA IN 0 
A-05-18-32848  LITTLE RIVER BAND OF OTTAWA INDIANS 0 
A-05-18-32890  COMMUNITY HEALTH SYSTEMS, INC. 6 
A-05-18-32891  OUTREACH COMMUNITY HEALTH CENTERS, INC. 7 
A-05-18-32892  DECATUR COUNTY INDIANA 5 
A-05-18-32913  MEDICAL COLLEGE OF WISCONSIN, INC. 0 
A-05-18-32944  SCHOOL DISTRICT OF WESTFIELD 2 
A-05-18-32965  MARIAN UNIV. INC. 0 
A-05-18-32966  INSTITUTE FOR POPULATION HEALTH INC. 11 
A-05-18-33004  NEAR NORTH HEALTH SERVICE CORP. 1 
A-05-18-33019  BERLIN AREA SCHOOL DISTRICT 1 
A-05-18-33074  COMMON GROUND HEALTHCARE COOPERATIVE 2 
A-05-18-33075  HEARTLAND ALLIANCE FOR HUMAN NEEDS & HUMAN RIGHTS 0 
A-05-18-33118  CHICAGO FAMILY HEALTH CENTER, INC. & SUBSIDIARIES 1 
A-05-18-33150  M.G.H. FAMILY HEALTH CENTER DBA: MUSKEGON FAMILY C 1 
A-05-18-33151  COMMUNITY HEALTH & EMERGENCY SERVICES INC. 6 
A-05-18-33169  CITY OF DETROIT 1 
A-05-18-33170  HAMILTON COMMUNITY HEALTH NETWORK, INC. 2 
A-05-18-33171  NORTHWEST INDIANA HEALTH DEPT. COOPERATIVE 4 
A-05-18-33173  CEDARVILLE UNIVERSITY 0 
A-05-18-33181  ONEIDA NATION 1 
A-05-18-33280  MATCH-E-BE-NASH-SHE-WISH BAND OF POTTAWATOMI INDIA 0 
A-06-12-00043  REVIEW OF PHYSICIAN SUPPLEMENTAL PAYMENTS AT TEXAS TECH  $9,911,321  0 
UNIVERSITY 
A-06-15-00041  Texas Did Not Appropriately Spend Some State Balancing Incentive  $11,982,826  2 
Payments Program Funds 
A-06-16-00004  Texas Did Not Bill Some Manufacturers for Rebates for Pharmacy  $4,438,368  1 
Drugs Dispensed to Enrollees of Medicaid Managed-Care 
Organizations 
A-06-16-00018  Review of Physician Administered Drug Rebates in Arkansas  $9,892,356  2 
A-06-16-05004  Texas Managed Care Organizations Received Medicaid Capitation  $1,038,875  3 
Payments After Beneficiarys Deaths 
A-06-16-08004  Oklahoma May Be Paying for Provider-Preventable Conditions on  1 
Some Inpatient Hospital Claims 
A-06-16-08012  Oklahoma Did Not Correctly Process Adjustments to Medicare  1 
Crossover Claims 
A-06-18-31412  SOONERVERSE, INC. 0 
A-06-18-31610  COMANCHE NATION GOVERNMENTAL PROGRAMS DEPT. 0 
A-06-18-31902  LA CASA DE BUENA SALUD INC. 3 
A-06-18-32008  PREVENTATIVE CARE HEALTH SERVICES, INC. 4 
A-06-18-32056  LONE STAR COMMUNITY HEALTH CENTER INC. 1 
A-06-18-32060  EAST TEXAS BORDER HEALTH CLINIC D/B/A GENESIS PRIM 1 
A-06-18-32092  PRESBYTERIAN MEDICAL SERVICES 1 
A-06-18-32110  TARRANT COUNTY TEXAS 1 
A-06-18-32145  COUNCIL FOR ADVANCEMENT OF SOCIAL SERVICES & EDUCA 3 
A-06-18-32170  ELLIS COUNTY COALITION FOR HEALTH OPTIONS, INC. (H 3 
4/19/2018 8:38:04AM  Page 7 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-06-18-32201  TEXAS BIOMEDICAL RESEARCH INSTITUTE  1 
A-06-18-32263  PUEBLO OF POJOAQUE  3 
A-06-18-32264  MESCALERO APACHE TRIBE  0 
A-06-18-32268  CHICKASAW NATION  0 
A-06-18-32269  WICHITA & AFFILIATED TRIBES  1 
A-06-18-32270  MODOC TRIBE OF OKLAHOMA  0 
A-06-18-32271  SEMINOLE NATION OF OKLAHOMA  5 
A-06-18-32272  SAC & FOX NATION OF OKLAHOMA  0 
A-06-18-32311  KICKAPOO TRIBE OF OKLAHOMA  0 
A-06-18-32332  PUEBLO DE SAN FELIPE  0 
A-06-18-32346  SOUTH CENTRAL HOUSTON ACTION COUNCIL, INC. D/B/A C  11 
A-06-18-32347  CITY OF BATON ROUGE & PARISH OF EAST BATON ROUGE  1 
A-06-18-32362  MIAMI TRIBE OF OKLAHOMA  0 
A-06-18-32363  ABSENTEE SHAWNEE TRIBE OF INDIANS OF OKLAHOMA  0 
A-06-18-32370  COUSHATTA TRIBE OF LOUISIANA  3 
A-06-18-32405  HEALTH SERVICES OF NORTH TEXAS, INC.  1 
A-06-18-32412  PICURIS PUEBLO  0 
A-06-18-32413  CHOCTAW NATION OF OKLAHOMA  1 
A-06-18-32418  VALLEY AIDS COUNCIL, INC.  0 
A-06-18-32482  RAMAH NAVAJO SCHOOL BOARD, INC.  2 
A-06-18-32491  VISIONQUEST BIOMEDICAL, LLC  1 
A-06-18-32499  HIDALGO MEDICAL SERVICES  3 
A-06-18-32514  SANTO DOMINGO TRIBE TRIBAL PROGRAMS OFFICE  7 
A-06-18-32530  WINDMILL CARDIOVASCULAR SYSTEMS, INC.  4 
A-06-18-32548  PEORIA TRIBE OF INDIANS OF OKLAHOMA  0 
A-06-18-32640  VULINTUS, INC.  1 
A-06-18-32659  PUEBLO OF TESUQUE  3 
A-06-18-32660  JICARILLA APACHE NATION  3 
A-06-18-32661  PUEBLO OF ISLETA  3 
A-06-18-32662  PUEBLO OF ZUNI  2 
A-06-18-32664  LONGVIEW WELLNESS CENTER INC.  1 
A-06-18-32665  SPECIAL HEALTH RESOURCES OF EAST TEXAS INC.  1 
A-06-18-32667  PAWNEE NATION OF OKLAHOMA  1 
A-06-18-32668  CHEYENNE & ARAPAHO TRIBES OF OKLAHOMA  8 
A-06-18-32695  PUEBLO DE COCHITI GOVERNMENTAL SERVICES DEPARTMENT  4 
A-06-18-32696  PREVENTATIVE CARE HEALTH SERVICES, INC.  2 
A-06-18-32700  KAW NATION  1 
A-06-18-32701  OTOE-MISSOURIA TRIBE OF INDIANS  4 
A-06-18-32722  YSLETA DEL SUR PUEBLO  0 
A-06-18-32729  MT. ENTERPRISE COMMUNITY HEALTH CLINIC  2 
A-06-18-32758  ST. GABRIEL HEALTH CLINIC INC.  0 
A-06-18-32796  MID-DELTA HEALTH SYSTEMS INC.  1 
A-06-18-32831  OHKAY OWINGEH  0 
A-06-18-32832  PUEBLO OF SANDIA  2 
A-06-18-32833  TAOS PUEBLO CENTRAL MANAGEMENT SYSTEM  0 
A-06-18-32834  SANTA CLARA INDIAN PUEBLO ADMINISTRATIVE UNIT  0 
A-06-18-32835  PUEBLO OF ACOMA  1 
A-06-18-32839  ALABAMA-COUSHATTA TRIBE OF TEXAS  0 
A-06-18-32840  FORT SILL APACHE TRIBE OF OKLAHOMA  0 
A-06-18-32841  IOWA TRIBE OF OKLAHOMA  2 
A-06-18-32856  INDIAN HEALTH CARE RESOURCE CENTER OF TULSA INC.  0 
A-06-18-32858  BAYLOR COLLEGE OF MEDICINE  0 
A-06-18-32871  AMERICAN HEART ASSOCATIONS, INC.  1 
A-06-18-32879  HOUSTON AREA COMMUNITY SERVICES, INC.  4 
A-06-18-32880  UNIV. OF OKLAHOMA HEALTH SCIENCES CENTER  1 
A-06-18-32881  UNIV. OF OKLAHOMA NORMAN CAMPUS  2 
A-06-18-32882  UNIV. OF ARKANSAS FOR MEDICAL SCIENCES  0 
A-06-18-32898  PUEBLO OF LAGUNA  3 
4/19/2018 8:38:04AM  Page 8 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-06-18-32899  TEXAS HEART INSTITUTE & SUBSIDIARIES 3 
A-06-18-32901  EXCELTH, INC. 1 
A-06-18-32932  LANGSTON UNIV. 1 
A-06-18-32936  ST. GABRIEL HEALTH CLINIC INC. 3 
A-06-18-32995  NEW MEXICO OFFICE OF THE SUPERINTENDENT OF INSURAN 11 
