U.S. Department of Health and Human Services 
Office of Inspector General 
 
Rhode Island Medicaid Fraud 
Control Unit: 2022 Inspection 
 
Ann Maxwell 
Deputy Inspector General for Evaluation and Inspections 
March 2023, OEI-07-22-00370  U.S. Department of Health and Human Services 
 
Office of Inspector General 
Report in Brief 
March 2023, OEI-07-22-00370 
Unit Case Outcomes  Rhode Island Medicaid Fraud Control Unit: 
Federal fiscal years (FYs) 
2022 Inspection  
20192021: 
  17 indictments 
What OIG Found 
  6 convictions 
Our inspection of the Rhode Island MFCU for FYs 20192021 found that the Unit 
  33 civil settlements 
maintained strong working relationships and investigated cases jointly with OIG and 
and judgments 
the U.S. Attorneys Office.  The Unit also took steps to maintain an adequate volume 
  $9.7 million in 
and quality of fraud and patient abuse or neglect referrals, including maintaining 
recoveries 
strong relationships with State partners. 
Unit Snapshot  However, we made three findings related to the Units management of case files and 
The Rhode Island Medicaid  case information.  First, we found that the Unit did not have an information 
Fraud Control Unit (MFCU or  management system with the functionality to manage and track case information 
Unit) is housed in the Rhode  from initiation to resolution, which posed challenges for monitoring cases and 
reporting case information and performance data.  Further, we found that the Unit 
Island Office of the Attorney 
did not have adequate policies or procedures, or consistent practices, for effectively 
General (OAG). 
maintaining case files.  We also found that 60 percent of applicable case files 
At the time of our onsite  contained no documentation of periodic supervisory reviews and that the Units 
inspection in August 2022,  policies and procedures manual did not describe the procedures for or frequencies 
the Unit had a total of nine  of supervisory reviews.   
staff located in Providence.  We made four additional findings related to other aspects of the Units operations.  
We found that some parts of the Units policies and procedures manual lacked 
   
adequate guidance and some parts did not describe the Units current practices.  In 
addition, we found that the Supervisor of Investigations performed auditing duties 
and carried an investigative caseload in addition to his managerial responsibilities, 
which may have impeded the efficiency and effectiveness of the Units operations.  
We also found that the Unit did not consistently report convictions and adverse 
actions to Federal partners within the appropriate timeframes.  Finally, we found that 
Unit supervisors did not track and verify that staff met training requirements.  
What OIG Recommends and How the Unit Responded  
To address the findings, we recommend that the Unit (1) assess whether the Office 
of the Attorney Generals case management system can be modified to fully meet 
the Units needs, and if appropriate, seek approval to implement its own case 
management system; (2) establish policies and/or procedures to ensure that case 
files are maintained in an effective manner; (3) develop a plan to ensure that case 
files include documentation of periodic supervisory reviews and update the Units 
policies and procedures manual to describe the Units current practices for periodic 
supervisory reviews; (4) update its policies and procedures manual to reflect current 
practices; (5) assess the duties of the Supervisor of Investigations, and if warranted, 
develop a plan to reduce his nonmanagerial duties; (6) take steps to ensure that 
convictions and adverse actions are reported to Federal partners within the 
appropriate timeframes; and (7) take steps to track and verify that Unit staff meet 
requirements in its training plan.  The Unit concurred with all seven 
recommendations.     
   
TABLE OF CONTENTS 
 
 
BACKGROUND ................................................................................................................................................ 1 
Methodology ............................................................................................................................................................................. 4 
PERFORMANCE ASSESSMENT ................................................................................................................... 6 
Case Outcomes ......................................................................................................................................................................... 6 
Observation: The Unit reported 17 indictments; 6 convictions; and 33 civil settlements and 
judgments for FYs 20192021. 
Observation: The Unit reported total recoveries of over $9.7 million for FYs 20192021, 
which were primarily from global civil cases. 
Performance Standard 1: Compliance with Requirements ...................................................................................... 7 
Observation: From the data we reviewed, the Rhode Island Unit did not comply with one 
applicable legal requirement. 
Performance Standard 2: Staffing ..................................................................................................................................... 7 
Observation: The Office of the Attorney General eliminated two investigative positions from 
the Unit during the review period. 
Finding: The Supervisor of Investigations performed auditing duties and carried an 
investigative caseload in addition to his managerial responsibilities, which may have 
impeded the efficiency and effectiveness of the Units operations. 
Performance Standard 3: Policies and Procedures ..................................................................................................... 8 
Finding: The Unit maintained a policies and procedures manual, but some parts of the 
manual lacked adequate guidance and some parts did not describe the Units current 
practices. 
Performance Standard 4: Maintaining Adequate Referrals ..................................................................................... 9 
Observation: The Unit took steps to maintain an adequate volume and quality of fraud and 
patient abuse or neglect referrals. 
Performance Standard 5: Maintaining Continuous Case Flow ............................................................................. 10 
Observation: The Unit took steps to maintain a continuous case flow. 
Performance Standard 6: Case Mix ................................................................................................................................. 11 
Observation: The Units caseload included both fraud and patient abuse or neglect cases 
and covered a range of provider types. 
Performance Standard 7: Maintaining Case Information ....................................................................................... 11 
   
Finding: The Unit did not have an information management system with the functionality to 
manage and track case information from initiation to resolution, which posed challenges for 
monitoring cases and reporting case information and performance data. 
Finding: The Unit did not have adequate policies or procedures, or consistent practices, for 
effectively maintaining case files. 
Finding: Sixty percent of applicable case files contained no documentation of periodic 
supervisory reviews, and the Units policies and procedures manual did not describe the 
Units current practices for periodic supervisory reviews. 
Performance Standard 8: Cooperation with Federal Authorities on Fraud Cases ......................................... 15 
Observation: The Unit maintained strong working relationships and investigated cases 
jointly with OIG and the U.S. Attorneys Office. 
Finding: The Unit did not consistently report convictions and adverse actions to Federal 
partners within the appropriate timeframes. 
Performance Standard 9: Program Recommendations .......................................................................................... 16 
Observation: The Unit made recommendations to the State Medicaid agency during the 
review period. 
Performance Standard 10: Agreement with Medicaid Agency ............................................................................ 17 
Observation: During the review period, the Units MOU with the State Medicaid agency did 
not reflect current practice and a legal requirement, but the MOU was subsequently 
amended in 2022 to generally reflect current practice, policy, and legal requirements. 
Performance Standard 11: Fiscal Control ..................................................................................................................... 17 
Observation: From our limited review, we identified no deficiencies in the Units fiscal 
control of its resources. 
Performance Standard 12: Training ................................................................................................................................ 18 
Finding: Although the Unit maintained an annual training plan for its staff, Unit supervisors 
did not track and verify that staff met training requirements. 
Other Observation ................................................................................................................................................................. 18 
Observation: The Unit did not issue mobile phones to professional staff for business use. 
CONCLUSION AND RECOMMENDATIONS ........................................................................................... 19 
Assess whether the Office of the Attorney Generals case management system can be modified to 
fully meet the Units needs, and if appropriate, seek approval to implement its own case 
management system ............................................................................................................................................................ 20 
Establish policies and/or procedures to ensure that case files are maintained in an effective  
manner ....................................................................................................................................................................................... 20 
 
