Department of Health and Human Services 
OFFICE OF 
 
INSPECTOR GENERAL 
 
 
 
 
 
 
 
 
M S
INNESOTA  TATE 
 
 
M F C
EDICAID  RAUD  ONTROL 
 
U   :  2013 O R
NIT    NSITE  EVIEW 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
  Brian P. Ritchie  
Acting Deputy Inspector General 
for Evaluation and Inspections  
 
March 2014  
OEI-06-13-00200   
   
EXECUTIVE SUMMARY  MINNESOTA STATE MEDICAID FRAUD CONTROL UNIT:                            
2013 ONSITE REVIEW 
OEI-06-12-00200  
 
WHY WE DID THIS STUDY  
The Office of Inspector General (OIG) oversees the activities of all Medicaid Fraud Control 
Units (MFCUs or Units).  As part of this oversight, OIG conducts periodic reviews of all Units 
and prepares public reports based on these reviews.  The reviews assess Unit performance in 
accordance with the 12 MFCU performance standards and monitor Unit compliance with Federal 
grant requirements.   
 
HOW WE DID THIS STUDY  
We based our review on an analysis of data from seven sources:  (1) a review of policies, 
procedures and documentation of the Units operations, staffing, and caseload; (2) a review of 
financial documentation; (3) structured interviews with key stakeholders; (4) a survey of Unit 
staff; (5) structured interviews with the Unit Director and supervisors; (6) an onsite review of 
case files; and (7) an onsite review of Unit operations conducted in April 2013.  
 
WHAT WE FOUND  
For fiscal years (FYs) 2010 through 2012, the Minnesota Unit obtained 62 criminal convictions 
and 59 civil settlements, and reported recoveries of over $64 million.  Our review of compliance 
issues found no evidence of significant noncompliance with applicable laws, regulations, or 
policy transmittals.  However, we found that the Units memorandum of understanding (MOU) 
with the State Medicaid agency did not reflect all current processes.  In addition, the Units 
training plan did not include a minimum number of training hours.  We also found that some  
Unit case files lacked documentation of supervisory approval and periodic review.  Finally, the 
Unit stored some case files in a location accessible to non-Unit staff. 
 
WHAT WE RECOMMEND 
We recommend that the Minnesota Unit (1) update its MOU with the State Medicaid agency;  
(2) establish training hour requirements for each professional discipline; (3) include notation of 
supervisory approval and periodic supervisory review in all case files; and (4) secure case files.  
The Unit concurred with all four of our recommendations.   
 
 
 
 
 
 
 
 
 
 
     
   
 
TABLE OF CONTENTS 
Objective..................................................................................................................1 

Background..............................................................................................................1 

Methodology............................................................................................................4 

Findings....................................................................................................................7 

For FYs 2010 through 2012, the Minnesota Unit obtained 62 criminal      
                 
convictions and 59 civil settlements, and reported recoveries of over                                  

$64 million  ...................................................................................................7 

The Units MOU with the State Medicaid agency did not reflect all         
current processes..........................................................................................8 

The Units training plan did not include a minimum number of training 

hours.............................................................................................................8 

Some Unit case files lacked documentation of supervisory reviews 
and approvals ...............................................................................................9 

The Unit stored some case files in a location accessible to non-Unit       

staff ..............................................................................................................9 

Other observation: The Unit helped to pass legislation that strengthens 

background checks for guardians and conservators of Medicaid 

beneficiaries ...............................................................................................10 

Other observation: The Unit does not issue mobile phones to its  

investigators ...............................................................................................10 

Conclusion and Recommendations ........................................................................11 
 
Unit Comments and Office of Inspector General Response ......................12 

Appendixes ............................................................................................................13 

A: 	1994 Performance Standards ...............................................................13 

B: 	2012 Performance Standards................................................................17 

C: 	Point Estimates and Confidence Intervals Based on  

Review of Case Files ...........................................................................24 

D: Unit Comments ....................................................................................25 

Acknowledgments..................................................................................................27
 
     
   
OBJECTIVE 
To conduct an onsite review of the Minnesota State Medicaid Fraud 
Control Unit (MFCU or Unit). 
BACKGROUND 
The mission of State MFCUs, as established by Federal statute, is to 
investigate fraud and patient abuse and neglect by Medicaid providers and 
to prosecute it under State law.1  Pursuant to Title XIX of the Social 
Security Act (SSA), each State must maintain a certified Unit unless the 
Secretary of Health and Human Services determines that operation of a 
Unit would not be cost-effective because (1) minimal Medicaid fraud 
exists in that State and (2) the State has other, adequate safeguards to 
protect Medicaid beneficiaries from abuse and neglect.2 Currently, 
49 States and the District of Columbia (States) have created such Units.3   
In Federal fiscal year (FY) 2012, combined Federal and State grant 
expenditures for the Units totaled $217.4 million.4      
To carry out its duties and responsibilities in an effective and efficient 
manner, each Unit must employ an interdisciplinary staff that consists of 
at least an investigator, an auditor, and an attorney.5 Unit staff review 
complaints provided by the State Medicaid agency and other sources and 
determine their potential for criminal prosecution and/or civil action.  In 
FY 2012, the 50 Units collectively reported 1,337 convictions, 823 civil 
settlements or judgments, and recoveries of approximately $2.9 billion.6, 7   
Units are required to have either Statewide authority to prosecute cases or 
formal procedures to refer suspected criminal violations to an office with 
 
1 Social Security Act (SSA)  1903(q)(3). 
 
2 Ibid.,  1902(a)(61) and  1903(q)(3).  Regulations at 42  CFR   1007.11(b)(1) add that 

the Units responsibilities may include reviewing complaints of misappropriation  of  

patients private funds in  residential health care facilities. 

3 Office of Inspector General (OIG) Medicaid Fraud Control Units.   Accessed at 

http://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/index.asp on May 22, 2013. 

4 OIG,  State Medicaid Fraud Control Units  Fiscal Year 2012 Grant Expenditures and 

Statistics. Accessed at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2012-statistical-chart.htm on March  8, 2013. 