A-06-18-32998  TEXAS A&M RESEARCH FOUNDATION 2 
A-06-18-33006  NEW MEXICO CONSORTIUM & SUBSIDIARY 1 
A-06-18-33010  EIGHT NORTHERN INDIAN PUEBLOS COUNCIL, INC. 6 
A-06-18-33046  LA FAMILIA MEDICAL CENTER 5 
A-06-18-33081  PUEBLO DE SAN ILDEFONSO 0 
A-06-18-33082  EASTERN SHAWNEE TRIBE OF OKLAHOMA 0 
A-06-18-33083  TUNICA-BILOXI TRIBE OF LOUISIANA 7 
A-06-18-33138  NEW MEXICO HUMAN SERVICES DEPT. 8 
A-06-18-33140  COUNCIL FOR ADVANCEMENT OF SOCIAL SERVICES & EDUCA 2 
A-06-18-33229  NEW MEXICO DEPT. OF HEALTH 2 
A-06-18-33230  DISABILITY RIGHTS ARKANSAS INC. 1 
A-06-18-33275  FIRST NATIONS COMMUNITY HEALTHSOURCE INC. 0 
A-06-18-33276  PUEBLO OF NAMBE 0 
A-06-18-33278  COMANCHE NATION GOVERNMENTAL PROGRAMS DEPT. 0 
A-07-13-06046  Physician Administered Drug Rebates for Managed Care Claims in  $1,065,264  2 
Nebraska 
A-07-16-00486  Review of North Carolina Medicaid General Controls over the NC  9 
Fast Eligibiility Determination System 
A-07-16-00493  First Coast Service Options, Inc., Understated Its Allocable Pension  2 
Costs 
A-07-16-00494  First Coast Service Options, Inc., Understated Its Medicare  $1,033,833  1 
Segment Pension Assets 
A-07-16-00495  First Coast Service Options, Inc., Generally Claimed Allowable  $33,619  0 
Medicare Pension Costs 
A-07-16-05087  Review of Medicare Part C Payment on Behalf of Deceased  $2,420,761  1 
Beneficiaries 
A-07-17-00506  Palmetto Government Benefits Administrator, LLC Claimed Some  $95,038  0 
Unallowable Pension Costs Through Its Incurred Costs Proposals 
A-07-17-00513  CGS Administrators, LLC, Did Not Claim Some Allowable Pension  1 
Costs Through Its Incurred Cost Proposals 
A-07-17-00516  Wisconsin Physician Service Insurance Corporation Understated Its  $241,574  1 
Medicare Segment Pension Assets for Its Employees' Pension Plan 
A-07-17-00517  Wisconsin Physicians Service Insurance Corporation Overstated Its  $33,463  1 
Medicare Segment Penion Assets for Its Managerial Retirement 
Program for Selected Locations 
A-07-17-00518  Wisconsin Physician Service Insurance Corporation Understated Its  $3,214,152  1 
Medicare Segment Pension Assets for Its Managerial Pension Plan 
A-07-17-00519  Wisconsin Physicians Service Insurance Corporation Did Not Claim  1 
Some Allowable Medicare Pension Costs 
A-07-17-00520  Wisconsin Physicians Service Insurance Corporation Understated Its  2 
Allocable Pension Costs 
A-07-18-31672  COMMUNITY HEALTH CENTERS OF SOUTHERN IOWA INC. 3 
A-07-18-31673  PARAQUAD, INC. & PARAQUAD 5240, INC. 2 
A-07-18-31758  ASCENSION HEALTH ALLIANCE 1 
A-07-18-31857  CITY OF ST. LOUIS 2 
A-07-18-31922  HUNTER HEALTH CLINIC INC. 4 
A-07-18-31965  IOWA HEALTH SYSTEM & SUBSIDIARIES 0 
A-07-18-32098  CHARLES DREW HEALTH CENTER INC. & FOUNDATION 1 
A-07-18-32207  OMAHA TRIBE OF NEBRASKA 12 
A-07-18-32274  PONCA TRIBE OF NEBRASKA 0 
A-07-18-32275  WINNEBAGO TRIBE OF NEBRASKA 4 
A-07-18-32308  COMMUNITY HEALTH CENTERS OF SOUTHERN IOWA INC. 1 
A-07-18-32328  HEARTLAND HEALTH CENTER INC. 4 
A-07-18-32356  GRACE HILL SETTLEMENT HOUSE 4 
A-07-18-32438  ATCHISON COMMUNITY HEALTH CLINIC INC. 5 
A-07-18-32466  EAST CENTRAL MISSOURI BEHAVIORAL HEALTH SERVICES, 4 
A-07-18-32467  SAC & FOX TRIBE OF THE MISSISSIPPI IN IOWA 10 
4/19/2018 8:38:04AM  Page 9 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-07-18-32503  KANSAS CITY CARE CLINIC  5 
A-07-18-32536  DES MOINES UNIV. - OSTEOPATHIC MEDICAL CENTER  0 
A-07-18-32641  APT THERAPEUTICS, INC.  2 
A-07-18-32674  PRAIRIE BAND POTAWATOMI NATION  1 
A-07-18-32711  DOUGLAS COUNTY, KANSAS  3 
A-07-18-32724  KICKAPOO TRIBE IN KANSAS  5 
A-07-18-32725  NATIONAL RURAL ACCOUNTABLE CARE CONSORTIUM  3 
A-07-18-32726  FATHER FLANAGAN'S BOYS' HOME DBA BOYS TOWN  1 
A-07-18-32789  SOUTHWEST BAPTIST UNIV.  0 
A-07-18-32845  IOWA TRIBE OF KANSAS & NEBRASKA  0 
A-07-18-32860  UNIV. OF KANSAS MEDICAL CENTER RESEARCH INSTITUTE,  1 
A-07-18-32861  UNIV. OF KANSAS CENTER FOR RESEARCH INC.  0 
A-07-18-32888  METROPOLITAN COMMUNITY COLLEGE  0 
A-07-18-32889  MARYVILLE UNIV.  0 
A-07-18-32943  COMMUNITY ACTION PARTNERSHIP OF WESTERN NEBRASKA I  3 
A-07-18-32963  OZARK TRI-COUNTY HEALTH CARE CONSORTIUM, INC.  2 
A-07-18-32967  ASCENSION HEALTH ALLIANCE  1 
A-07-18-33002  PLANNED PARENTHOOD OF THE HEARTLAND INC.  1 
A-07-18-33003  MT. MERCY UNIV.  0 
A-07-18-33018  BIG SPRINGS MEDICAL ASSOCIATION, INC.  2 
A-07-18-33027  CITY OF ST. LOUIS MENTAL HEALTH  1 
A-07-18-33139  GREAT MINES HEALTH CENTER INC.  1 
A-07-18-33168  EAST CENTRAL MISSOURI BEHAVIORAL HEALTH SERVICES I  2 
A-08-18-31856  TURTLE MOUNTAIN BAND OF CHIPPEWA INDIANS  7 
A-08-18-31967  SUMMIT COMMUNITY CARE CLINIC, INC.  2 
A-08-18-32043  ACTION FOR EASTERN MONTANA  1 
A-08-18-32054  PREVENT CHILD ABUSE NORTH DAKOTA  6 
A-08-18-32057  UTAH PARTNERS FOR HEALTH  2 
A-08-18-32093  ARAPAHOE HOUSE, INC.  3 
A-08-18-32108  MARILLAC CLINIC INC.  6 
A-08-18-32177  BLACKFEET TRIBE OF THE BLACKFEET INDIAN RESERVATIO  3 
A-08-18-32210  THREE AFFILIATED TRIBES  9 
A-08-18-32211  TURTLE MOUNTAIN BAND OF CHIPPEWA INDIANS  7 
A-08-18-32237  BOULDER COUNTY COLORADO  2 
A-08-18-32266  ROCKY BOY HEALTH BOARD  0 
A-08-18-32267  ASSINIBOINE & SIOUX TRIBES OF THE FORT PECK INDIAN  1 
A-08-18-32276  SISSETON-WAHPETON OYATE  0 
A-08-18-32300  WASATCH HOMELESS HEALTH CARE INC.  4 
A-08-18-32345  LA CLINICA TEPEYAC  1 
A-08-18-32383  COMMUNITY ACTION OF LARAMIE COUNTY, INC.  6 
A-08-18-32404  UNCOMPAHGRE COMBINED CLINICS  1 
A-08-18-32428  PLAN DE SALUD DEL VALLE INC.  1 
A-08-18-32456  CUSTER COUNTY COMMUNITY HEALTH CENTER, INC.  2 
A-08-18-32457  NORTHLAND HEALTH PARTNERS COMMUNITY HEALTH CENTER  3 
A-08-18-32500  MOUNTAIN FAMILY HEALTH CENTERS  1 