   
Develop a plan to ensure that case files include documentation of periodic supervisory reviews and 
update the Units policies and procedures manual to describe the Units current practices for periodic 
supervisory reviews ............................................................................................................................................................... 20 
Update its policies and procedures manual to reflect current practices .......................................................... 21 
Assess the duties of the Supervisor of Investigations, and if warranted, develop a plan to reduce his 
nonmanagerial duties .......................................................................................................................................................... 21 
Take steps to ensure that convictions and adverse actions are reported to Federal partners within the 
appropriate timeframes ...................................................................................................................................................... 21 
Take steps to track and verify that Unit staff meet requirements in its training plan ................................. 21 
UNIT COMMENTS AND OIG RESPONSE ............................................................................................... 22 
DETAILED METHODOLOGY ...................................................................................................................... 24 
APPENDICES.................................................................................................................................................. 27 
Appendix A: Unit Referrals by Source for Fiscal Years 20192021 ..................................................................... 27 
Appendix B: Point Estimates and 95-Percent Confidence Intervals of Case File Reviews .......................... 28 
Appendix C: Unit Comments ............................................................................................................................................. 29 
ACKNOWLEDGMENTS AND CONTACT ................................................................................................ 33 
ABOUT THE OFFICE OF INSPECTOR GENERAL .................................................................................... 34 
 
 
   
BACKGROUND 
OBJECTIVE 
To examine the performance and operations of the Rhode Island Medicaid Fraud 
Control Unit (MFCU or Unit). 
 
Medicaid Fraud Control Units 
MFCUs investigate Medicaid provider fraud and patient abuse or neglect, and 
prosecute those cases under State law or refer them to other prosecuting offices.1, 2, 3  
Under the Social Security Act (SSA), a MFCU must be a single, identifiable entity of 
State government, separate and distinct from the State Medicaid agency, and 
employ one or more investigators, attorneys, and auditors.4  Each State must operate 
a MFCU or receive a waiver.5  Currently, 50 States, the District of Columbia, Puerto 
Rico, and the U.S. Virgin Islands operate MFCUs.6   
MFCUs are funded jointly by Federal and State governments.  Each Unit receives a 
Federal grant award equivalent to 90 percent of total expenditures for new Units and 
75 percent for all other Units.7  In Federal fiscal year (FY) 2021, combined Federal and 
State expenditures for the MFCUs totaled approximately $314 million, of which 
approximately $236 million represented Federal funds.8   
 