5 SSA  1903(q)(6) and  42 CFR   1007.13.  

6 OIG,  State Medicaid Fraud Control Units  Fiscal Year 2012 Grant Expenditures and 

Statistics. Accessed at http://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/ on  
April 16, 2012. 
7 Ibid. Recoveries are defined as the amount  of money that defendants are required to 
pay as a result of a settlement, judgment, or pre-filing settlement in criminal and civil 
cases and may not reflect actual collections.  Recoveries may involve cases that include  
participation by other Federal and State agencies. 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   1   
   
such authority.8  If the Unit is located in a State that does not have an 
entity with statewide prosecutorial-authority, the Unit must have formal 
procedures approved by OIG to ensure that cases are referred to State 
entities with criminal prosecutorial  authority and ensure that the State 
entities cooperate with the Unit.9  In 44 States and the District of 
Columbia, the Units are located within offices of State Attorneys General; 
in 6 States, the Units are located in other State agencies.10  Each Unit must 
be a single, identifiable entity of State government, distinct from the single 
State Medicaid agency, and must develop a formal agreement (i.e., 
Memorandum of Understanding (MOU) that describes its relationship 
with that agency.11   
Oversight of the MFCU Program 
The Secretary of HHS delegated to OIG the authority to annually certify the 
Units and to administer grant awards to reimburse States for a percentage of 
their costs of operating certified Units.12   All Units are currently federally 
funded on a 75-percent matching basis, with the States contributing the 
remaining 25 percent.13  To receive Federal reimbursement, each Unit must 
submit an application to OIG.14  OIG reviews the application and notifies the 
Unit if it is approved and the Unit is certified.  Approval and certification are 
for a 1-year period; the Unit must be recertified each year thereafter.15    
Pursuant to Title XIX of the SSA, States must operate Units that effectively 
carry out their statutory functions and meet program requirements.16                                
OIG developed and issued 12 performance standards to define the criteria it 
applies in assessing whether a Unit is  effectively carrying out statutory  
   
 
8  SSA  1903(q)(1).  
9  SSA  1903(q)(1)(B).  
10OIG Medicaid Fraud Control Units. Accessed at http://oig.hhs.gov/fraud/medicaid-
fraud-control-units-mfcu/index.asp on  May 21, 2013. 
11 SSA  1903(q)(2);  42 CFR   1007.5 and 1007.9(d).   
12 The portion of funds reimbursed to States by the Federal  government for  its share of  
expenditures for the Federal  Medicaid program, including  the MFCUs, is  called Federal  
Financial Participation  (FFP). 
13 SSA  1903(a)(6)(B).   
14 42  CFR  1007.15(a).  
15 42  CFR  1007.15(b) and (c).  
16 SSA  1902(a)(61). 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   2   
   
functions and meeting program requirements.17  Examples of criteria include 
maintaining an adequate caseload through referrals from several sources, 
maintaining an annual training plan for all professional disciplines, and 
establishing policy and procedure manuals to reflect the Units operations.  
See Appendix A for a complete list of the 1994 performance standards and 
Appendix B for a complete list of the 2012 performance standards.  
Minnesota Medicaid Program 
The Minnesota Medicaid program is located within the Minnesota 
Department of Human Services.  The Minnesota Medicaid program  
provides services to over 885,000 Minnesotans, 68 percent of whom are 
enrolled in managed care.18   Total Minnesota Medicaid expenditures for                                  
FY 2012 were over $9 billion.19  
Minnesota Unit 
The Minnesota Unit is housed within the Minnesota Attorney Generals 
Office (AGO), located in the State capital of St. Paul.  The Unit expended 
a total of $1.4 million in combined State and Federal funds for FY 2012.20   
At the time of our April 2013 review, the Unit employed 13 staff members 
including a director, 4 attorneys, 4 investigators, 1 investigative auditor, 
and 3 support staff. During FY 2010 through FY 2012, provider fraud 
represented 87 percent of the Units open cases; the remaining 13 percent 
involved cases of patient abuse and neglect, including cases of theft of 
patient funds. The Unit has authority to prosecute Medicaid fraud cases, 
but does not have original jurisdiction to prosecute abuse and neglect 
cases.21  However, county attorneys with original jurisdiction may choose 
to refer cases back to the Unit for prosecution. 
   
 
17 77 Fed Reg. 32645 (June 1, 2012).  Accessed at http://oig.hhs.gov/authorities/docs/ 
2012/PerformanceStandardsFinal060112.pdf  on August 15, 2012.  Previous performance 
standards established in  1994  are found at 59 Fed. Reg.  49080 (Sept. 26, 1994).  
Accessed at http://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/files/ 
Performance%20Standards.pdf on August 15, 2013.                                     
18  Mecdicaid.gov Minnesota Medicaid Statistics.   Accessed at  http://www.medicaid.gov/  
medicaid-chip-program-information/by-state/minnesota.html  on June 10, 2003.  
19  MFCU Statistical Data for FY 2011. Accessed at https://oig.hhs.gov/fraud/medicaid-
fraud-control-units-mfcu/ on January  13, 2014.  
20  OIG,  State Medicaid Fraud Control Units  Fiscal Year 2012 Grant Expenditures and 
Statistics. Accessed at  https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/expenditures_statistics/fy2012-statistical-chart.htm on March  8, 2013. 
21  Minnesota  Statute 388.051 provides county attorneys with original jurisdiction for 
prosecution of all crimes in Minnesota, unless specifically provided elsewhere.  
Minnesota Statute 256B.21 provides the Unit with  original  jurisdiction in  Medicaid fraud  
cases. 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   3   
   