A-08-18-32606  SITEONE THERAPEUTICS INC.  1 
A-08-18-32648  CARTERRA, INC.  1 
A-08-18-32657  PAIUTE INDIAN TRIBE OF UTAH  4 
A-08-18-32675  COMMUNITY HEALTH CENTER OF THE BLACK HILLS, INC. &  4 
A-08-18-32697  COMMUNITY HEALTH CENTER OF CENTRAL WYOMING INC.  4 
A-08-18-32761  BIGHORN VALLEY HEALTH CENTER INC.  1 
A-08-18-32774  SISTERS OF CHARITY OF LEAVENWORTH HEALTH SYSTEM IN  0 
A-08-18-32787  LOWER BRULE SIOUX TRIBE  8 
A-08-18-32788  NEUROPSYCHIATRIC RESEARCH INSTITUTE & NRI MEDICAL  1 
A-08-18-32836  NORTHWESTERN BAND OF THE SHOSHONE NATION  0 
A-08-18-32837  NORTHERN ARAPAHO TRIBE OF INDIANS  0 
A-08-18-32846  OGLALA SIOUX TRIBE  0 
A-08-18-32875  EASTERN SHOSHONE TRIBE  8 
4/19/2018 8:38:04AM  Page 10 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-08-18-32903  AVERA HEALTH 5 
A-08-18-33001  CANKDESKA CIKANA COMMUNITY COLLEGE 2 
A-08-18-33009  CARBON MEDICAL SERVICE ASSOCIATION INC. 2 
A-08-18-33047  SOUTHERN UTE INDIAN TRIBE 1 
A-08-18-33085  NATRONA COUNTY WYOMING 4 
A-08-18-33097  BLACKROCK MICROSYSTEMS, LLC 1 
A-08-18-33098  BLACKROCK MICROSYSTEMS, LLC 1 
A-08-18-33110  UTAH NAVAJO HEALTH SYSTEM, INC. 2 
A-08-18-33117  CHEYENNE RIVER SIOUX TRIBE 8 
A-08-18-33137  STATE OF UTAH 6 
A-08-18-33152  PREVENT CHILD ABUSE NORTH DAKOTA 4 
A-08-18-33156  GREEN RIVER MEDICAL CENTER 1 
A-08-18-33290  COMMUNITY DEVELOPMENT INSTITUTE HEAD START 0 
A-09-16-02023  California Made Medicaid Payments on Behalf of Newly Eligible  7 
Beneficiaries Who Did Not Meet Federal and State Requirements 
A-09-16-02031  Arizona Did Not Bill Manufacturers for Some Rebates for Drugs  $18,326,775  2 
Dispensed to Enrollees of Medicaid Managed Care Organizations 
A-09-16-02034  Medicare Improperly Paid Providers for Specimen Validity Tests Billed  $66,309,751  $12,146,760  0 
in Combination With Urine Drug Tests 
A-09-16-02037  Lincare Pharmacy Services Inc. Generally Complied with Medicare  1 
Requirements When Billing for Inhalation Drugs 
A-09-16-02042  Medicare Needs Better Controls to Prevent Fraud, Waste, and  4 
Abuse Related to Chiropractic Services: An OIG Portfolio 
A-09-17-03010  CMS Ensured That Medicare Shared Savings Program Beneficiaries  0 
Were Properly Assigned: Beneficiaries Were Assigned to Only One 
Accountable Care Organization and Were Not Assigned to Other 
Shared Savings Program 
A-09-18-31667  SOUTHERN TRINITY HEALTH SERVICES INC. 0 
A-09-18-31839  WILMINGTON COMMUNITY CLINIC 1 
A-09-18-31843  CHILDREN'S HOSPITAL & RESEARCH CENTER AT OAKLAND 4 
A-09-18-31863  ANTELOPE VALLEY COMMUNITY CLINIC 1 
A-09-18-31871  COALITION FOR A DRUG-FREE HAWAII INC. DBA DRUG-FRE 3 
A-09-18-31906  COMMONWEALTH HEALTHCARE CORP. 45 
A-09-18-31916  CENTRAL CITY COMMUNITY HEALTH CENTER 3 
A-09-18-32015  GUAM DEPT. OF EDUCATION 0 
A-09-18-32025  COMMUNITY MEDICAL CENTERS, INC. 4 
A-09-18-32026  STANFORD UNIV. 2 
A-09-18-32027  HEAD START OF NORTHEASTERN NEVADA 2 
A-09-18-32045  SUSTAINABLE SCIENCES INSTITUTE 0 
A-09-18-32047  COMMONWEALTH OF THE NORTHERN MARIANA ISLANDS PUBLI 2 
A-09-18-32088  GOVERNMENT OF GUAM 5 
A-09-18-32103  NORTHEAST VALLEY HEALTH CORP. 1 
A-09-18-32160  SUN LIFE FAMILY HEALTH CENTER INC. 2 
A-09-18-32166  REPUBLIC OF THE MARSHALL ISLANDS 0 
A-09-18-32167  INTER-TRIBAL COUNCIL OF NEVADA INC. 3 
A-09-18-32192  HAWAII YOUTH SERVICES NETWORK 2 
A-09-18-32193  FEDERATED STATES OF MICRONESIA 0 
A-09-18-32196  SAN CARLOS APACHE TRIBE 3 
A-09-18-32197  NAVAJO NATION 3 
A-09-18-32241  HOOPA VALLEY TRIBE 2 
A-09-18-32258  ELKO BAND COUNCIL 0 
A-09-18-32259  FORT MCDOWELL YAVAPAI NATION 0 
A-09-18-32260  FORT DEFIANCE INDIAN HOSPITAL BOARD, INC. 0 
A-09-18-32261  HAVASUPAI TRIBE 0 
A-09-18-32262  GILA RIVER INDIAN COMMUNITY 0 
A-09-18-32289  GILA RIVER HEALTH CARE CORP. 1 
A-09-18-32299  SRI INTERNATIONAL 1 
A-09-18-32302  YAVAPAI-PRESCOTT INDIAN TRIBE 2 
A-09-18-32324  ADELANTE HEALTHCARE, INC. 2 
A-09-18-32333  COLUSA INDIAN COMMUNITY COUNCIL OF THE CACHIL DEHE 0 
4/19/2018 8:38:04AM  Page 11 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-09-18-32364  REDDING RANCHERIA  0 
A-09-18-32390  NATIVE AMERICANS FOR COMMUNITY ACTION INC.  0 
A-09-18-32409  INDIAN HEALTH COUNCIL INC.  0 
A-09-18-32410  SONOMA COUNTY INDIAN HEALTH PROJECT INC.  0 
A-09-18-32411  FALLON PAIUTE-SHOSHONE TRIBE  0 
A-09-18-32429  TRANSLATIONAL GENOMICS RESEARCH INSTITUTE & AFFILI  1 
A-09-18-32461  QUECHAN INDIAN TRIBE  6 
A-09-18-32484  SONOMOTION INC.  1 
A-09-18-32516  SCINTILLON INSTITUTE  1 
A-09-18-32528  INTRINSIC LIFESCIENCES LLC  2 
A-09-18-32543  INVENIO IMAGING INC.  2 
A-09-18-32551  SHERWOOD VALLEY BAND OF POMO INDIANS  0 
A-09-18-32552  RENO-SPARKS INDIAN COLONY  0 
A-09-18-32555  AK-CHIN INDIAN COMMUNITY  0 
A-09-18-32557  SANTA YNEZ TRIBAL HEALTH CLINIC OF THE SANTA YNEZ  1 
A-09-18-32570  OSEL, INC. & SUBSIDIARY  0 
A-09-18-32587  PROGNOSYS BIOSCIENCES, INC.  3 
A-09-18-32594  SIGRAY INC.  4 
A-09-18-32614  RIVERSIDE-SAN BERNARDINO COUNTY INDIAN HEALTH INC.  0 
A-09-18-32642  EYENUK, INC.  3 
A-09-18-32656  PYRAMID LAKE PAIUTE TRIBE  4 
A-09-18-32658  TONTO-APACHE TRIBE  5 
A-09-18-32663  TUOLUMNE BAND OF ME-WUK INDIANS  4 
A-09-18-32669  QUARTZ VALLEY INDIAN RESERVATION  2 
A-09-18-32687  PALA BAND OF MISSION INDIANS  0 
A-09-18-32688  ROUND VALLEY INDIAN TRIBES OF THE ROUND VALLEY RES  2 
A-09-18-32693  WALKER RIVER PAIUTE TRIBE  2 
A-09-18-32694  COCOPAH INDIAN TRIBE  1 
A-09-18-32702  SCOTTS VALLEY BAND OF POMO INDIANS  7 
A-09-18-32712  ELY SHOSHONE TRIBE  0 
A-09-18-32713  PAXVAX GLOBAL, INC.  1 
A-09-18-32735  BARTZ-ALTADONNA COMMUNITY HEALTH CENTER  2 
A-09-18-32749  WINTERS HEALTHCARE FOUNDATION, INC.  1 
A-09-18-32751  BIOMEDICAL RESEARCH INSTITUTE OF SOUTHER CALIFORNI  1 