 
_____________________________________________________________________________________________________________________________ 
1 SSA  1903(q)(3).  Regulations at 42 CFR  1007.11(b)(1) clarify that a Units responsibilities include the 
review of complaints of misappropriation of patients private funds in health care facilities. 
2 As of December 27, 2020, MFCUs may also receive Federal financial participation to investigate and 
prosecute abuse or neglect of Medicaid enrollees in a noninstitutional or other setting.  Consolidated 
Appropriations Act, 2021, Public Law 116-260, Division CC,  207. 
3 References to State in this report refer to the States, the District of Columbia, and the U.S. territories. 
4 SSA  1903(q). 
5 SSA  1902(a)(61). 
6 The territories of American Samoa, Guam, and the Northern Mariana Islands have not established Units. 
7 SSA  1903(a)(6).  For a Units first 3 years of operation, the Federal Government contributes 90 percent 
of funding and the State contributes 10 percent.  Thereafter, the Federal Government contributes 
75 percent and the State contributes 25 percent. 
8 OIG analysis of MFCU annual statistical reporting data for FY 2021.  The Federal FY 2021 was from 
October 1, 2021, through September 30, 2022. 
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OIG Grant Administration and Oversight of MFCUs 
The Office of Inspector General (OIG) administers the grant award to each Unit and 
provides oversight of Units.9, 10  As part of its oversight, OIG conducts a desk review of 
each Unit during the annual recertification process.  OIG also conducts periodic 
inspections and reviews.  Finally, OIG provides ongoing training and technical support 
to the Units. 
In its annual recertification review, OIG examines the Units reapplication materials, 
case statistics, and questionnaire responses from Unit stakeholders.  Through the 
recertification review, OIG assesses a Units performance, as measured by the Units 
adherence to published performance standards;11 the Units compliance with 
applicable laws, regulations, and OIG policy transmittals;12 and the Units case 
outcomes. 
OIG further assesses Unit performance by conducting inspections and reviews of 
selected Units.  These inspections and reviews result in public reports of findings and 
recommendations for improvement.  OIG reports may also include observations 
regarding Unit operations and practices, including beneficial practices that may be 
useful to share with other Units.  OIG also provides training and technical assistance 
to Units, as appropriate, during inspections and reviews. 
Rhode Island MFCU 
The Rhode Island Unit is located within the Office of the Attorney General (OAG) in 
Providence.  At the time of our inspection in August 2022, the Unit had an approved 
staff size of 10, and it employed 9 staff3 attorneys (including the Director and 
Managing Attorney), 5 investigators (including the Supervisor of Investigations, who 
also served as the Units auditor), and a paralegal/case coordinator.  The Unit was in 
the process of filling one vacant nurse investigator position.  During the review period 
of FYs 20192021, the Unit spent approximately $3.7 million, with a State share of 
approximately $942,000.  
_____________________________________________________________________________________________________________________________ 
9 As part of grant administration, OIG receives and examines financial information from Units, such as 
budgets and quarterly and final Federal Financial Reports that detail MFCU income and expenditures. 
10 The SSA authorizes the Secretary of Health and Human Services to award grants (SSA  1903(a)(6)) and 
to certify and annually recertify the Units (SSA  1903(q)).  The Secretary delegated these authorities to 
OIG in 1979. 
11 MFCU performance standards are published at 77 Fed. Reg. 32645 (June 1, 2012).  The performance 
standards were developed by OIG in conjunction with the MFCUs and were originally published at 59 
Fed. Reg. 49080 (Sept. 26, 1994). 
12 OIG occasionally issues policy transmittals to provide guidance and instruction to MFCUs.  Policy 
transmittals are located at https://oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/index.asp.  
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Referrals  
The Unit receives referrals of Medicaid provider fraud and of patient abuse or neglect 
from several sources, including the State Medicaid agencys program integrity unit; 
the State survey and certification agency, known as the Center for Health Facilities 
Regulation (CHFR); and the Department of Behavioral Healthcare, Developmental 
Disabilities, and Hospitals (BHDDH).13  The Supervisor of Investigations is responsible 
for conducting the initial intake of referrals and reviews each referral to determine 
whether it falls within the MFCUs jurisdiction.  If additional information is needed to 
evaluate the referral, the case may be assigned to an investigator for preliminary 
investigation.  The Director, Managing Attorney, and Supervisor of Investigations 
decide whether to open a case or decline it for investigation. 
Investigations and Prosecutions 
Once the Unit decides to open a case, the Supervisor of Investigations assigns the 
matter to an investigator.  Unit investigators typically specialize in either fraud cases 
or patient abuse or neglect cases.  During the investigative phase of a case, Unit 
attorneys monitor investigations and advise on cases.  Investigators participate in 
periodic supervisory reviews of their caseloads with the Supervisor of Investigations 
and Unit attorneys.  Upon completion of investigative activities, the case is either 
closed, charged criminally, filed civilly, or referred to another agency as appropriate.  If 
a case is prosecuted, the Unit has Statewide prosecutorial authority.   
Rhode Island Medicaid Program 
The Rhode Island Executive Office of Health and Human Services (EOHHS) administers 
the State Medicaid program.  As of July 2022, the program served 318,021 enrollees.14  
Approximately 88 percent of Rhode Island Medicaid enrollees received services 
through three managed care organizations (MCOs).15, 16  In FY 2021, Rhode Islands 
Medicaid expenditures were approximately $3.2 billion.17 
_____________________________________________________________________________________________________________________________ 
13 BHDDH provides services to individuals who are living with mental illness and/or substance use 
conditions; have developmental disabilities; or need long-term acute care in the State hospital system.  
See https://bhddh.ri.gov/about-us.  
14 Centers for Medicare and Medicaid Services (CMS), July 2022 State Medicaid and CHIP Applications, 
Eligibility Determinations, and Enrollment Data, accessed at 
https://www.medicaid.gov/medicaid/national-medicaid-chip-program-information/medicaid-chip-
enrollment-data/monthly-medicaid-chip-application-eligibility-determination-and-enrollment-reports-
data/index.html on December 2, 2022. 
15 Kaiser Family Foundation (KFF), Share of Medicaid Population Covered under Different Delivery Systems, 
accessed at https://www.kff.org/medicaid/state-indicator/share-of-medicaid-population-covered-under-
different-delivery-systems/ on December 2, 2022. 
16 KFF, Total Medicaid MCOs, accessed at https://www.kff.org/medicaid/state-indicator/total-medicaid-
mcos/ on August 19, 2022. 
17 OIG, MFCU Statistical Data for FY 2021, accessed at https://oig.hhs.gov/fraud/medicaid-fraud-control-
units-mfcu/expenditures_statistics/fy2021-statistical-chart.pdf on August 19, 2022. 
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EOHHSs Office of Program Integrity (OPI) is responsible for Medicaid program 
integrity efforts.  OPI receives referrals of suspected provider fraud from MCOs and 
from a contracted investigation team responsible for the fee-for-service component 
of Rhode Islands Medicaid program.  MCOs send referrals of suspected provider 
fraud to OPI and the Unit simultaneously, but the Unit does not open a case until it 
receives a formal referral from OPI.18  OPI reviews referrals of suspected provider 
fraud to determine whether they constitute a credible allegation of fraud, and then 
refers those cases to the MFCU as appropriate. 
Prior OIG Report 
OIG conducted a previous onsite review of the Rhode Island Unit in 2014.19  In that 
review, which covered FYs 20122014, OIG found that (1) the overall number of 
referrals to the Unit decreased significantly; (2) the Unit did not refer all convictions to 
OIG for program exclusion in a timely manner; (3) the Unit did not report adverse 
actions to the National Practitioner Data Bank (NPDB); (4) the Units internal controls 
over grant expenditures did not include segregation of duties involving its purchase 
card; and (5) almost all case files contained documentation of supervisory approval to 
open and close cases as well as of periodic supervisory reviews. 
OIG recommended that the Unit (1) work with the State Medicaid agency to increase 
referrals; (2) refer providers for exclusion to OIG within an appropriate timeframe; (3) 
report adverse actions to the NPDB; and (4) improve controls over purchase card 
duties and document purchase requests from Unit staff.  On the basis of information 
received from the Unit, OIG considered the recommendations implemented as of June 
2016. 
Methodology 
OIG conducted the inspection of the Rhode Island MFCU in August 2022.  Our 
inspection covered the 3-year period of FYs 20192021.  We based our inspection on 
an analysis of data and information from 7 sources: (1) Unit documentation; (2) 
financial documentation; (3) structured interviews with key stakeholders; (4) structured 
interviews with the Units managers and other selected staff; (5) a review of a sample 
of 51 criminal and nonglobal civil case files that were open at some point during the 
review period; (6) a review of all convictions submitted to OIG for program exclusion 
and all adverse actions submitted to the NPDB during the review period; and (7) an 
onsite review of Unit operations.  See the Detailed Methodology on page 24.   
_____________________________________________________________________________________________________________________________ 
18 The practice of MCOs sending referrals of suspected provider fraud to OPI and the Unit simultaneously 
began in FY 2020.  Although this practice was not described in the Units MOU with the State Medicaid 
agency during the review period (see Performance Standard 10), OPI reported that it was included in its 
operational procedures and will be included in new MCO contracts (see Performance Standard 9). 
19 OIG, Rhode Island State Medicaid Fraud Control Unit: 2014 Onsite Review, accessed at 
https://oig.hhs.gov/oei/reports/oei-02-14-00580.pdf on August 19, 2022. 
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In examining the Units operations and performance, we applied the published 
performance standards, but we did not assess adherence to every performance 
indicator for every standard. 
Standards 
We conducted this study in accordance with the Quality Standards for Inspection and 
Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.  
These inspections differ from other OIG evaluations in that they support OIGs direct 
administration of the MFCU grant program, but they are subject to the same internal 
quality controls as are other OIG evaluations, including internal and external peer 
review. 
 
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PERFORMANCE ASSESSMENT 
In assessing the performance and operations of the Rhode Island Unit, we identified 
the Units case outcomes, evaluated whether the Unit complied with legal 
requirements, and assessed whether the Unit adhered to each of the 12 MFCU 
performance standards.  We identified seven findings and made several observations 
regarding the Units performance and operations, and we made seven 
recommendations for improvement. 
Case Outcomes 
Observation: The Unit reported 17 indictments; 6 convictions; and 33 civil 
settlements and judgments for FYs 20192021.  
All six convictions involved Medicaid provider fraud; none of the convictions involved 
patient abuse or neglect.  However, of the 17 indictments, 9 involved Medicaid 
provider fraud and 8 involved patient abuse or neglect. 
 
 
 
 
 
Observation: The Unit reported total recoveries of over $9.7 million for FYs 
20192021, which were primarily from global civil cases. 
 