Previous Review  
In 2007, OIG conducted an onsite review of the Minnesota Unit.  In that 
review, OIG found that the investigative case files lacked consistency and 
that the Unit did not have standardized policies and procedures in place for 
the creation and maintenance of investigative case files.22 The review also 
found that Unit investigators had a high average of open cases (18 cases 
per investigator), making it difficult to effectively and efficiently manage 
the investigative process. 
METHODOLOGY 
We based the review on an analysis of data from seven sources:   
(1) a review of policies, procedures, and documentation of the Units 
operations, staffing, and caseload; (2) a review of financial 
documentation; (3) structured interviews with key stakeholders; 
(4) a survey of Unit staff; (5) structured interviews with the Units 
Director and supervisors; (6) an onsite review of case files that were open 
in FYs 2010 through 2012; and (7) an onsite review of Unit operations in 
April 2013. We analyzed data from  all seven sources to describe the 
caseload; assess the performance of the Unit; identify any opportunities 
for improvement; and identify any instances in which the Unit did not 
fully meet the performance standards or was not operating in accordance 
with laws, regulations, and policy transmittals.23 In addition, we noted any 
practices that appeared to benefit the Unit.  We based these observations 
on statements from Unit staff, data analysis, and our own judgment.  We  
did not independently verify the effectiveness of these practices, but 
included the information because it may be useful to other Units in their 
operations. 
Data Collection and Analysis 
Review of Unit Documentation.  We reviewed policies, procedures, and 
documentation of the Units operations, staffing, and cases, including its 
annual reports, quarterly statistical reports, and responses to recertification 
questionnaires.  
Review of Financial Documentation. We reviewed Unit financial 
practices to determine compliance with applicable laws and regulations 
and to determine the need for additional internal controls.  Prior to the 
onsite review, we reviewed the Units financial policies and procedures, 
its response to an internal control questionnaire, and MFCU grant-related 
 
22 OIG issued the 2007  review directly to the Unit and did  not make the review publicly 
available. 

23 All relevant  regulations, statutes, and  policy transmittals are available online at 

http://oig.hhs.gov. 

Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   4   
   
documents such as financial status reports.  During the onsite review, we 
reviewed a sample of the Units purchase and travel transactions.  In 
addition, we reviewed a sample of time and effort records.  
Interviews with Key Stakeholders. We conducted structured interviews 
with key stakeholders who were familiar with the Unit operations.  
Specifically, we interviewed staff from the Minnesota Department of 
Human Services, Medicaid Program Integrity Unit (hereinafter referred to 
as the State Medicaid agency); the Minnesota Department of Human 
Services, Office of Long Term Care; an HHS OIG investigator who 
worked closely with the Unit during the review period; three of the four 
largest managed care organizations that operate in Minnesota (Blue Cross 
Blue Shield, Health Partners, and UCare); and an Assistant United States 
Attorney. These interviews focused on the Units interaction with external 
agencies.  
Survey of Unit Staff.  We administered an electronic survey to 
nonmanagerial Unit staff.  Our questions focused on operations, 
opportunities for improvement, and effective practices.   
Interviews with Unit Management and Staff. We conducted structured 
interviews with the Assistant Attorney General (who serves as the Unit 
Director and Chief Attorney), the Deputy Attorney General, the Chief  
Investigator, and the Chief Auditor.  We asked respondents to provide any 
additional information to better illustrate the Units operations, identify  
opportunities for improvement and effective practices, and clarify 
information we obtained from other data sources. 
Onsite Review of Case Files.  We selected a statistically valid, simple 
random sample of 100 case files from the 267 cases open at some point 
during FYs 2010 through 2012.  We reviewed all 100 of these sampled 
case files for the following issues:  documentation of supervisory approval 
for the opening and closing of cases; periodic supervisory reviews, 
timeliness of case development; and the Units processes for monitoring 
the status and outcomes of cases.  From these 100 case files, we selected a 
further random sample of 50 files for a more in-depth review of issues, 
such as the appropriateness and timeliness of investigations.  See 
Appendix C for point estimates and corresponding 95-percent confidence 
intervals.  
Onsite Review of Unit Operations. We reviewed the Units operations 
during our onsite visit. Specifically, we reviewed the process for 
receiving referrals, electronic case management, security of case files, and 
general functioning of the Unit. 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   5   
   
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of the Inspectors General 
on Integrity and Efficiency.   
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   6   
   
FINDINGS 
For FYs 2010 through 2012, the Minnesota Unit 
obtained 62 criminal convictions and 59 civil 
settlements, and reported recoveries of over                           
$64 million 
For FYs 2010 through 2012, the Unit filed criminal charges against                 
74 defendants and obtained 62 criminal convictions.  Nearly 80 percent of 
these convictions involved provider fraud; the remaining 20 percent 
involved patient abuse and neglect, including theft of patient funds.  The 
Unit was awarded nearly $3 million in criminal recoveries.  See  
Table 1. 
Table 1: Unit Criminal Charges, Convictions, and Ordered Recoveries,                      
FYs 20102012  
Criminal Investigations   Charges   Convictions  
Fraud  60  49 
Patient Abuse and Neglect  4  4 
Theft of Patient Funds  10  9 
     Total   74  62 
Criminal Recoveries Ordered    $2,976,780*  
Source:  OIG analysis of Unit  data and quarterly statistical reports, FYs 20102012.  

 
*Unit criminal recoveries ordered were $856,490 in FY 2010, $347,641 in FY 2011, and $1,772,648 in FY 2012.
 
The Unit obtained 59 civil settlements, resulting in more than $61 million 
in civil recoveries.  Ninety-seven percent ($59 million) of settlements 
were from global settlements.24 See Table 2. 
Table 2: Unit Civil Recoveries, FYs 20102012  
Total  
Recovery  Type   FY 2010   FY 2011   FY 2012  
Recoveries  
Global  $23,101,825  $17,309,623  $18,839,389   $59,250,837  
State Only    $738,166  $370,146  $707,496   $1,815,808 
 Total   $23,839,991   $17,679,769   $19,546,885   $61,066,645  
Source:  OIG analysis of Unit  data and quarterly statistical reports, FYs 20102012. 
 
 
24 Global settlements originate from civil false claims cases involving the 
U.S.  Department of Justice and other State MFCUs.  The Federal Government often  
represents multiple States in  global settlements, but the $59  million is the portion  owed to  
Minnesota.    
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   7   
   
The Units MOU with the State Medicaid agency did 
not reflect all current processes 
According to Performance Standard 10, the Unit should periodically 
review its MOU with the State Medicaid agency to ensure that the MOU 
reflects current law and practice. The Unit updated its MOU with the 
State Medicaid agency in April 2012. However, the MOU did not include 
language that addresses 42 CFR  455.23, which requires payment 
suspension of any provider against whom there is a credible allegation of  
fraud (effective March 25, 2011).25  Despite the lack of payment 
suspension language in the MOU, the Unit and the State Medicaid agency 
have a documented process for suspending payments to providers against 
whom there is a credible allegation of fraud.  Since our onsite visit, the 
Unit has modified its MOU with the State Medicaid agency to address  
42 CFR  455.23. 
The Units training plan did not include a minimum 
number of training hours 
Performance Standard 12 states that the Unit should maintain a training 
plan that indicates an annual minimum number of training hours for each 
professional discipline and should ensure that professional staff satisfy 
continuing education standards. We found that the Unit had a training 
plan for each professional discipline, but the plan did not specify a 
minimum number of training hours.  Nonetheless, Unit professional staff 
satisfied continuing education standards by attending training on health 
care, investigative issues, and legal issues sponsored by the Department of 
Veterans Affairs, the National White Collar Crime Center, and legal 
education entities.26 Since our onsite visit, the Unit has updated its 
training plan to include an annual minimum number of training hours for 
each professional discipline.  
   