A-09-18-32756  AMERICAN COLLEGE OF MEDICAL TOXICOLOGY, INC. & IT'  1 
A-09-18-32765  SAN DIEGO STATE UNIV. RESEARCH FOUNDATION  0 
A-09-18-32766  KAISER FOUNDATION HEALTH PLAN INC. & SUBSIDIARIES  0 
A-09-18-32775  CALIFORNIA RURAL INDIAN HEALTH BOARD, INC.  0 
A-09-18-32795  CENTRAL CITY COMMUNITY HEALTH CENTER  3 
A-09-18-32809  IIPAY NATION OF SANTA YSABEL  0 
A-09-18-32810  HOPLAND BAND OF POMO INDIANS  0 
A-09-18-32811  ELY SHOSHONE TRIBE  1 
A-09-18-32812  COYOTE VALLEY BAND OF POMO INDIANS  0 
A-09-18-32815  SUSANVILLE INDIAN RANCHERIA  1 
A-09-18-32827  WASHOE TRIBE OF NEVADA & CALIFORNIA  1 
A-09-18-32828  CHEMEHUEVI INDIAN TRIBE  0 
A-09-18-32829  YAVAPAI-APACHE NATION  1 
A-09-18-32830  HUALAPAI NATION  0 
A-09-18-32842  SHINGLE SPRINGS BAND OF MIWOK INDIANS  0 
A-09-18-32843  GREENVILLE RANCHERIA  0 
A-09-18-32844  PINOLEVILLE POMO NATION  0 
A-09-18-32852  SORRENTO THERAPEUTICS, INC. & SUBSIDIARY  4 
A-09-18-32855  SAN DIEGO AMERICAN INDIAN HEALTH CENTER  0 
A-09-18-32872  UNIV. OF SAN DIEGO  0 
A-09-18-32873  BUCK INSTITUTE FOR AGE RESEARCH  1 
A-09-18-32877  AMERICAN INDIAN HEALTH & SERVICES  5 
A-09-18-32897  HORIZON HEALTH & WELLNESS, INC.  2 
A-09-18-32926  EPIGEN BIOSCIENCES, INC.  1 
4/19/2018 8:38:04AM  Page 12 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-09-18-32928  WHITTIER COLLEGE  1 
A-09-18-32929  DAVIS STREET COMMUNITY CENTER INC.  2 
A-09-18-32933  CITY OF HENDERSON, NEVADA  0 
A-09-18-32934  NEVADA SYSTEM OF HIGHER EDUCATION  0 
A-09-18-32953  CHARLES DREW UNIV. OF MEDICINE & SCIENCE  0 
A-09-18-32982  SANFORD BURNHAM PREBYS MEDICAL DISCOVERY INSTITUTE  0 
A-09-18-32991  DOMINICAN UNIV. OF CALIFORNIA  2 
A-09-18-32993  WASHOE COUNTY, NEVADA  0 
A-09-18-33011  SANTA BARBARA NEIGHBORHOOD CLINICS  1 
A-09-18-33021  CIRCLE THE CITY & SUBSIDIARIES  1 
A-09-18-33044  COMMUNITY MEDICAL CENTERS, INC.  4 
A-09-18-33062  CITY OF HOPE & AFFILIATES  0 
A-09-18-33063  CEDARS-SINAI MEDICAL CENTER  0 
A-09-18-33080  PIT RIVER HEALTH SERVICE INC.  0 
A-09-18-33103  COUNTY OF SAN LUIS OBISPO CALIFORNIA  0 
A-09-18-33109  SIERRA COUNTY CALIFORNIA  0 
A-09-18-33120  PACIFIC ISLANDS PRIMARY CARE ASSOCIATION  1 
A-09-18-33133  MISSION CITY COMMUNITY NETWORK, INC.  1 
A-09-18-33136  SOUTHERN NEVADA HEALTH DISTRICT  2 
A-09-18-33159  HOPI TRIBE  13 
A-09-18-33161  WHITE MOUNTAIN APACHE TRIBE  18 
A-09-18-33182  VOLUNTEERS OF AMERICA OF LOS ANGELES  0 
A-09-18-33184  SANTA CRUZ COUNTY  0 
A-09-18-33185  BUTTE COUNTY CALIFORNIA  3 
A-09-18-33204  SCRIPPS RESEARCH INSTITUTE  0 
A-09-18-33228  LAS VEGAS PAIUTE TRIBE  4 
A-09-18-33265  LAKE COUNTY TRIBAL HEALTH CONSORTIUM INC.  0 
A-09-18-33285  ALAMEDA COUNTY CALIFORNIA  0 
A-09-18-33286  SAN FRANCISCO UNIFIED SCHOOL DISTRICT  0 
A-10-18-31684  LA PINE COMMUNITY HEALTH CENTER  2 
A-10-18-32001  ALASKA ISLAND COMMUNITY SERVICES  1 
A-10-18-32150  SPRINGSTAR, INC.  4 
A-10-18-32248  JAMESTOWN S' KLALLAM TRIBE OF INDIANS  0 
A-10-18-32255  SPOKANE TRIBE OF INDIANS  0 
A-10-18-32256  CONFEDERATED TRIBES & BANDS OF THE YAKAMA NATION  0 
A-10-18-32257  CONFEDERATED TRIBES OF THE COLVILLE RESERVATION  0 
A-10-18-32265  NEZ PERCE TRIBE  2 
A-10-18-32321  WATERFALL CLINIC, INC.  5 
A-10-18-32322  INSTITUTE FOR SYSTEMS BIOLOGY  3 
A-10-18-32323  HARBORVIEW MEDICAL CENTER  1 
A-10-18-32360  CONFEDERATED TRIBES OF THE UMATILLA INDIAN RESERVA  0 
A-10-18-32379  COQUILLE INDIAN TRIBE  0 
A-10-18-32426  OREGON PRIMARY CARE ASSOCIATION  1 
A-10-18-32479  CONFEDERATED TRIBES OF THE GRAND RONDE COMMUNITY O  0 
A-10-18-32480  YAKUTAT TLINGIT TRIBE  0 
A-10-18-32481  UPPER SKAGIT INDIAN TRIBE  0 
A-10-18-32498  MOSES LAKE COMMUNITY HEALTH CENTER & SUBSIDIARY  2 
A-10-18-32533  RINEHART CLINIC  4 
A-10-18-32549  CONFEDERATED TRIBES OF SILETZ INDIANS OF OREGON  0 
A-10-18-32553  SWINOMISH INDIAN TRIBAL COMMUNITY  0 
A-10-18-32605  PAI LIFE SCIENCES, INC.  3 
A-10-18-32632  NOVUSON SURGICAL, INC.  2 
A-10-18-32650  KING COUNTY WASHINGTON  1 
A-10-18-32651  COWLITZ INDIAN TRIBE  1 
A-10-18-32653  TULALIP TRIBES OF WASHINGTON  0 
A-10-18-32680  SAGE BIONETWORKS  1 
A-10-18-32690  NOOKSACK INDIAN TRIBE  1 
A-10-18-32691  SAUK-SUIATTLE INDIAN TRIBE  3 
4/19/2018 8:38:04AM  Page 13 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HEALTH FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-10-18-32692  CONFEDERATED TRIBES OF THE CHEHALIS RESERVATION  1 
A-10-18-32698  PROVIDENCE ST. JOSEPH HEALTH  2 
A-10-18-32767  PIERCE COUNTY WASHINGTON  0 
A-10-18-32784  COAST COMMUNITY HEALTH CENTER  1 
A-10-18-32817  CONFEDERATED TRIBES OF COOS LOWER UMPQUA & SIUSLAW  0 
A-10-18-32818  CONFEDERATED TRIBES OF THE WARM SPRINGS RESERVATIO  0 
A-10-18-32819  KETCHIKAN INDIAN CORP.  1 
A-10-18-32820  LUMMI INDIAN BUSINESS COUNCIL  0 
A-10-18-32821  PORT GAMBLE S'KLALLAM TRIBE  0 
A-10-18-32822  NISQUALLY INDIAN TRIBE  1 
A-10-18-32823  MUCKLESHOOT INDIAN TRIBE  0 
A-10-18-32824  MAKAH TRIBAL COUNCIL  0 
A-10-18-32862  ANCHORAGE NEIGHBORHOOD HEALTH CENTER INC.  1 
A-10-18-32876  BOISE STATE UNIV.  1 
A-10-18-32908  OREGON HEALTH & SCIENCE UNIV.  0 
A-10-18-32930  WATERFALL CLINIC, INC.  6 
A-10-18-32931  CROSS ROAD HEALTH MINISTRIES INC.  3 
A-10-18-32972  NATIVE VILLAGE OF TYONEK  3 
A-10-18-32985  FRED HUTCHINSON CANCER RESEARCH CENTER  0 
A-10-18-32992  ASSOCIATION OF VILLAGE COUNCIL PRESIDENTS  18 
A-10-18-33030  SEDIA BIOSCIENCES CORP.  1 
A-10-18-33045  DECISION SCIENCE RESEARCH INSTITUTE INC. DBA DECIS  1 
A-10-18-33084  BENTON COUNTY  2 
A-10-18-33135  SEATTLE CHILDREN'S HOSPITAL  1 
A-10-18-33146  ALTIUS INSTITUTE FOR BIOMEDICAL SCIENCES  6 
A-10-18-33163  BOISE STATE UNIV.  2 
A-10-18-33177  SOUTHEAST ALASKA REGIONAL HEALTH CONSORTIUM  0 