 
 
 
 
 
 
 
 
 
Source: OIG analysis of Unit statistical data, FYs 20192021.   
Note: Global civil recoveries derive from civil settlements or judgments in global cases, which are cases that involve 
the U.S. Department of Justice and a group of State MFCUs and are facilitated by the National Association of Medicaid 
Fraud Control Units (NAMFCU). 
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Performance Standard 1: Compliance with Requirements 
A Unit conforms with all applicable statutes, regulations, and policy directives. 
Observation: From the data we reviewed, the Rhode Island Unit did not comply 
with one applicable legal requirement. 
We identified one compliance concern related to the Units reporting of convictions 
and adverse actions to Federal partners (see Performance Standard 8 finding). 
Performance Standard 2: Staffing 
A Unit maintains reasonable staff levels and office locations in relation to the 
States Medicaid program expenditures and in accordance with staffing allocations 
approved in its budget.  
Observation: The Office of the Attorney General eliminated two investigative 
positions from the Unit during the review period. 
Following a change in leadership at the Rhode Island Office of the Attorney General 
(OAG) in FY 2019, OAG eliminated two investigative positions from the Unit.  
Specifically, OAG did not retain the individual serving as the Units chief investigator 
and did not fill an investigative vacancy following the retirement of another Unit 
investigator.  Although the Unit promoted another Unit investigator to serve as chief 
investigator (renamed as the Supervisor of Investigations), a total of two positions 
were eliminated from the Units budget.  As a result, the Units approved staff size 
decreased from 12 to 10.   
Despite the elimination of investigative positions and turnover of other staff, the Unit 
retained several long-term investigators.  At the time of the inspection, the Units 
remaining five investigators had been employed by the Unit for periods ranging from 
6 years to over 16 years, with an average tenure of 11 years.20  Unit stakeholders 
identified the experience levels of the Units investigators as well as its attorneys as a 
strength of the Unit. 
Finding: The Supervisor of Investigations performed auditing duties and carried 
an investigative caseload in addition to his managerial responsibilities, which 
may have impeded the efficiency and effectiveness of the Units operations. 
Performance Standard 2(c) states that the Unit should employ an appropriate mix and 
number of professional staff that allows the Unit to effectively investigate and 
prosecute an appropriate volume of case referrals and workload for both Medicaid 
fraud and patient abuse and neglect. 21  Following OAGs removal of the Units 
previous chief investigator, one of the Units investigatorswho was also designated 
_____________________________________________________________________________________________________________________________ 
20 At the time of the inspection, the Unit had a vacant nurse investigator position, which the Unit was in 
the process of filling.  The Unit reported that it experienced difficulties in hiring and retaining nurse 
investigators because of relatively low salaries and a high demand for nurses. 
21 Additionally, 42 CFR  1007.13(a) requires a Unit to employ sufficient professional staff to carry out its 
duties and responsibilities in an effective and efficient manner. 
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as the Units auditorwas promoted to Supervisor of Investigations.  At the time of 
our inspection, the Supervisor of Investigations performed multiple duties within the 
Unit.  As a manager, he directly supervised all of the Units investigators; performed 
the initial assessment of all incoming referrals; and attended numerous meetings and 
maintained regular communication with Unit stakeholders.  In addition to his 
managerial responsibilities, the Supervisor of Investigations continued to serve as the 
Units auditor. 22, 23  He also carried an investigative caseload of five to six cases, 
including cases that were opened after he assumed his supervisory role.  He explained 
that when other investigators workloads were too high, he preferred to take a new 
case rather than add to another investigators workload.24      
The Supervisor of Investigations multiple duties within the Unit may have impacted 
the timeliness of his cases.  We did not observe that the additional duties inhibited 
the Supervisor of Investigations from fulfilling his managerial responsibilities, and he 
reported that he prioritized completing his daily managerial duties.  However, he 
acknowledged that he had concerns about the impact of his other duties on the 
timeliness of his own cases.  Additionally, a law enforcement partner who worked joint 
cases with the Unit suggested that the Supervisor of Investigations overall workload 
may have impacted the timeliness of some joint cases. 
In OIGs judgment, the multiple duties of the Supervisor of Investigationsserving as 
both the chief investigator and auditor, as well as investigating his own caseload
raise a concern that the Unit may not have the appropriate mix and/or number of 
professional staff to efficiently and effectively investigate its cases. 
Performance Standard 3: Policies and Procedures 
A Unit establishes written policies and procedures for its operations and ensures 
that staff are familiar with, and adhere to, policies and procedures. 
Finding: The Unit maintained a policies and procedures manual, but some parts 
of the manual lacked adequate guidance and some parts did not describe the 
Units current practices. 
Performance Standard 3(a) states that the Unit should have written guidelines or 
manuals that contain current policies and procedures.  The Unit maintained a policies 
and procedures manual, which was made available to staff in print and electronically.  
However, we found that the Unit did not have adequate policies and/or procedures 
for effectively maintaining case files (see Performance Standard 7, second finding).  
Additionally, the manual did not describe some of the Units current practices, 
_____________________________________________________________________________________________________________________________ 
22 42 CFR  1007.13(b)(2) requires Units to employ one or more experienced auditors.   
23 The Supervisor of Investigations and another investigator both performed auditing tasks for the Unit.  
However, the formal designation of these staff members as the Units auditor varied during the review 
period.  The Supervisor of Investigations was designated as the Units only auditor in FYs 2019 and 2021 
and at the time of the inspection.  In FY 2020, the other investigator was designated as the Units auditor. 
24 At the time of the inspection, line investigators reported that their caseloads were manageable, but 
that their workloads could vary. 
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including its practices for periodic supervisory reviews (see Performance Standard 7, 
third finding).  Finally, we found that other aspects of the Units policies and 
procedures manual were outdated.  For example, position descriptions and job duties 
described in the manual did not always reflect current job titles or duties, and the 
Units organizational chart did not accurately reflect the Units supervisory structure. 
Performance Standard 4: Maintaining Adequate Referrals 
A Unit takes steps to maintain an adequate volume and quality of referrals from 
the State Medicaid agency and other sources. 
Observation: The Unit took steps to maintain an adequate volume and quality of 
fraud and patient abuse or neglect referrals. 
Consistent with Performance Standard 4, the Unit took steps to encourage fraud and 
patient abuse or neglect referrals from key referral sources during the review period.  
At the time of our review, both the Office of Program Integrity (OPI) and the Unit 
reported that they maintained a strong working relationship with regular 
communication.  The Unit participated in monthly and quarterly meetings with OPI 
and MCOs, which also included OIG and other stakeholders.  These meetings were 
used to discuss active cases, and the Unit reported that these meetings were 
beneficial.  Specifically, the Supervisor of Investigations stated that because of these 
meetings, the Unit is aware of the investigations being conducted by MCOs and OPI; 
as a result, the Unit is informed of cases before it receives formal referrals. 
The Unit also maintained strong relationships with stakeholders that provide patient 
abuse or neglect referrals, including the State survey and certification agency, known 
as the Center for Health Facilities Regulation (CHFR), and the Department of 
Behavioral Healthcare, Developmental Disabilities, and Hospitals (BHDDH).  The Unit 
engaged in regular calls with CHFR and engaged in regular informal communication 
with both CHFR and BHDDH.   
Additionally, the Unit reported that it conducted outreach and provided training to 
nursing homes and other facilities.  The training covered pertinent laws and reporting 
requirements.   
During the review period, the Unit reported that it received 122 fraud referrals, of 
which 18 came from OPI.  Of the 18 referrals from OPI, the Unit opened 17 as cases.  
The Unit also received 374 patient abuse or neglect referrals during the review period, 
primarily from CHFR and BHDDH, and opened 36 as cases.  See Appendix A for all 
sources of referrals involving fraud and patient abuse or neglect during FYs 2019
2021. 
 