 
25  42  CFR  455.23.  Accessed at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-
mfcu/45523.asp  on June 12, 2013.   
26 Although we reviewed training records, we did not evaluate  each staff members 
professional qualifications.  Rather, we applied the performance standards to evaluate  
whether the Unit maintained  a formal training  plan for each professional discipline and 
assessed training opportunities specific to  Unit operations.  We  recognize that attorneys, 
investigators, and auditors receive professional and law enforcement training, and that the 
lack of a minimum number  of training hours does not suggest that professional staff are 
unqualified.  
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   8   
   
Some Unit case files lacked documentation of 
supervisory reviews and approvals 
Performance Standard 6 states that Unit supervisors should periodically 
conduct reviews of ongoing investigations and should note the reviews in 
the case file. During our onsite review, the Unit Director reported meeting 
at least monthly with investigators and attorneys to discuss and review all 
open case files and provided documentation of these reviews.  However, 
these supervisory reviews were not documented in 58 percent of the case 
files that were open for longer than 30 days and instead were stored in the 
Unit Directors office. See Appendix C for point estimates and 
corresponding 95-percent confidence intervals.  
Performance Standard 6 also states that managers should approve the 
opening and closing of cases, and the Units policies and procedures state 
that these approvals should be documented in case files.  We found that 
case files lacked documentation of supervisory approval for 19 percent of 
case openings and 23 percent of case closings. The Unit Director 
explained that there was supervisory approval for case openings and 
closings in each case, but in some cases the Unit Director or Chief 
Investigator did not sign the memo  for the opening or closing.  See 
Appendix C for point estimates and corresponding 95-percent confidence 
intervals.   
The Unit stored some case files in a location 
accessible to non-Unit staff 
According to Performance Standard 1, the Unit should conform to all 
applicable statutes, regulations, and policy transmittals.  Federal 
regulations and OIG policy require Units to prevent the misuse of  
information under the Units control by safeguarding the privacy rights of 
witnesses, victims, and informants.27  During our onsite review, we 
observed that some case files were stored in unlocked file cabinets in a 
hallway that is inaccessible to the public, but in proximity to non-Unit 
staff in the Minnesota Attorney Generals Office.  Unit officials reported  
that they promptly moved the file cabinets to a locked storage room  
accessible only to Unit staff.   
 
 
27 42 CFR   1007.11(f); OIG State Fraud Policy Transmittal 99-02, Public Disclosure    
Requests and Safeguarding  of  Privacy Rights (December 22, 1999). 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   9   
   
Other observation:  The Unit helped to pass
legislation that strengthens background checks for 
guardians and conservators of Medicaid beneficiaries   
The Unit worked with two Minnesota Deputy Attorneys General to 
research and draft legislation that strengthens Minnesotas background 
check processes for guardians (appointed persons who make personal 
decisions for Medicaid beneficiaries) and conservators (appointed persons 
who make financial decisions for Medicaid beneficiaries).  Effective 
May 2013, the expanded background checks include requirements that the 
guardian or conservator must disclose things such as whether they have 
ever been denied a professional license by the State, whether they have 
ever filed for bankruptcy, or whether they have ever had a restraining 
order filed against them.  Additionally, the new legislation requires that 
the court conduct background checks of guardians and conservators every 
2 years rather than every 4 years.28   
Other observation:  The Unit does not issue mobile 
phones to its investigators  
Notably, the Unit does not issue mobile phones to Unit investigators for 
use while in the field, as is standard among the other MFCUs and other 
law enforcement offices.  The Unit Director explained that the Units 
parent agency, the Minnesota AGO, also does not issue mobile phones to 
any staff. Therefore, when conducting field investigations, Unit staff may 
either use their personal mobile phones or the mobile phones of others, 
such as OIG agents jointly investigating a case.  When using personal 
mobile phones, Unit staff call the Unit operator to route the call to the 
appropriate individual using a State office phone number, thereby masking 
the caller identification of the personal mobile phone.   
   
 
28  Minnesota Statute 524.5-188. Accessed at https://www.revisor.mn.gov/  
statutes/?id=524.5-118 on  November 8, 2013. 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   10   
   
CONCLUSION AND RECOMMENDATIONS 
For FYs 2010 through 2012, the Minnesota Unit obtained 62 criminal 
convictions and 59 civil settlements, and reported recoveries of over                              
$64 million.  Unit staff reported working with the Minnesota Attorney 
General to draft legislation that strengthened background checks for 
guardians and conservators of Medicaid beneficiaries.   
Our review of compliance issues found no evidence of significant 
noncompliance with applicable laws or regulations.  However, we found 
four opportunities for improvement in the Units adherence to the 
performance standards.  As a result, we recommend that the Minnesota 
Unit: 
Update its MOU with the State Medicaid Agency  
The Unit should update its MOU with the State Medicaid agency to 
include language that sufficiently addresses 42 CFR  455.23 regarding 
provider payment suspension. 
Establish training hour requirements for each professional 
discipline 
The Unit should include an annual minimum number of training hours for 
attorneys, auditors, director, and investigators in the Unit training plan.     
Include notation of periodic supervisory reviews and approval 
in all case files 
The Unit should ensure that all appropriate documentation is located in the 
case files. Specifically, supervisory reviews and supervisory approval for 
opening and closing cases should be documented and located in the case 
file.   
Secure case files 
The Unit should store all case files and other documentation containing 
personally identifiable information in a locked room or in locked storage 
cabinets.  
 