A-10-18-33246  YUKON-KUSKOKWIM HEALTH CORP.  1 
A-10-18-33267  EASTERN ALEUTIAN TRIBES INC.  1 
A-10-18-33268  NATIVE VILLAGE OF EKLUTNA  0 
A-10-18-33270  BRISTOL BAY AREA HEALTH CORP.  2 
A-10-18-33271  NORTON SOUND HEALTH CORP.  0 
A-10-18-33272  MANIILAQ ASSOCIATION  1 
A-10-18-33273  FAIRBANKS NATIVE ASSOCIATION  0 
A-10-18-33274  SHOALWATER BAY INDIAN TRIBE  0 
A-10-18-33288  MULTNOMAH COUNTY OREGON  0 
A-17-17-02016  FY 2017 CFO Financial Statement Audit of CMS  0 
A-18-16-30810  IT Audit - SAMHSA Penetration Test  8 
A-18-17-11200  Review of the DHHS' Compliance with the FISMA of 2014 for FY  6 
2017 
A-18-17-11300  Review of Medicare Administrative Contractor Information Security  0 
Program Evaluations for FY 2016 
Totals :  $640,005,268  $20,007,447  $156,476,096 
4/19/2018 8:38:04AM  Page 14 of 14  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HUMAN DEVELOPMENT FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-01-16-02500  MA Foster Care Health and Safety - Group Home Inspections 4 
A-01-18-32312  SELF HELP, INC. 0 
A-01-18-32359  AREA COOPERATIVE EDUCATIONAL SERVICES 5 
A-01-18-32905  ANDROSCOGGIN HEAD START & CHILD CARE 1 
A-01-18-32970  FRANKLIN COUNTY DIAL SELF INC. 1 
A-01-18-32989  COMMUNITY DAY CARE CENTER OF LAWRENCE INC. 0 
A-01-18-32990  COMMUNITY TEAMWORK, INC. 0 
A-01-18-33132  CONNECTICUT COALITION AGAINST DOMESTIC VIOLENCE IN 0 
A-02-15-02014  New York Did Not Always Comply with State Requirements for  1 
Recording and Investigating Allegations of Abuse and Neglect for 
Title IV-E Foster Care Children 
A-02-16-02009  The Administration for Children and Families Region II Did Not  4 
Always Resolve Head Start Grantees Single Audit Findings in 
Accordance With Federal Requirements 
A-02-18-31869  CHILD CENTER OF NEW YORK, INC. 1 
A-02-18-32019  PUERTO RICO DEPT. OF THE FAMILY 19 
A-02-18-32101  QUALITY CARE RESOURCE & REFERRAL SERIVCES, INC. 1 
A-02-18-32366  MDRC 0 
A-02-18-32388  JOINT COUNCIL FOR ECONOMIC OPPORTUNITY OF CLINTON 1 
A-02-18-32392  COMMUNITY ACTION OF ORLEANS & GENESEE, INC. 0 
A-02-18-32440  LEWIS COUNTY HEAD START INC. 1 
A-02-18-32473  MONMOUTH COUNTY NEW JERSEY 0 
A-02-18-32741  OCEAN COMMUNITY ECONOMIC ACTION NOW INC. 7 
A-02-18-32806  SULLIVAN COUNTY HEAD START INC. 1 
A-02-18-32948  BURLINGTON COUNTY COMMUNITY ACTION PROGRAM 2 
A-02-18-32949  REGIONAL ECONOMIC COMMUNITY ACTION PROGRAM INC. 1 
A-02-18-33121  COMMUNITY ACTION ORGANIZATION OF ERIE COUNTY INC. 1 
A-03-18-31917  NATIONAL DISABILITY RIGHTS NETWORK, INC. 1 
A-03-18-32220  NORTHERN TIER COMMUNITY ACTION CORP. 2 
A-03-18-32327  RESNA 2 
A-03-18-32373  INDEPENDENCE NOW, INC. 1 
A-03-18-32380  SCHOOL DISTRICT OF PITTSBURGH PENNSYLVANIA 0 
A-03-18-32459  KIDSPEACE CORP. & SUBSIDIARIES 1 
A-03-18-32506  POLARIS PROJECT, INC. 1 
A-03-18-32671  TRANSCEN INC. 5 
A-03-18-32672  COMMUNITY ACTION PARTNERSHIP 3 
A-03-18-32676  MILE HIGH KIDS & COMMUNITY DEVELOPMENT, INC. 1 
A-03-18-32884  MONTICELLO AREA COMMUNITY ACTION AGENCY INC. 2 
A-03-18-32941  CENTER FOR URBAN FAMILIES INC. 2 
A-03-18-33007  FAMILY & COMMUNITY CHRISTIAN ASSOCIATION 4 
A-03-18-33055  TABLELAND SERVICES INC. 1 
A-03-18-33088  KANAWHA INSTITUTE FOR SOCIAL RESEARCH & ACTION INC 2 
A-03-18-33165  STEPS, INC 1 
A-04-16-03566  Unaccompanied Alien Children Program Grantee Review - His House  6 
Children's Home 
A-04-18-31796  FAMILY SERVICES INC. 1 
A-04-18-31897  FIVE COUNTY CHILD DEVELOPMENT PROGRAM INC. 3 
A-04-18-31898  PARTNERSHIP FOR COMMUNITY ACTION, INC. 1 
A-04-18-31899  COMMUNITY ACTION FOR IMPROVEMENT, INC. 6 
A-04-18-32016  MOBILE COMMUNITY ACTION, INC. 6 
A-04-18-32029  SALISBURY-ROWAN COMMUNITY ACTION AGENCY, INC. 0 
A-04-18-32049  COASTAL COMMUNITY ACTION INC. 1 
A-04-18-32050  LUMBEE REGIONAL DEVELOPMENT ASSOCIATION, INC. 4 
A-04-18-32204  KCEOC COMMUNITY ACTION PARTNERSHIP, INC. & AFFILIA 1 
A-04-18-32221  BEAUFORT-JASPER ECONOMIC OPPORTUNITY COMMISSION, I 0 
A-04-18-32310  ORGANIZED COMMUNITY ACTION PROGRAM INC. 0 
A-04-18-32372  SALISBURY-ROWAN COMMUNITY ACTION AGENCY, INC. 4 
A-04-18-32502  WATEREE COMMUNITY ACTIONS, INC. 7 
A-04-18-32704  MOBILE COMMUNITY ACTION, INC. 5 
4/19/2018 8:39:16AM  Page 1 of 4  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HUMAN DEVELOPMENT FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-04-18-32799  WATEREE COMMUNITY ACTIONS, INC. 6 
A-04-18-32863  CENTRAL MISSISSIPPI INC. 3 
A-04-18-32902  CATHOLIC SOCIAL SERVICES OF THE GREATER MOBILE ARE 2 
A-04-18-32937  MONTGOMERY COMMUNITY ACTION COMMITTEE & CDC, INC. 1 
A-04-18-32975  BREVARD COUNTY DISTRICT SCHOOL BOARD FLORIDA 0 
A-04-18-33067  DISTRICT SCHOOL BOARD OF COLLIER COUNTY 0 
A-04-18-33087  GREENE LAMP INC. 1 
A-04-18-33114  COMMUNITY ACTION OPPORTUNITIES 2 
A-04-18-33188  EARLY LEARNING COALITION OF MIAMI-DADE/MONROE, INC 0 
A-04-18-33192  ECKERD YOUTH ALTERNATIVES INC. DBA ECKERD CONNECT 0 
A-05-18-31860  METROPOLITAN CHILDREN & YOUTH, INC. UNITED 1 
A-05-18-31915  BLUE WATER COMMUNITY ACTION 0 
A-05-18-32031  WEST CENTRAL ILLINOIS AREA AGENCY ON AGING 4 
A-05-18-32122  MAHUBE-OTWA COMMUNITY ACTION PARTNERSHIP, INC. 2 
A-05-18-32234  DUBOIS-PIKE-WARRICK ECONOMIC OPPORTUNITY COMMITTEE 0 
A-05-18-32391  KNO-HO-CO-ASHLAND COMMUNITY ACTION COMMISSION & SU 0 
A-05-18-32435  LAKES & PRAIRIES COMMUNITY ACTION PARTNERSHIP INC. 3 
A-05-18-32468  MATRIX HUMAN SERVICES 9 
A-05-18-32504  CHILD CARE CONSORTIUM, INC. 11 
A-05-18-32518  HEARTLAND HEAD START INC. 5 
A-05-18-32579  NORTHWESTERN ILLINOIS COMMUNITY ACTION AGENCY INC. 2 
A-05-18-32733  COMMUNITY ACTION PARTNERSHIP OF LAKE COUNTY 1 
A-05-18-32773  MACOMB COUNTY MICHIGAN 2 
A-05-18-32804  COUNCIL FOR ECONOMIC OPPORTUNITIES IN GREATER CLEV 1 