 
 
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Performance Standard 5: Maintaining Continuous Case 
Flow 
A Unit takes steps to maintain a continuous case flow and to complete cases in an 
appropriate timeframe based on the complexity of the cases. 
Observation: The Unit took steps to maintain a continuous case flow. 
Consistent with Performance Standard 5, the Unit reported that it took steps to 
maintain a continuous case flow, including frequent informal communication among 
Unit staff and supervisory reviews of cases.  The Director reported that due to the 
Units small staff size and the proximity of their offices, managers and other staff were 
able to discuss cases almost daily.  In interviews, many Unit staff identified this 
communication as a strength of the Unit, and Unit managers reported that this 
frequent communication benefited case flow. 
In addition to the strong communication, we found that Unit supervisors took 
appropriate steps to provide supervision of cases.  Performance Standard 5(b) states 
that supervisors should 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.  We 
found that the Units cases had supervisory approval to open, and nearly all (94 
percent) of the applicable case files contained documentation of supervisory approval 
to close the case.25  (See Appendix B for the point estimates and confidence intervals 
from our onsite review of case files.)  Further, Unit managers and other staff reported 
that the Unit regularly conducted supervisory reviews of case files.  Supervisory 
reviews were conducted in two separate group meetings, for fraud and for patient 
abuse or neglect cases.  The Units Director, attorneys, Supervisor of Investigations, 
and investigators attended these meetings and discussed updates regarding each 
case.  During the review period, supervisory reviews were initially conducted quarterly, 
then became monthly around June 2019, and then changed to bimonthly in June 
2021.  However, we found that these supervisory reviews were not consistently 
documented in case files (see Performance Standard 7, third finding).   
 
 
 
 
 
_____________________________________________________________________________________________________________________________ 
25 According to the Units policies, a case file is only created after a supervisor makes the determination 
to open an investigation; as a result, the Unit did not separately note supervisory approval to open a case 
in the case file. 
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Performance Standard 6: Case Mix 
A Units case mix, as practicable, covers all significant provider types and includes a 
balance of fraud and, where appropriate, patient abuse and neglect cases.  
Observation: The Units caseload included both fraud and patient abuse or 
neglect cases and covered a range of provider types. 
Of the 229 cases that were open during FYs 20192021, 78 percent (179 cases) 
involved provider fraud and 22 percent (50 cases) involved patient abuse or neglect.  
During this period, the Units cases covered 21 different provider types, including 
pharmaceutical manufacturers, personal care services attendants, and nurses. 
Performance Standard 7: Maintaining Case Information 
A Unit maintains case files in an effective manner and develops a case management 
system that allows efficient access to case information and other performance data. 
Finding: The Unit did not have an information management system with the 
functionality to manage and track case information from initiation to resolution, 
which posed challenges for monitoring cases and reporting case information 
and performance data. 
We found that the Units electronic case management system lacked the functionality 
to manage and track case information.  Performance Standard 7(e) states that the 
Unit should have an information management system that manages and tracks case 
information from initiation to resolution.  Unit staff reported that the Units electronic 
case management system was developed for use throughout OAG and was primarily 
designed to manage prosecutions.  Unit investigators reported that the system had 
limited functionalities for directly entering case information and that it was 
cumbersome to use during the investigative stage of a case.  Unit staff also reported, 
and we observed, that the system primarily served as a repository for case documents 
after the end of the investigative stage and lacked the functionality to generate 
performance data or other case status information that could aid Unit supervisors in 
managing and tracking cases.  At the time of the inspection, OAGs case management 
system had received a recent upgrade, but Unit staff expressed skepticism that the 
system could be modified to fully meet the Units needs.  However, following the 
inspection, Unit management reported that the Unit was working with OAGs 
contractor to determine whether the system could be modified to accommodate the 
needs of the Unit.   
As a result of the limitations of the electronic case management system, the Unit 
maintained documents and other case information (e.g., case types, current case 
statuses, and case outcomes) across several different repositories, none of which were 
individually capable of managing and tracking case information from the initiation of 
a case to its resolution.  The Unit stored investigative documents and case information 
on a shared network drive with folders for each investigator and in paper case files.  
Unit managers did not access investigators folders on the shared network drive, and 
in many cases, the paper files did not contain the full case information throughout an 
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investigation (see finding immediately below).  To track case information, the Unit 
used multiple spreadsheets that were manually maintained by different individuals 
and could not be automatically synchronized with information from other 
repositories.  The Units paralegal/case coordinator maintained a master list of cases 
which contained the status of each case (i.e., open or closed).  She also maintained 
spreadsheets for the purpose of tracking case outcomes.  Additionally, the Supervisor 
of Investigations maintained a separate spreadsheet of cases that he used for 
purposes of tracking open cases during supervisory review meetings.  See Exhibit 1 
for a summary of each repository.   
Exhibit 1: The Unit maintained five repositories for case information. 
 