 
 
 
 
 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   11   
   
UNIT COMMENTS AND OFFICE OF INSPECTOR GENERAL  
RESPONSE 
    The Unit concurred with the four report recommendations. 
Regarding the first recommendation, the Unit reported that it had long 
utilized a documented process for suspending payments to providers 
against whom there are credible allegations of fraud.  The Unit reported 
that it has updated its MOU with the Minnesota Department of Human 
Services to reflect this process.   
Regarding the second recommendation, the Unit explained that Unit 
attorneys satisfy a minimum of 45 credit hours of professional training 
every 3 years and that nonattorney Unit staff receive regular training from 
a number of sources.  The Unit reported that it has updated its training 
plan to specify a minimum number of training hours that Unit 
professionals must receive.  
Regarding the third recommendation, the Unit explained that the Unit 
Director regularly reviews the status of all open investigations.  The Unit 
reported that in the past, the Unit Director had maintained these records in 
his office, but that following our onsite visit, he began placing a record of 
reviews in case files.  Additionally, the Unit reported that the Director has  
begun documenting approval of case opening and closing in case files.  
Regarding the fourth recommendation, the Unit reported that it has moved 
the contents of file cabinets to locked rooms within the Unit office.  
The full text of the Units comments is provided in Appendix D.  We did 
not make any changes to the report as a result of the Units comments.  
   
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   12   
   
APPENDIX A 
Performance Standards for Medicaid Fraud Control Units 
[59 Fed. Reg. 49080, Sept. 26, 1994] 
1. 	A Unit will be in conformance with all applicable statutes, 
regulations and policy transmittals.  In meeting this standard, the 
Unit must meet, but is not limited to, the following requirements:  
a. 	  The Unit professional staff must consist of permanent employees 
working full-time on Medicaid fraud and patient abuse matters. 
b. 	  The Unit must be separate and distinct from the single State 
Medicaid agency. 
c. 	  The Unit must have prosecutorial authority or an approved formal 
procedure for referring cases to a prosecutor. 
d. 	  The Unit must submit annual reports, with appropriate 

certifications, on a timely basis. 
 
e. 	  The Unit must submit quarterly reports on a timely basis. 
f. 	  The Unit must comply with the Americans with Disabilities Act, 
the Equal Employment opportunity requirements, the Drug Free 
workplace requirements, Federal lobbying restrictions, and other 
such rules that are made conditions of the grant. 
2. 	A Unit should maintain staff levels in accordance with staffing 
allocations approved in its budget. In meeting this standard, the 
following performance indicators will be considered: 
a. 	  Does the Unit employ the number of staff that was included in the 
Units budget as approved by the OIG? 
b. 	  Does the Unit employ the number of attorneys, auditors, and 
investigators that were approved in the Units budget? 
c. 	  Does the Unit employ a reasonable size of professional staff in 
relation to the States total Medicaid program expenditures?   
d. 	  Are the Unit office locations established on a rational basis and are 
such locations appropriately staffed? 
3. 	A Unit should establish policies and procedures for its operations, 
and maintain appropriate systems for case management and case 
tracking.  In meeting this standard, the following performance 
indicators will be considered: 
a. 	  Does the Unit have policy and procedure manuals? 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   13   
   
b. 	  Is an adequate, computerized case management and tracking 
system in place? 
4. 	A Unit should take steps to ensure that it maintains an adequate 
workload through referrals from the single State agency and other 
sources.  In meeting this standard, the following performance 
indicators will be considered:  
a. 	  Does the Unit work with the single State Medicaid agency to 
ensure adequate fraud referrals? 
b. 	  Does the Unit work with other agencies to encourage fraud 

referrals? 

c. 	  Does the Unit generate any of its own fraud cases? 
d. 	  Does the Unit ensure that adequate referrals of patient abuse 
complaints are received from all sources? 
5. 	A Units case mix, when possibl e, should cover all significant 
provider types. In meeting this standard, the following performance 
indicators will be considered:  
a. 	  Does the Unit seek to have a mix of cases among all types of 
providers in the State? 
b. 	  Does the Unit seek to have a mix of Medicaid fraud and Medicaid 
patient abuse cases? 
c. 	  Does the Unit seek to have a mix of cases that reflect the 

proportion of Medicaid expenditures for particular provider 

groups? 

d. 	  Are there any special Unit initiatives targeting specific provider 
types that affect case mix? 
e. 	  Does the Unit consider civil and administrative remedies when  
appropriate? 
6. 	A Unit should have a continuous  case flow, and cases should be 
completed in a reasonable time. In meeting this standard, the 
following performance indicators will be considered:  
a. 	  Is each stage of an investigation and prosecution completed in an 
appropriate time frame?  
b. 	  Are supervisors approving the opening and closing of 

investigations?
   
c. 	  Are supervisory reviews conducted periodically and noted in the 
case file? 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   14   
   
7. A Unit should have a process for monitoring the outcome of cases.  
In meeting this standard, the following performance indicators will be 
considered:  
a. 	  The number, age, and type of cases in inventory. 
b. 	  The number of referrals to other agencies for prosecution. 
c. 	  The number of arrests and indictments. 
d. 	  The number of convictions. 
e. 	  The amount of overpayments identified. 
f. 	  The amount of fines and restitution ordered. 
g.	   The amount of civil recoveries. 
h.	   The numbers of administrative sanctions imposed. 
8. 	A Unit will cooperate with the OIG and other Federal agencies, 
whenever appropriate and consistent with its mission, in the 
investigation and prosecution of health care fraud.  In meeting this 
standard, the following performance indicators will be considered: 
a. 	  Does the Unit communicate effectively with the OIG and other 
Federal agencies in investigating or prosecuting health care fraud 
in their State? 
b.	   Does the Unit provide OIG regional management, and other 
Federal agencies, where appropriate, with timely information 
concerning significant actions in all cases being pursued by the 
Unit? 
c. 	  Does the Unit have an effective procedure for referring cases,  
when appropriate, to Federal agencies for investigation and other 
action?  
d.	   Does the Unit transmit to the OIG, for purposes of program  
exclusions under section 1128 of the Social Security Act, reports 
of convictions, and copies of Judgment and Sentence or other 
acceptable documentation within 30 days or other reasonable time 
period? 
9. 	A Unit should make statutor y or programmatic recommendations, 
when necessary, to the State government. In meeting this standard, 
the following performance indicators will be considered:  
a. 	  Does the Unit recommend amendments to the enforcement 
provisions of the States statutes when necessary and appropriate 
to do so? 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   15   
   