A-05-18-32904  TWO RIVERS REGIONAL COUNCIL OF PUBLIC OFFICIALS 1 
A-05-18-33005  ECONOMIC & COMMUNITY DEVELOPMENT INSTITUTE 3 
A-05-18-33148  BATTERED WOMENS JUSTICE PROJECT 2 
A-05-18-33153  OUNCE OF PREVENTION FUND ILLINOIS 1 
A-05-18-33154  FREMONT COMMUNITY SCHOOLS 3 
A-05-18-33212  ROCK ISLAND-MILAN SCHOOL DISTRICT NO. 41 0 
A-06-16-00013  Pine Bluff Jefferson County Economic Opportunities Commission Did  $279,543 11 
Not Always Operate Its Head Start Program In Accordance With 
Federal Requirements 
A-06-16-00015  Southeast Arkansas Community Action Corporation Did Not Always  $4,784  8 
Operate Its Head Start Program In Accordance With Federal 
Regulations 
A-06-16-07006  Oklahoma Did Not Always Comply With Requirements for Providing   1 
Health Care Services to Children in Foster Care 
A-06-16-07007  BCFS Health and Human Services Did Not Always Comply with  $658,248 0 
Federal Requirements Related to Less-Than-Arm's Length Leases 
A-06-17-07003  The Administration for Children and Families Did Not Always Resolve  4 
American Indian and Alaska Native Head Start Grantees' Single 
Audit Findings in Accordance with Federal Requirements. 
A-06-18-31905  ST. JAMES PARISH SCHOOL BOARD 2 
A-06-18-32013  ARKANSAS EARLY LEARNING, INC. 2 
A-06-18-32094  NATIONAL DOMESTIC VIOLENCE HOTLINE 3 
A-06-18-32171  CHILDCAREGROUP 1 
A-06-18-32303  COMMUNITY ACTION PROGRAM FOR CENTRAL ARKANSAS INC. 4 
A-06-18-32367  DELTA COMMUNITY ACTION FOUNDATION INC. 0 
A-06-18-32430  OUACHITA MULTI-PURPOSE COMMUNITY ACTION PROGRAM IN 3 
A-06-18-32431  SOUTHEAST ARKANSAS COMMUNITY ACTION CORP. 2 
A-06-18-32453  MOREHOUSE COMMUNITY IMPROVEMENT ORGANIZATION INC. 2 
A-06-18-32462  WILLIAMSON-BURNET COUNTY OPPORTUNITIES, INC. 4 
A-06-18-32463  CENTRAL TRIBES OF THE SHAWNEE AREA INC. 4 
A-06-18-32472  HIDALGO COUNTY 0 
A-06-18-32501  CHILDREN'S CENTER, INC. 10 
A-06-18-32519  AMBASSADORS FOR CHRIST YOUTH MINISTRIES 0 
A-06-18-32526  WEBSTER PARISH OFFICE OF COMMUNITY SERVICES 1 
A-06-18-32558  CHILD CARE ASSOCIATES 0 
A-06-18-32666  SCURRY COMMUNITY SERVICES INC. 4 
4/19/2018 8:39:16AM  Page 2 of 4  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HUMAN DEVELOPMENT FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-06-18-32682  CENTER FOR NEW COMMUNITIES 1 
A-06-18-32757  GALVESTON COUNTY COMMUNITY ACTION COUNCIL INC. 4 
A-06-18-32792  AMBASSADORS FOR CHRIST YOUTH MINISTRIES 1 
A-06-18-32857  TEXAS MIGRANT COUNCIL D/B/A TMC-TEACHING & MENTORI 1 
A-06-18-32900  BRAZORIA COUNTY HEAD START EARLY LEARNING SCHOOLS, 1 
A-06-18-32917  SHILOH TREATMENT CENTER, INC. 0 
A-06-18-32958  CHILD INC. 3 
A-06-18-33048  NORTHEAST OKLAHOMA COMMUNITY ACTION AGENCY, INC. & 2 
A-06-18-33049  COMMUNITY ACTION PROGRAM FOR CENTRAL ARKANSAS INC. 3 
A-06-18-33065  BCFS HEALTH & HUMAN SERVICES 0 
A-06-18-33111  AVANCE, INC. 2 
A-06-18-33164  WEST FELICIANA PARISH SCHOOL BOARD 2 
A-06-18-33186  SOUTHWEST KEY PROGRAMS, INC. & AFFILIATES 0 
A-07-15-04226  Not All of Missouri's Child Care Subsidy Program Payments Complied  $19,076,167 2 
with Federal and State Requirements 
A-07-18-31882  OZARKS AREA COMMUNITY ACTION CORP. 0 
A-07-18-31885  SALVATION ARMY OMAHA AREA 0 
A-07-18-31891  WEST CENTRAL MISSOURI COMMUNITY ACTION AGENCY 2 
A-07-18-32100  CONNECTIONS TO SUCCESS 7 
A-07-18-32223  YOUTH IN NEED 0 
A-07-18-32730  CONNECTIONS TO SUCCESS 7 
A-07-18-32886  CENTRAL COMMUNITY COLLEGE AREA 2 
A-07-18-32983  DOUGLAS COUNTY SCHOOL DISTRICT #0001 0 
A-07-18-33147  CENTRAL NEBRASKA COMMUNITY SERVICES, INC. 1 
A-08-18-32439  CENTER FOR CHILDREN & FAMILIES, INC. 4 
A-08-18-32515  ANACONDA - DEER LODGE COUNTY 3 
A-08-18-32763  NORTHWEST MONTANA HEAD START INC. 1 
A-08-18-32786  RED CLOUD INDIAN SCHOOL, INC. 1 
A-08-18-32887  LUTHERAN SOCIAL SERVICES OF SOUTH DAKOTA, INC. & C 5 
A-08-18-32961  BISMARCK PUBLIC SCHOOL DISTRICT NO. 1 2 
A-08-18-32994  SALT LAKE COMMUNITY ACTION PROGRAM 5 
A-08-18-33054  FIRST NATIONS DEVELOPMENT INSTITUTE & SUBSIDIARY 1 
A-08-18-33157  CENTRO DE LA FAMILIA DE UTAH 2 
A-09-16-01004  The Administration for Children and Families Region X Did Not  1 
Always Resolve Head Start Grantees' Single Audit Findings in 
Accordance With Federal Requirements 
A-09-16-01006  Some Washington State Group-Care Facilities for Children in Foster  7 
Care Did Not Always Comply With State Health and Safety 
Requirements 
A-09-18-31757  SAN DIEGO WORKFORCE PARTNERSHIP, INC. 1 
A-09-18-32028  CHILD START, INC. 3 
A-09-18-32424  KEIKI O KA 'AINA PRESCHOOL, INC. 1 
A-09-18-32874  INTER-TRIBAL COUNCIL OF CALIFORNIA, INC. 13 
A-09-18-32907  COMMUNITY ACTION PARTNERSHIP OF KERN 0 
A-09-18-32957  ABILITY360 & SUBSIDIARY 3 
A-09-18-32973  LONG BEACH UNIFIED SCHOOL DISTRICT 0 
A-09-18-32974  NEIGHBORHOOD HOUSE ASSOCIATION 0 
A-09-18-33059  LOS ANGELES COUNTY OFFICE OF EDUCATION 0 
A-09-18-33060  CRYSTAL STAIRS INC. 0 
A-09-18-33061  CHILD CARE RESOURCE CENTER, INC. 0 
A-09-18-33064  SACRAMENTO EMPLOYMENT & TRAINING AGENCY 0 
A-09-18-33160  ARIZONA'S CHILDREN ASSOCIATION & ARIZONA'S CHILDRE 1 
A-09-18-33183  STANISLAUS COUNTY OFFICE OF EDUCATION 0 
A-09-18-33203  RIVERSIDE COUNTY OFFICE OF EDUCATION 0 
A-10-18-32091  FAMILY SERVICES OF GRANT COUNTY 1 
A-10-18-32194  ORGANIZED VILLAGE OF KWETHLUK KWETHLUK IRA COUNCIL 2 
A-10-18-32455  MID-COLUMBIA CHILDREN'S COUNCIL INC. 1 
A-10-18-32469  COOK INLET NATIVE HEAD START 1 
A-10-18-32652  OKANOGAN COUNTY CHILD DEVELOPMENT ASSOCIATION 2 
4/19/2018 8:39:16AM  Page 3 of 4  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
HUMAN DEVELOPMENT FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-10-18-32654  DIOCESE OF OLYMPIA 1 
A-10-18-32689  KIDS & COMPANY OF LINN COUNTY 4 
A-10-18-32755  BRIGHT BEGINNINGS FOR KITTITAS COUNTY 2 