Source: OIG analysis of interviews with Unit staff and OIGs observations during the onsite inspection. 
The Units limited electronic case management system, coupled with its different 
repositories for case information, also posed challenges for monitoring cases and 
reporting case information and performance data.  Performance Standard 7(f) states 
that the Unit should have an information management system that allows for the 
monitoring and reporting of case information.  The Units disjointed storage of case 
information across multiple repositories, including spreadsheets that could not be 
automatically synchronized to reflect current case information, may limit the Units 
capacity for accurately monitoring case information.  During our inspection, we 
identified multiple errors in a case list created from the paralegal/case coordinators 
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master list of cases, including cases with inaccurate closing dates.26  Under the Units 
system for storing case information, it was possible for a case to be closed in the 
paper case file but continue to be open on the master case list and in the electronic 
case management system, which may limit the ability of Unit managers to accurately 
monitor case information.  Further, Federal regulations require Units to report 
statistical information annually to OIG, including data on cases and case outcomes.27  
The Units paralegal/case coordinator completed this reporting task using her 
manually maintained spreadsheets, and in some instances, this required her to 
manually tabulate data.28  In our judgment, the inaccuracies we identified in the Units 
case list also highlight the potential for imprecise reporting to OIG.  Additionally, we 
found that this practice for compiling case information and performance data was 
highly inefficient; the paralegal/case coordinator stated that it takes her up to 4 weeks 
to assemble and submit the annual data required by OIG.  
In OIGs experience, and consistent with Performance Standard 7, a centralized case 
management system with the capacity to monitor cases and report case information 
and performance data efficiently and accurately is essential for the optimal operation 
of a Unit.   
Finding: The Unit did not have adequate policies or procedures, or consistent 
practices, for effectively maintaining case files. 
Performance Standard 7 states that a Unit should maintain case files in an effective 
manner.  However, we found that the Unit did not have procedures for organizing 
case information in an effective manner, which made it difficult to locate case 
information.  From interviews with Unit staff and our review of Unit case files, we 
found that the case files lacked consistent structure and organization, and some files 
contained duplicate documents.  We also found that case files lacked standardized 
formatting for routine case information.  The Units inadequate procedures for filing 
case information in a consistent manner made it difficult for us to locate and confirm 
the accuracy of significant reported dates and documents and to clearly understand 
the progression of the investigation in its entirety.   
Further, the Unit lacked effective procedures for maintaining case files across the 
Units multiple repositories, and staff did not follow consistent case file management 
practices.  Although the Units policies and procedures manual required investigative 
activities to be documented in the electronic case management system throughout an 
_____________________________________________________________________________________________________________________________ 
26 Prior to our onsite inspection, we requested from the Unit a list of all cases open at any point during 
the review period.  The Unit provided a list of cases which was created from the paralegal/case 
coordinators master list of cases; the electronic case management system did not have this reporting 
capability.  During our onsite review of case files, we found that five cases in our sample were not eligible 
for review due to inaccuracies in the case list provided by the Unit.  For example, our review of case files 
determined that some cases that were listed as being open during the review period were actually closed 
prior to the review period. 
27 42 CFR  1007.17(a)(2). 
28 For example, Units must report annual data on the provider types associated with each of their cases.  
The paralegal/case coordinators spreadsheets did not include specific provider type information for 
every case; as a result, she manually tabulated these data case by case. 
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investigation, this requirement was not always followed in practice.  Investigators 
reported that they typically did not upload case documents to the electronic case 
management system until the conclusion of the investigative stage of a case.  Instead, 
most investigators explained that they maintained case documents on the shared 
network drive or in paper case files during the investigative stage of a case, in part 
due to the limitations of the electronic case management system (see finding above).  
The Unit did not have policies or procedures for maintaining case files on the shared 
network drive or in paper case files.  Some investigators maintained paper case files 
throughout the investigative stage of a case, but other investigators added case 
documents from the shared drive to the paper file at the conclusion of the 
investigation.  In our opinion, the Units lack of effective procedures for storing case 
files across its multiple repositories may limit its capability to maintain cohesive case 
files at all stages of a case.  With the Units current practices, full case information for 
an ongoing investigation may not be available in one location for convenient access 
by supervisors or by another investigator (e.g., in the event of a case reassignment).  
Although the Units lack of a capable centralized case management system posed 
challenges for effectively maintaining case files, its inadequate procedures for 
documenting investigations in case files exacerbated these challenges.  Regardless of 
a Units case management system, establishing and following consistent policies 
and/or procedures for documenting investigations is important for ensuring that case 
information is organized and easily accessible.  However, these procedures are 
particularly important when case information is stored across multiple repositories. 
Finding: Sixty percent of applicable case files contained no documentation of 
periodic supervisory reviews, and the Units policies and procedures manual did 
not describe the Units current practices for periodic supervisory reviews. 
Performance Standard 7(a) states that reviews by supervisors should be conducted 
periodically, consistent with MFCU policies and procedures, and should be noted in 
the case file.  Although Unit managers and other staff consistently stated in interviews 
that the Unit conducted regular supervisory reviews of case files during the review 
period (see Performance Standard 5), these reviews were often not documented.  
Specifically, we found that 60 percent of applicable cases had no documentation of 
any supervisory reviews in the case file.29  This finding contrasts with OIGs 2014 
onsite review, which found that only 6 percent of case files contained no 
documentation of supervisory reviews.   
The Unit attributed the lack of documentation of supervisory reviews to an inability to 
document the reviews during the public health emergency, but our analysis also 
included the period outside of the public health emergency.  According to the Units 
policies and procedures manual, supervisory reviews should be documented using a 
log in the paper case file, but Unit managers stated that the logs could not be 
_____________________________________________________________________________________________________________________________ 
29 According to Unit managers, supervisory reviews during the review period were initially conducted 
quarterly, then became monthly around June 2019, and then changed to bimonthly in June 2021 (see 
Performance Standard 5).  We excluded from this calculation cases which were not open for at least one 
quarter, 1 month, or 2 months, as applicable. 
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updated during the period in which the Unit was working remotely due to the public 
health emergency (March 2020 through June 2021).  However, we found that 45 of 
the 48 applicable cases in our sample were eligible for one or more supervisory 
reviews before and/or after the 16-month period of remote work,30 and 60 percent of 
the 48 sampled cases contained no documentation of any supervisory review for the 
duration of the case.  Therefore, an inability to update the logs during the 16-month 
period of remote work did not explain the lack of documentation of any supervisory 
reviews for these case files before and after the public health emergency. 
Additionally, the Units policies and procedures manual did not describe the Units 
current supervisory review practices, nor did it require a specific frequency for the 
reviews.  While the manual stated that case progress should be reviewed 
periodically and documented by a supervisor, it did not describe the two separate 
supervisory review meetings that occurred bimonthly for fraud cases and for patient 
abuse or neglect cases (see Performance Standard 5) or which of the Units 
supervisors was responsible for documenting the reviews.    
Performance Standard 8: Cooperation with Federal 
Authorities on Fraud Cases 
A Unit cooperates with OIG and other Federal agencies in the investigation and 
prosecution of Medicaid and other health care fraud. 
Observation: The Unit maintained strong working relationships and investigated 
cases jointly with OIG and the U.S. Attorneys Office. 
During the review period, the Unit maintained an excellent working relationship with 
OIG and jointly investigated a total of 23 cases.  Unit management communicated 
regularly with OIGs Office of Investigations (OI), and Unit investigators maintained 
strong working relationships with OI agents.  One Unit investigator commented that 
OI agents are almost part of the office on a day-to-day basis.  Additionally, the Unit 
maintained a positive working relationship with the U.S. Attorneys Office in Rhode 
Island. 
Finding: The Unit did not consistently report convictions and adverse actions to 
Federal partners within the appropriate timeframes. 
Federal regulations require Units, for the purpose of excluding convicted parties from 
Federal health care programs, to transmit information on all convictions to OIG within 
30 days of sentencing, or as soon as practicable if the Unit encountered delays in 
receiving the necessary information from the court.31  During the review period, the 
_____________________________________________________________________________________________________________________________ 
30 Three of the 48 applicable cases in our sample were exclusively eligible for supervisory review during 
the period in which the Unit was working remotely (i.e., opened after February 2020 and closed prior to 
July 2021).  All of the 45 cases that were open before March 2020 and/or after June 2021 were open for a 
long enough period before and/or after the public health emergency that we would expect to see 
documentation of a supervisory review.   
31 42 CFR  1007.11(g), effective May 21, 2019.  Also, Performance Standard 8(f) states that Units should 
transmit convictions to OIG within 30 days of sentencing.  
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Unit did not submit four of its nine convictions to OIG within the 30-day timeframe.  
Regarding the Units other five convictions, staff reported that the Unit experienced 
delays in receiving the necessary information from the court, and that these cases 
were submitted as soon as practicable, as required. 
Federal regulations also require Units to report any adverse actions resulting from 
investigations or prosecutions of health care providers to the NPDB within 30 days of 
the final adverse action.32, 33  During the review period, the Unit reported all of its nine 
adverse actions to the NPDB more than 30 days after the final adverse action.   
In addition to delays in receiving necessary information from the court, the Unit 
reported that the reason for which submissions to OIG and the NPDB were delayed 
involved an internal misunderstanding among staff regarding the Units process and 
requirements for submissions.  At the time of the inspection, the misunderstanding 
had been addressed.   
Performance Standard 9: Program Recommendations 
A Unit makes statutory or programmatic recommendations, when warranted, to the 
State government. 
Observation: The Unit made recommendations to the State Medicaid agency 
during the review period. 
The Unit made recommendations to the State Medicaid agency pertaining to MCO 
referrals and MCO contracts.  The Unit requested that MCOs report suspected fraud 
simultaneously to both OPI and the Unit, and that this requirement be added to MCO 
contracts.  OPI agreed to this arrangement for referrals and reported that this 
language is in its operational procedures and will be included in future MCO 
contracts. 
 