b. 	  Does the Unit provide program recommendations to single State 
agency when appropriate? 
c. 	  Does the Unit monitor actions taken by State legislature or State 
Medicaid agency in response to recommendations? 
10. 	A Unit should periodica lly review its memorandum of 
understanding (MOU) with the single State Medicaid agency and 
seek amendments, as necessary, to ensure it reflects current law  
and practice.  In meeting this standard, the following performance 
indicators will be considered:  
a. 	  Is the MOU more than 5 years old? 
b. 	  Does the MOU meet Federal legal requirements? 
c. 	  Does the MOU address cross-training with the fraud detection staff  
of the State Medicaid agency? 
d. 	  Does the MOU address the Units responsibility to make program  
recommendations to the Medicaid agency and monitor actions  
taken by the Medicaid agency concerning those recommendations? 
11. 	The Unit director should exercise proper fiscal control over the 
Unit resources.  In meeting this standard, the following performance 
indicators will be considered:  
a. 	  Does the Unit director receive on a timely basis copies of all fiscal 
and administrative reports concerning Unit expenditures from the 
State parent agency? 
b. 	  Does the Unit maintain an equipment inventory?  
c. 	  Does the Unit apply generally accepted accounting principles in its 
control of Unit funding? 
12. 	A Unit should maintain an annual training plan for all 
professional disciplines.  In meeting this standard, the following 
performance indicators will be considered:  
a. 	  Does the Unit have a training plan in place and funds available to 
fully implement the plan? 
b. 	  Does the Unit have a minimum number of hours training 
requirement for each professional discipline, and does the staff 
comply with the requirement? 
c. 	  Are continuing education standards met for professional staff? 
d. 	  Does the training undertaken by staff aid to the mission of the 
Unit?   
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   16   
   
APPENDIX B 
2012 Performance Standards  
[77 Fed. Reg. 32645, June 1, 2012] 
1. 	A unit conforms with all applicable statutes, regulations, and 
policy directives, including:  
a. 	  Section 1903(q) of the Social Security Act, containing the basic 
requirements for operation of a MFCU; 
b. 	  Regulations for operation of a MFCU contained in 42 CFR part 
1007; 
c. 	  Grant administration requirements at 45 CFR part 92 and Federal 
cost principles at 2 CFR part 225; 
d. 	  OIG policy transmittals as maintained on the OIG Web site; and  
e. 	  Terms and conditions of the notice of the grant award. 
2. 	A Unit maintains reasonable staff levels and office locations in 
relation to the States Medicaid program expenditures and in 
accordance with staffing allocations approved in its budget.  
a. 	  The Unit employs the number of staff that is included in the Units 
budget estimate as approved by OIG. 
b. 	  The Unit employs a total number of professional staff that is 
commensurate with the States total Medicaid program  
expenditures and that enables the Unit to effectively investigate  
and prosecute (or refer for prosecution) an appropriate volume of 
case referrals and workload for both Medicaid fraud and patient 
abuse and neglect. 
c. 	  The Unit employs an appropriate mix and number of attorneys, 
auditors, investigators, and other professional staff that is both 
commensurate with the States total Medicaid program  
expenditures and that allows the Unit to effectively investigate and 
prosecute (or refer for prosecution) an appropriate volume of case 
referrals and workload for both Medicaid fraud and patient abuse 
and neglect. 
d. 	  The Unit employs a number of support staff in relation to its 
overall size that allows the Unit to operate effectively.  
e. 	  To the extent that a Unit maintains multiple office locations, such 
locations are distributed throughout the State, and are adequately 
staffed, commensurate with the volume of case referrals and 
workload for each location. 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   17   
   
3. 	A Unit establishes written policies and procedures for its 
operations and ensures that staff are familiar with, and adhere to, 
policies and procedures.  
a. 	  The Unit has written guidelines or manuals that contain current 
policies and procedures, consistent with these performance 
standards, for the investigation and (for those Units with 
prosecutorial authority) prosecution of Medicaid fraud and patient 
abuse and neglect. 
b.	   The Unit adheres to current policies and procedures in its 

operations. 

c. 	  Procedures include a process for referring cases, when appropriate, 
to Federal and State agencies. Referrals to State agencies, 
including the State Medicaid agency, should identify whether 
further investigation or other administrative action is warranted, 
such as the collection of overpayments or suspension of payments. 
d. 	  Written guidelines and manuals are readily available to all Unit 
staff, either online or in hard copy. 
e. 	  Policies and procedures address training standards for Unit 

employees. 

4. 	A Unit takes steps to maintain an adequate volume and quality of 
referrals from the State Medicaid agency and other sources. 
a. 	  The Unit takes steps, such as the development of operational 
protocols, to ensure that the State Medicaid agency, managed care 
organizations, and other agencies refer to the Unit all suspected 
provider fraud cases. Consistent with 42 CFR 1007.9(g), the Unit 
provides timely written notice to the State Medicaid agency when 
referred cases are accepted or declined for investigation.  
b. 	  The Unit provides periodic feedback to the State Medicaid agency 
and other referral sources on the adequacy of both the volume and 
quality of its referrals.  
c. 	  The Unit provides timely information to the State Medicaid or 
other agency when the Medicaid or other agency requests 
information on the status of MFCU investigations, including when 
the Medicaid agency requests quarterly certification pursuant to  
42 CFR 455.23(d)(3)(ii). 
d. 	  For those States in which the Unit has original jurisdiction to 
investigate or prosecute patient abuse and neglect cases, the Unit 
takes steps, such as the development of operational protocols, to 
ensure that pertinent agencies refer such cases to the Unit, 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   18   
   