A-10-18-32954  ROGUE COMMUNITY COLLEGE DISTRICT 1 
A-10-18-33227  NEIGHBORHOOD ECONOMIC DEVELOPMENT CORP. & SUBSIDIA 1 
Totals :  $20,018,742  $0  $0 
4/19/2018 8:39:16AM  Page 4 of 4  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
GENERAL GOVERNMENT FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-03-18-00351  Independent Attestation Review: Indian Health Service Fiscal Year   0 
2017 Detailed Accounting Submission and Performance Summary 
Report for National Drug Control Activities and Accompanying 
Required Assertions 
A-03-18-32802  NATIVE AMERICAN LIFELINES INC. 4 
A-03-18-33205  ALLEGHENY VALLEY SCHOOL 0 
A-04-18-32800  EDGECOMBE COUNTY NORTH CAROLINA 0 
A-04-18-32910  UNION COUNTY 0 
A-04-18-32911  DURHAM COUNTY NORTH CAROLINA 0 
A-04-18-32976  SOUTH FLORIDA BEHAVIORAL HEALTH NETWORK INC. 0 
A-04-18-32977  FLORIDA HEALTHY KIDS CORP. 0 
A-04-18-33069  HAYWOOD COUNTY 0 
A-04-18-33070  RUTHERFORD COUNTY NORTH CAROLINA 0 
A-04-18-33072  BUNCOMBE COUNTY NORTH CAROLINA 0 
A-04-18-33073  ALAMANCE COUNTY NORTH CAROLINA 0 
A-04-18-33107  JONES COUNTY NORTH CAROLINA 0 
A-04-18-33115  TRANSYLVANIA COUNTY NORTH CAROLINA 0 
A-04-18-33187  CHILDNET, INC. & AFFILIATE 0 
A-04-18-33197  SURRY COUNTY NORTH CAROLINA 0 
A-04-18-33198  SAMPSON COUNTY NORTH CAROLINA 0 
A-04-18-33199  JOHNSTON COUNTY NORTH CAROLINA 0 
A-04-18-33200  BLADEN COUNTY NORTH CAROLINA 0 
A-04-18-33201  CHILD CARE RESOURCES INC. NORTH CAROLINA 0 
A-05-17-32033  SUSTAINABLE RESOURCES CENTER INC. & SUBSIDIARY 0 
A-05-18-33102  HUBBARD COUNTY 0 
A-06-18-32284  KEWA PUEBLO HEALTH CORP. 0 
A-06-18-32556  JENA BAND OF CHOCTAW INDIANS 0 
A-06-18-33066  JEFFERSON PARISH PUBLIC SCHOOL SYSTEM 0 
A-06-18-33179  NORTHEASTERN TRIBAL HEALTH SYSTEM 0 
A-08-18-32507  CONFEDERATED TRIBES OF THE GOSHUTE RESERVATION 0 
A-08-18-32508  CONFEDERATED TRIBES OF THE GOSHUTE RESERVATION 0 
A-08-18-32509  CONFEDERATED TRIBES OF THE GOSHUTE RESERVATION 0 
A-08-18-32727  BLACK HILLS CENTER FOR AMERICAN INDIAN HEALTH 2 
A-08-18-32935  URBAN INDIAN CENTER OF SALT LAKE 3 
A-09-18-31925  SAN JOAQUIN COUNTY CALIFORNIA 0 
A-09-18-32109  WINSLOW INDIAN HEALTH CARE CENTER INC. 1 
A-09-18-32286  LOVELOCK PAIUTE TRIBE 0 
A-09-18-32331  SIERRA TRIBAL CONSORTIUM INC. 0 
A-09-18-32334  BAKERSFIELD AMERICAN INDIAN HEALTH PROJECT INC. 0 
A-09-18-32335  SYCUAN BAND OF THE KUMEYAAY NATION 0 
A-09-18-32378  STRONG FAMILY HEALTH CENTER 0 
A-09-18-32403  NEVADA URBAN INDIANS INC. 1 
A-09-18-32414  GUIDIVILLE BAND OF POMO INDIANS 0 
A-09-18-32427  YOMBA SHOSHONE TRIBE 6 
A-09-18-32460  APACHE BEHAVIORAL HEALTH SERVICES, INC. 1 
A-09-18-32477  CONSOLIDATED TRIBAL HEALTH PROJECT INC. 0 
A-09-18-32478  NORTHERN VALLEY INDIAN HEALTH INC. 0 
A-09-18-32554  KAIBAB BAND OF PAIUTE INDIANS 0 
A-09-18-32655  YOMBA SHOSHONE TRIBE 4 
A-09-18-32813  KASHIA BAND OF POMO INDIANS OF THE STEWARTS POINT 0 
A-09-18-32814  MARIPOSA, AMADOR, CALAVERAS, TUOLUMNE HEALTH BOARD 0 
A-09-18-32825  FORT MCDERMITT PAIUTE-SHOSHONE TRIBE 0 
A-09-18-32826  DUCKWATER SHOSHONE TRIBE 3 
A-09-18-32838  TABLE MOUNTAIN RANCHERIA 0 
A-09-18-32849  WILTON RANCHERIA 3 
A-09-18-33176  CABAZON BAND OF MISSION INDIANS 0 
A-09-18-33180  FEATHER RIVER TRIBAL HEALTH INC. 0 
A-09-18-33266  CHAPA-DE INDIAN HEALTH PROGRAM INC. 0 
A-09-18-33284  SAN BERNARDINO COUNTY SUPERINTENDENT OF SCHOOLS 0 
4/19/2018 8:40:16AM  Page 1 of 2  OFFICE OF AUDIT SERVICES 
FINAL AUDIT REPORTS ISSUED FOR SEMIANNUAL PERIOD 
GENERAL GOVERNMENT FROM 10/01/2017 TO 03/31/2018 
Costs  Unsupported  Funds Put To  PM 
CIN  Audit Title  Questioned  Cost  Better Use  Recs 
A-10-18-32361  SAMISH INDIAN NATION  0 
A-10-18-32816  KLAMATH TRIBAL HEALTH & FAMILY SERVICES  0 
A-10-18-32896  BURNS PAIUTE TRIBE  7 
A-10-18-33101  CHITINA TRADITIONAL INDIAN VILLAGE COUNCIL  4 
A-10-18-33269  NATIVE VILLAGE OF KARLUK  1 
A-10-18-33277  KOOTENAI TRIBE OF IDAHO  0 
A-17-17-00001  FY 2017 HHS Consolidated Financial Statement Audit  0 
A-17-17-02018  DATA Act Audit  0 
A-18-16-30540  Two Indian Health Service Hospitals Had System Security and  8 
Physical Controls for Prescription Drug and Opioid Despensing but 
Could Still Improve Controls 
Totals :  $0  $0  $0 
4/19/2018 8:40:16AM  Page 2 of 2  OEI Final Reports Issued 
Issue Date Between 10/01/2017 and 03/31/2018 
Inspection Number  Funding Source  Inspection Title  Report  Issued 
OEI-03-17-00040  Medicare  CMS Ensured Nearly All Part D Drug Records Contained Valid Prescriber Identifiers in  FINALS  10/31/2017 
2016 
*OEI-03-17-00550  Medicare  Comparison of Average Sales Prices and Average Manufacturer Prices: Results for  FINALS  11/14/2017 
Second Quarter 2017 
OEI-03-17-00100  Medicaid  Potential Misclassifications Reported by Drug Manufacturers May Have Led to $1 Billion  FINALS  12/15/2017 
in Lost Medicaid Rebates 
*OEI-03-15-00060  Medicare  Medicare Advantage Encounter Data Show Promise for Program Oversight, But  FINALS  01/11/2018 
Improvements Are Needed 
*OEI-03-18-00150  Medicare  Comparison of Average Sales Prices and Average Manufacturer Prices: Results for the  FINALS  02/15/2018 
Third Quarter of 2017 
*OEI-04-15-00432  Discretionary  Entities Experiences and Perceptions of Reporting the Theft, Loss, and Release of  FINALS  02/27/2018 
Select Agents or Toxins to CDC 
OEI-05-16-00510  Medicare  Reliance on Unverified Patient Lists Creates a Vulnerability in Home Health Surveys  FINALS  03/05/2018 
OEI-05-16-00550  Discretionary  Drug Supply Chain Security: Dispensers Received Most Tracing Information  FINALS  03/26/2018 
*OEI-09-18-00180  Medicaid  Medicaid Fraud Control Units Fiscal Year 2017 Annual Report  FINALS  03/30/2018 