 
 
 
_____________________________________________________________________________________________________________________________ 
32 45 CFR  60.5.  Examples of adverse actions include, but are not limited to, health care-related criminal 
convictions and civil judgments (but not civil settlements), and program exclusions.  See SSA  1128E(a) 
and (g)(1). 
33 The NPDB is intended to restrict the ability of physicians, dentists, and other health care practitioners 
to move from State to State without disclosure or discovery of previous medical malpractice and adverse 
actions.   
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Performance Standard 10: Agreement with Medicaid 
Agency 
A Unit periodically reviews its Memorandum of Understanding (MOU) with the 
State Medicaid agency to ensure that it reflects current practice, policy, and legal 
requirements. 
Observation: During the review period, the Units MOU with the State Medicaid 
agency did not reflect current practice and a legal requirement, but the MOU 
was subsequently amended in 2022 to generally reflect current practice, policy, 
and legal requirements. 
During the review period, the Unit had a MOU with EOHHS, which was executed in 
August 2016.  The MOU did not reflect current data mining practices and a recent 
legal requirement.  During the review period, the Unit and EOHHS established a data 
mining arrangement wherein the Unit has free access to data mining and associated 
training through EOHHSs vendor, but this practice was not described in the MOU.34  
Additionally, Federal regulations were amended in 2019 to require the Unit and the 
Medicaid agency to establish procedures in the MOU for the referral of potential 
fraud from MCOs.35  Although the Unit and OPI had established procedures for MCO 
referrals, those were not included in the MOU during the review period.  The Unit and 
EOHHS executed an amended MOU in November 2022 which remedied both of these 
deficiencies and generally reflected current practice, policy, and legal requirements.  
Performance Standard 11: Fiscal Control 
A Unit exercises proper fiscal control over its resources.  
Observation: From our limited review, we identified no deficiencies in the Units 
fiscal control of its resources. 
From the Units responses to a detailed fiscal controls questionnaire and follow-up 
with fiscal staff, we identified no issues related to the Units budget process, 
accounting system, cash management, procurement, electronic data security, 
property, or personnel.  In our inventory review, we accounted for 30 of the 30 
sampled inventory items.36 
 
 
_____________________________________________________________________________________________________________________________ 
34 Although this arrangement was not described in the MOU, the Unit provided to OIG a signed data 
mining agreement between the Unit, EOHHS, and the vendor as part of its application for renewal of its 
data mining waiver in FY 2020.  See 42 CFR  1007.20(a)(4)(iv). 
35 42 CFR  1007.9(d)(3)(iv). 
36 The Unit provided documentation showing that 6 of the 30 sampled items had recently been  
disposed of prior to our onsite inspection. 
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Performance Standard 12: Training 
A Unit conducts training that aids in the mission of the Unit.  
Finding: Although the Unit maintained an annual training plan for its staff, Unit 
supervisors did not track and verify that staff met training requirements. 
Performance Standards 12(a) and 12(b) state that the Unit should maintain a training 
plan for each professional discipline, and that the Unit should ensure that professional 
staff comply with the training plans and maintain records of this compliance.  We 
found that the Unit maintained a training plan requiring a minimum of 20 hours of 
training per fiscal year for professional staff, and professional staff attended trainings 
that aided in the mission of the Unit.  However, while the Unit maintained a list of 
trainings completed by each professional staff member for each fiscal year, Unit 
supervisors did not track or verify the number of training hours completed by staff.  In 
reviewing the Units training records, we found instances in which staff members 
appeared to complete fewer than 20 hours of training in a fiscal year.  At the time of 
our onsite review, the Director stated that the Unit would institute a policy of tracking 
training hours. 
Other Observation 
Observation: The Unit did not issue mobile phones to professional staff for 
business use. 
We found that professional staff in the Unit were not provided with business cell 
phones for use while outside of the office, as is standard among other MFCUs and law 
enforcement offices.  The Managing Attorney explained that the Units parent agency, 
the Rhode Island OAG, does not issue mobile phones to most staff.  In OIGs 
judgment, access to secure mobile phones is important for investigator safety and 
would improve the Units ability to efficiently investigate and prosecute cases. 
 
 
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CONCLUSION AND RECOMMENDATIONS 
The Rhode Island Unit reported 17 indictments; 6 convictions; 33 civil settlements and 
judgments; and over $9.7 million in recoveries for FYs 20192021.  From the 
information we reviewed, we observed that the Unit maintained strong working 
relationships and investigated cases jointly with OIG and the U.S. Attorneys Office.  
The Unit also took steps to maintain an adequate volume and quality of fraud and 
patient abuse or neglect referrals, including maintaining strong relationships with 
State partners.  However, we identified seven areas in which the Unit should improve 
its adherence to performance standards or program requirements.   
We made three findings related to the Units management of case files and case 
information.  First, we found that the Unit did not have an information management 
system with the functionality to manage and track case information from initiation to 
resolution, which posed challenges for monitoring cases and reporting case 
information and performance data.  Further, we found that the Unit did not have 
adequate policies or procedures, or consistent practices, for effectively maintaining 
case files.  We also found that 60 percent of applicable case files contained no 
documentation of periodic supervisory reviews, a large increase in case files with no 
such documentation from OIGs 2014 onsite review, and that the Units policies and 
procedures manual did not describe the procedures for or frequencies of supervisory 
reviews.    
We made four additional findings related to other aspects of the Units operations.  
We found that some parts of the Units policies and procedures manual lacked 
adequate guidance and some parts did not describe the Units current practices.  In 
addition, we found that the Supervisor of Investigations performed auditing duties 
and carried an investigative caseload in addition to his managerial duties, which may 
have impeded the efficiency and effectiveness of the Units operations.  We also 
found that the Unit did not consistently report convictions and adverse actions to 
Federal partners within the appropriate timeframes, as required by regulations.  
Finally, although the Unit maintained an annual training plan for its staff, we found 
that Unit supervisors did not track and verify that staff met training requirements. 
To address the findings identified in this report, we made the following 
recommendations to the Rhode Island Unit.  
 