consistent with patient confidentiality and consent.  Pertinent 
agencies vary by State but may include licensing and certification 
agencies, the State Long Term Care Ombudsman, and adult 
protective services offices. 
e. 	  The Unit provides timely information, when requested, to those 
agencies identified in (D) above regarding the status of referrals. 
f. 	  The Unit takes steps, through public outreach or other means, to 
encourage the public to refer cases to the Unit.  
5. 	A Unit takes steps to maintain a continuous case flow and to 
complete cases in an appropriate timeframe based on the 
complexity of the cases.  
a. 	  Each stage of an investigation and prosecution is completed in an 
appropriate timeframe. 
b. 	  Supervisors approve the opening and closing of all investigations 
and review the progress of cases and take action as necessary to 
ensure that each stage of an investigation and prosecution is 
completed in an appropriate timeframe. 
c. 	  Delays to investigations and prosecutions are limited to situations 
imposed by resource constraints or other exigencies. 
6. 	A Units case mix, as practicabl e, covers all significant provider 
types and includes a balance of fraud and, where appropriate, 
patient abuse and neglect cases.  
a. 	  The Unit seeks to have a mix of cases from all significant provider 
types in the State.  
b. 	  For those States that rely substantially on managed care entities for 
the provision of Medicaid services, the Unit includes a 
commensurate number of managed care cases in its mix of cases. 
c. 	  The Unit seeks to allocate resources among provider types based 
on levels of Medicaid expenditures or other risk factors.  Special 
Unit initiatives may focus on specific provider types. 
d. 	  As part of its case mix, the Unit maintains a balance of fraud and 
patient abuse and neglect cases for those States in which the Unit 
has original jurisdiction to investigate or prosecute patient abuse 
and neglect cases.  
e. 	  As part of its case mix, the Unit seeks to maintain, consistent with 
its legal authorities, a balance of criminal and civil fraud cases. 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   19   
   
7. 	A Unit maintains case files in an effective manner and develops a 
case management system that allows efficient access to case 
information and other performance data. 
a. 	  Reviews by supervisors are conducted periodically, consistent with 
MFCU policies and procedures, and are noted in the case file.  
b. 	  Case files include all relevant facts and information and justify the 
opening and closing of the cases. 
c. 	  Significant documents, such as charging documents and settlement 
agreements, are included in the file.  
d. 	  Interview summaries are written promptly, as defined by the Units 
policies and procedures. 
e. 	  The Unit has an information management system that manages and 
tracks case information from initiation to resolution. 
f. 	  The Unit has an information management system that allows for 
the monitoring and reporting of case information, including the 
following: 
1. 	  The number of cases opened and closed and the reason that  
cases are closed. 
2. 	  The length of time taken to determine whether to open a 
case referred by the State Medicaid agency or other 
referring source. 
3. 	  The number, age, and types of cases in the Units 
inventory/docket. 
4. 	  The number of referrals received by the Unit and the 
number of referrals by the Unit to other agencies. 
5. 	  The dollar amount of overpayments identified. 
6. 	  The number of cases criminally prosecuted by the Unit or 
referred to others for prosecution, the number of 
individuals or entities charged, and the number of pending 
prosecutions. 
7. 	  The number of criminal convictions and the number of civil 
judgments. 
8. 	  The dollar amount of fines, penalties, and restitution 
ordered in a criminal case and the dollar amount of 
recoveries and the types of relief obtained through civil 
judgments or prefiling settlements. 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   20   
   
8. 	A Unit cooperates with OIG and other Federal agencies in the 
investigation and prosecution of Medicaid and other health care 
fraud.  
a. 	  The Unit communicates on a regular basis with OIG and other 
Federal agencies investigating or prosecuting health care fraud in 
the State.  
b.	   The Unit cooperates and, as appropriate, coordinates with OIGs 
Office of Investigations and other Federal agencies on cases being 
pursued jointly, cases involving the same suspects or allegations, 
and cases that have been referred to the Unit by OIG or another 
Federal agency. 
c. 	  The Unit makes available, to the extent authorized by law and 
upon request by Federal investigators and prosecutors, all 
information in its possession concerning provider fraud or fraud in 
the administration of the Medicaid program. 
d.	   For cases that require the granting of extended jurisdiction to 
investigate Medicare or other Federal health care fraud, the Unit 
seeks permission from OIG or other relevant agencies under 
procedures as set by those agencies.  
e. 	  For cases that have civil fraud potential, the Unit investigates and 
prosecutes such cases under State authority or refers such cases to 
OIG or the U.S. Department of Justice. 
f. 	  The Unit transmits to OIG, for purposes of program exclusions 
under section 1128 of the Social Security Act, all pertinent 
information on MFCU convictions within 30 days of sentencing, 
including charging documents, plea agreements, and sentencing 
orders. 
g. 	  The Unit reports qualifying cases to the Healthcare Integrity & 
Protection Databank, the National Practitioner Data Bank, or 
successor data bases.  
9. 	 A Unit makes statutory or programmatic recommendations, when 
warranted, to the State government. 
a. 	  The Unit, when warranted and appropriate, makes statutory 
recommendations to the State legislature to improve the operation 
of the Unit, including amendments to the enforcement provisions 
of the State code. 
b.	   The Unit, when warranted and appropriate, makes other regulatory 
or administrative recommendations regarding program integrity 
issues to the State Medicaid agency and to other agencies 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   21   
   
responsible for Medicaid operations or funding.  The Unit monitors 
actions taken by the State legislature and the State Medicaid or 
other agencies in response to recommendations. 
10. 	A Unit periodically reviews  its Memorandum of Understanding 
(MOU) with the State Medicaid agency to ensure that it reflects 
current practice, policy, and legal requirements. 
a. 	  The MFCU documents that it has reviewed the MOU at least every 
5 years, and has renegotiated the MOU as necessary, to ensure that 
it reflects current practice, policy, and legal requirements. 
b. 	  The MOU meets current Federal legal requirements as contained in 
law or regulation, including 42 CFR 455.21, Cooperation with 
State Medicaid fraud control units, and 42 CFR 455.23, 
Suspension of payments in cases of fraud. 
c. 	  The MOU is consistent with current Federal and State policy, 
including any policies issued by OIG or the Centers for Medicare 
& Medicaid Services (CMS). 
d.	   Consistent with Performance Standard 4, the MOU establishes a 
process to ensure the receipt of an adequate volume and quality of  
referrals to the Unit from the State Medicaid agency. 
e. 	  The MOU incorporates by reference the CMS Performance 
Standard for Referrals of Suspected Fraud from a State Agency to 
a Medicaid Fraud Control Unit. 
11. 	A Unit exercises proper fiscal  control over Unit resources.  
a. 	  The Unit promptly submits to OIG its preliminary budget 
estimates, proposed budget, and Federal financial expenditure 
reports. 
b.	   The Unit maintains an equipment inventory that is updated 

regularly to reflect all property under the Units control. 

c. 	  The Unit maintains an effective time and attendance system and 
personnel activity records. 
d.	   The Unit applies generally accepted accounting principles in its 
control of Unit funding. 
e. 	  The Unit employs a financial system in compliance with the 
standards for financial management systems contained in 45 CFR 
92.20. 
 