OEI-12-17-00290  Medicare  Review of The Department of Health and Human Services (HHS) Cancellation of  FINALS  10/25/2017 
Marketplace Enrollment Outreach Efforts 
OEI-12-17-00260  Medicare  Excluding Noncovered Versions When Setting Payment for Two Part B Drugs Would  FINALS  11/21/2017 
Have Resulted in Lower Drug Costs for Medicare and its Beneficiaries 
*OEI-12-16-00500  Medicaid  Medicaid Fraud Control Units: Investigation and Prosecution of Fraud and Beneficiary  FINALS  12/06/2017 
Abuse in Medicaid Personal Care Services 
OEI-12-17-00350  Medicare  Followup Review: CMSs Management of the Quality Payment Program  FINALS  12/12/2017 
Total Records Returned:  13 
OEI-12-17-00290  Medicare  Review of The Department of Health and Human Services (HHS) Cancellation of  FINALS  10/25/2017 
Marketplace Enrollment Outreach Efforts 
OEI-03-17-00040  Medicare  CMS Ensured Nearly All Part D Drug Records Contained Valid Prescriber Identifiers in  FINALS  10/31/2017 
2016 
4/30/2018 4:31:32PM  * - No IG Signature  Page 1 of 4  Issue Date Between 10/01/2017 and 03/31/2018 
Inspection Number  Funding Source  Inspection Title  Report  Issued 
*OEI-12-16-00500  Medicaid  Medicaid Fraud Control Units: Investigation and Prosecution of Fraud and Beneficiary  FINALS  12/06/2017 
Abuse in Medicaid Personal Care Services 
OEI-12-17-00350  Medicare  Followup Review: CMSs Management of the Quality Payment Program  FINALS  12/12/2017 
OEI-03-17-00100  Medicaid  Potential Misclassifications Reported by Drug Manufacturers May Have Led to $1 Billion  FINALS  12/15/2017 
in Lost Medicaid Rebates 
*OEI-03-15-00060  Medicare  Medicare Advantage Encounter Data Show Promise for Program Oversight, But  FINALS  01/11/2018 
Improvements Are Needed 
OEI-05-16-00550  Discretionary  Drug Supply Chain Security: Dispensers Received Most Tracing Information  FINALS  03/26/2018 
*OEI-09-18-00180  Medicaid  Medicaid Fraud Control Units Fiscal Year 2017 Annual Report  FINALS  03/30/2018 
*OEI-03-17-00550  Medicare  Comparison of Average Sales Prices and Average Manufacturer Prices: Results for  FINALS  11/14/2017 
Second Quarter 2017 
OEI-12-17-00260  Medicare  Excluding Noncovered Versions When Setting Payment for Two Part B Drugs Would  FINALS  11/21/2017 
Have Resulted in Lower Drug Costs for Medicare and its Beneficiaries 
*OEI-03-18-00150  Medicare  Comparison of Average Sales Prices and Average Manufacturer Prices: Results for the  FINALS  02/15/2018 
Third Quarter of 2017 
*OEI-04-15-00432  Discretionary  Entities Experiences and Perceptions of Reporting the Theft, Loss, and Release of  FINALS  02/27/2018 
Select Agents or Toxins to CDC 
OEI-05-16-00510  Medicare  Reliance on Unverified Patient Lists Creates a Vulnerability in Home Health Surveys  FINALS  03/05/2018 
Total Records Returned: 13 
Philadelphia 
Blue Cover Report 
OEI-03-17-00040  Medicare  CMS Ensured Nearly All Part D Drug Records Contained Valid Prescriber Identifiers in  FINALS  10/31/2017 
2016 
OEI-03-17-00100  Medicaid  Potential Misclassifications Reported by Drug Manufacturers May Have Led to $1 Billion  FINALS  12/15/2017 
in Lost Medicaid Rebates 
*OEI-03-15-00060  Medicare  Medicare Advantage Encounter Data Show Promise for Program Oversight, But  FINALS  01/11/2018 
Improvements Are Needed 
Product Type Records:  3 
4/30/2018 4:31:32PM  * - No IG Signature  Page 2 of 4  Issue Date Between 10/01/2017 and 03/31/2018 
Inspection Number  Funding Source  Inspection Title  Report  Issued 
Philadelphia 
Memo 
*OEI-03-17-00550  Medicare  Comparison of Average Sales Prices and Average Manufacturer Prices: Results for  FINALS  11/14/2017 
Second Quarter 2017 
*OEI-03-18-00150  Medicare  Comparison of Average Sales Prices and Average Manufacturer Prices: Results for the  FINALS  02/15/2018 
Third Quarter of 2017 
Product Type Records:  2 
Regional Records Returned:  5 
Atlanta 
Memo 
*OEI-04-15-00432  Discretionary  Entities Experiences and Perceptions of Reporting the Theft, Loss, and Release of  FINALS  02/27/2018 
Select Agents or Toxins to CDC 
Product Type Records:  1 
Regional Records Returned:  1 
Chicago 
Blue Cover Report 
OEI-05-16-00550  Discretionary  Drug Supply Chain Security: Dispensers Received Most Tracing Information  FINALS  03/26/2018 
Product Type Records:  1 
Other 
OEI-05-16-00510  Medicare  Reliance on Unverified Patient Lists Creates a Vulnerability in Home Health Surveys  FINALS  03/05/2018 
Product Type Records:  1 
Regional Records Returned:  2 
San Francisco 
Blue Cover Report 
4/30/2018 4:31:32PM  * - No IG Signature  Page 3 of 4  Issue Date Between 10/01/2017 and 03/31/2018 
Inspection Number  Funding Source  Inspection Title  Report  Issued 
San Francisco 
*OEI-09-18-00180  Medicaid  Medicaid Fraud Control Units Fiscal Year 2017 Annual Report  FINALS  03/30/2018 
Product Type Records:  1 
Regional Records Returned:  1 
Headquarters 
Blue Cover Report 
OEI-12-17-00290  Medicare  Review of The Department of Health and Human Services (HHS) Cancellation of  FINALS  10/25/2017 
Marketplace Enrollment Outreach Efforts 
*OEI-12-16-00500  Medicaid  Medicaid Fraud Control Units: Investigation and Prosecution of Fraud and Beneficiary  FINALS  12/06/2017 
Abuse in Medicaid Personal Care Services 
OEI-12-17-00350  Medicare  Followup Review: CMSs Management of the Quality Payment Program  FINALS  12/12/2017 
Product Type Records:  3 
Memo 
OEI-12-17-00260  Medicare  Excluding Noncovered Versions When Setting Payment for Two Part B Drugs Would  FINALS  11/21/2017 
Have Resulted in Lower Drug Costs for Medicare and its Beneficiaries 
Product Type Records: 1 
Regional Records Returned:  4 
Total Records Returned:  13 
4/30/2018 4:31:32PM  * - No IG Signature  Page 4 of 4