 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   22   
   
12. 	A Unit conducts training that  aids in the mission of the Unit. 
a. 	  The Unit maintains a training plan for each professional discipline 
that includes an annual minimum number of training hours and that 
is at least as stringent as required for professional certification. 
b. 	  The Unit ensures that professional staff comply with their training 
plans and maintain records of their staffs compliance.  
c. 	  Professional certifications are maintained for all staff, including  
those that fulfill continuing education requirements.  
d. 	  The Unit participates in MFCU related training, including training 
offered by OIG and other MFCUs, as such training is available and 
as funding permits. 
e. 	  The Unit participates in cross training with the fraud detection staff  
of the State Medicaid agency. As part of such training, Unit staff 
provide training on the elements of successful fraud referrals and 
receive training on the role and responsibilities of the State 
Medicaid agency. 
   
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   23   
   
APPENDIX C 
Point Estimates and Confidence Intervals Based on Review of 
Case Files 
95-Percent  
Confidence 
Sample  Point 
Estimate Characteristic   Interval  
Size  Estimate  
Lower  Upper  
Cases open longer than 30 days  and not containing documentation 
91  58.2%   47.4%   68.5%  
indicating at least one supervisory review   
Cases in which reviewers did not find evidence that the supervisor 
100  19.0%   11.8%   28.1%  
approved opening case 
Cases in which reviewers did not find evidence that the supervisor 
70  22.9%   13.7%   34.4%  
approved closing case 
Source:  OIG analysis of MFCU case files, 2013. 
   
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   24   
   
APPENDIX D 
Unit Comments 
 
     
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)  25  Mr. Stuart Wright 
Deputy Inspector General 
February 25.2014 
Page 2 
Response:  As Unit Director, I regularly review the status of all open investigations.  In 
the past, I maintained records of my reviews in my office, rather than in the individual case flies. 
I have now begun to place a record of my reviews both in the case files and in my office.  I also 
orally approved the opening and closing of all  cases.  I have now begun to document my 
approval of case openings and closings in the individual case files. 
Finding:  The l;nit stored some case Illes in a location accessible to non-Unit staff. 
Response:  The Unit stored some case tiles in file cabinets that were inaccessible to the 
public but in proximity to other attorneys and professionals within the Ofticc.  All attorneys and 
staff in the Office are held to the highest standards of conlidentiality and security, and I am not 
aware of any instance in which a non-Unit attorney or staff member accessed the MFCU file 
c.abinets.  Last spring, the Unit moved the contents of the lile cabinets to locked rooms within the 
Office. 
I thank you again for your office's thorough m1d professional review.  If you have any 
questions, plea:;e contact me. 
Sincerely, 
CHUCK ROEHRDANZ 
Director. Medicaid Fraud Control Unit 
Assistant Attorney General 
(651) 757-1299 (Voice) 
(651) 282-SROI (Fax) 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review (OEI-06-13-00200)  26   
   
ACKNOWLEDGMENTS 
This report was prepared under the direction of Kevin Golladay, Regional 
Inspector General for Evaluation and Inspections in the Dallas regional 
office; Blaine Collins, Deputy Regional Inspector General; and                           
Ruth Ann Dorrill, Deputy Regional Inspector General.    
Lyndsay Patty served as the team  leader for this study and Ben Gaddis 
served as the lead analyst.  Office of Investigations staff who provided 
support include Curt Muller and Jason Weinstock.  Central office staff 
who provided support include Susan Burbach, Kevin Farber, 
Christine Moritz, Richard Stern, and Sherri Weinstein.   
 
Minnesota State Medicaid Fraud Control Unit:  2013 Onsite Review  (OEI-06-13-00200)   27   
Office of Inspector General
http://oig.hhs.gov  
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as  
amended, is  to protect the integrity of the Department of  Health and Human Services  
(HHS)  programs, as well as the health and welfare of beneficiaries  served by those 
programs.  This statutory mission  is  carried  out through  a nationwide network  of  audits, 
investigations, and inspections conducted by the  following operating components: 
Office of Audit Services 
The Office  of  Audit Services  (OAS) provides auditing services  for HHS, either by  conducting  
audits  with its own audit resources or by  overseeing  audit work done by others.  Audits  
examine the performance of HHS programs and/or its grantees and contractors in carrying  
out their respective responsibilities and are intended  to provide independent assessments of 
HHS programs and operations.  These assessments help reduce waste, abuse, and  
mismanagement and promote economy and efficiency  throughout  HHS. 
Office  of Evaluation and Inspections 
The Office  of  Evaluation and Inspections (OEI)  conducts national evaluations to  provide 
HHS, Congress, and the public with timely, useful, and reliable information on significant 
issues.  These evaluations focus on preventing fraud,  waste, or abuse  and promoting  
economy, efficiency, and effectiveness of departmental programs.  To promote impact, OEI 
reports also present practical recommendations for improving program operations.  
Office of Investigations  
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations  
of  fraud and misconduct  related to HHS programs, operations, and beneficiaries.  With 
investigators working in all 50 States and the District of Columbia, OI  utilizes its resources 
by actively  coordinating with the Department  of Justice  and other Federal, State, and local 
law enforcement authorities.  The investigative efforts of OI often lead to  criminal 
convictions, administrative sanctions,  and/or  civil monetary  penalties.  
Office  of Counsel to  the Inspector  General  
The Office of Counsel to the  Inspector  General (OCIG) provides general legal services to 
OIG, rendering  advice and opinions on HHS programs and operations and  providing all  
legal support for OIGs  internal operations.  OCIG represents  OIG in all civil and 
administrative fraud and abuse cases involving HHS programs,  including False Claims Act, 
program exclusion, and civil monetary penalty cases.  In  connection with these cases, OCIG 
also negotiates and monitors corporate integrity agreements.  OCIG renders advisory 
opinions, issues compliance program  guidance, publishes fraud alerts, and provides other  
guidance  to  the health care industry concerning the anti-kickback statute and other  OIG  
enforcement authorities.