 
 
 
 
 
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We recommend that the Rhode Island Unit: 
Assess whether the Office of the Attorney Generals case 
management system can be modified to fully meet the Units 
needs, and if appropriate, seek approval to implement its own 
case management system 
The Unit should evaluate whether the OAGs case management system, relied on by 
the MFCU, can be modified to meet the Units needs for a comprehensive system that 
allows for efficient access to case information and performance data.  If the system 
cannot be modified to fully meet the Units needs, the Unit should seek approval from 
OAG officials to implement a new case management system, an expense that would 
be eligible for 75-percent Federal financial participation.  While awaiting 
implementation of a modified or new case management system, the Unit should take 
steps to mitigate the shortcomings of the current case management system and to 
improve processes for monitoring cases and reporting case information and 
performance data.  These steps could include instituting a policy of regular internal 
audits of case files and case data to ensure that information is up to date and 
consistent across the Units multiple repositories of case documents and information. 
Establish policies and/or procedures to ensure that case files are 
maintained in an effective manner 
The Unit should establish policies and/or procedures for effectively organizing case 
files and for maintaining case files across the Units multiple repositories.  These could 
include developing a consistent format and organization for routine case information 
and specific timeframes for updating each repository throughout an investigation.  
The Unit should also take steps to ensure that staff consistently follow the policies 
and/or procedures for maintaining case files. 
Develop a plan to ensure that case files include documentation 
of periodic supervisory reviews and update the Units policies 
and procedures manual to describe the Units current practices 
for periodic supervisory reviews 
The Unit should develop a plan to ensure that supervisory reviews of Unit case files 
are documented in the Units case files.  The Unit should also include in its policies 
and procedures manual its current practices for conducting supervisory reviews, 
including the specific frequency for the reviews and which of the Units managers is 
responsible for documenting the reviews.   
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Update its policies and procedures manual to reflect current 
practices 
In addition to the updates to the Units policies and procedures manual 
recommended above, the Unit should update outdated information contained in the 
manual, including its job descriptions, job duties, and organizational structure. 
Assess the duties of the Supervisor of Investigations, and if 
warranted, develop a plan to reduce his nonmanagerial duties 
The Unit should assess whether the Supervisor of Investigations existing auditing and 
investigative responsibilities negatively impact the Units operations.  The assessment 
should consider the Supervisor of Investigations availability to provide timely 
auditing support and to investigate his own cases in a timely manner.  The Unit 
should also consider whether it has the appropriate mix and/or number of 
professional staff to efficiently and effectively investigate its cases.  The Unit should 
share its assessment with OIG, and if warranted, the Unit should propose a plan to 
reduce or eliminate the Supervisor of Investigations nonmanagerial duties. 
Take steps to ensure that convictions and adverse actions are 
reported to Federal partners within the appropriate timeframes 
The Unit should take steps to ensure that it consistently reports all convictions to OIG 
within 30 days of sentencing, or as soon as practicable if the Unit encounters court 
delays, and that it reports adverse actions to the NPDB within 30 days of the adverse 
action.  These steps could include developing a plan to ensure that, in the future, 
appropriate staff are aware of reporting requirements and the Units internal 
processes for submissions. 
Take steps to track and verify that Unit staff meet requirements 
in its training plan 
The Unit should implement procedures to track the number of training hours 
completed by professional staff each fiscal year.  Unit supervisors should verify that 
professional staff document and complete the minimum number of annual training 
hours in its training plan.  
 
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UNIT COMMENTS AND OIG RESPONSE 
The Rhode Island MFCU concurred with all seven of our recommendations.  
First, the Unit concurred with our recommendation to assess whether OAGs case 
management system can be modified to fully meet the Units needs, and if 
appropriate, seek approval to implement its own case management system.  The Unit 
reported that, since the time of the onsite inspection, it has initiated discussions and 
an internal evaluation with an OAG official to determine whether OAGs case 
management system could be modified to meet the Units needs.  The Unit indicated 
that depending on the functionality and cost associated with modifying the current 
system, OAG may also evaluate the possibility of acquiring a separate case 
management system for the Unit.  The Unit noted that OAGs ability to implement 
significant modifications to the existing case management system or to acquire a new 
system will depend upon the availability of State and Federal funding.  As noted in the 
recommendation above, this expense would be eligible for 75-percent Federal 
financial participation.  
Second, the Unit concurred with our recommendation to establish policies and/or 
procedures to ensure that case files are maintained in an effective manner.  The Unit 
reported that it is currently drafting a written policy for effectively organizing case 
files across the Units multiple repositories, including specifying a consistent format 
for routine case information and timeframes for updating each repository during an 
investigation. 
Third, the Unit concurred with our recommendation to develop a plan to ensure that 
case files include documentation of periodic supervisory reviews and update the 
Units policies and procedures manual to describe the Units current practices for 
periodic supervisory reviews.  The Unit reported that it recently created a written 
policy reflecting its current practice of conducting supervisory reviews of case files 
every two months.  The Unit indicated that the Director or the Supervisor of 
Investigations will consistently document in the case file that the investigation was 
discussed and outline the next steps in the investigation. 
Fourth, the Unit concurred with our recommendation to update its policies and 
procedures manual to reflect current practices.  The Unit reported that, since the time 
of the onsite inspection, it has updated its policies and procedures manual to reflect 
its current job descriptions, job duties, and organizational structure. 
Fifth, the Unit concurred with our recommendation to assess the duties of the 
Supervisor of Investigations, and if warranted, develop a plan to reduce his 
nonmanagerial duties.  The Unit reported that, since the time of the onsite inspection, 
it has reassigned the Supervisor of Investigations auditing duties to another staff 
member and has taken steps to more efficiently manage the referral intake process to 
reduce the burden on the Supervisor of Investigations.  The Unit indicated that it will 
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OEI-07-22-00370                                                                                                                 Unit Comments and OIG Response | 22    
also evaluate its operations to determine whether to seek approval for additional 
staff. 
Sixth, the Unit concurred with our recommendation to take steps to ensure that 
convictions and adverse actions are reported to Federal partners within the 
appropriate timeframes.  The Unit reported that, since the time of the onsite 
inspection, it has taken steps to improve its reporting to OIG and the NPDB.  The Unit 
also reported that it has memorialized these steps in a written policy which makes 
clear that all convictions and adverse actions must be reported to Federal partners 
within 30 days, or as soon as practicable. 
Seventh, the Unit concurred with our recommendation to take steps to track and 
verify that Unit staff meet requirements in its training plan.  The Unit reported that it 
drafted a written procedure to track and verify that Unit staff meet those 
requirements. 
We appreciate the steps the Unit has taken and plans to take to address the 
recommendations in the report.  We believe that these steps will improve the Units 
adherence to performance standards and program requirements and will strengthen 
its operations. 
For the full text of the Units comments, see Appendix C. 
 
 
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DETAILED METHODOLOGY 
Data Collection and Analysis 
We collected and analyzed data from the seven sources described below to identify 
any opportunities for improvement and instances in which the Unit did not adhere to 
the MFCU performance standards or was not operating in accordance with laws, 
regulations, or policy transmittals.  We also used the data sources to make 
observations about the Units case outcomes as well as the Units operations and 
practices concerning the performance standards.    
Review of Unit Documentation 
Before the onsite inspection, we examined the Units recertification materials for FYs 
20192021, including (1) the Directors recertification questionnaires; (2) the Units 
MOU with EOHHS that was in place during the review period and the MOU that was 
executed in November 2022; (3) the program integrity directors questionnaires; and 
(4) the OIG Special Agent in Charge questionnaires.  We also reviewed the Units 
policies and procedures manual and the Units self-reported case outcomes and 
referrals included in its annual statistical reports for FYs 20192021.  Additionally, we 
examined the recommendations from the 2014 OIG onsite review and the Units 
implementation of those recommendations.   
Review of Unit Financial Documentation 
We conducted a limited review of the Units control over its fiscal resources.  Before 
the onsite inspection, we analyzed the Units responses to a questionnaire about 
internal controls and conducted a desk review of the Units quarterly financial reports.  
We followed up with staff from OAG and the Unit to clarify issues identified in the 
questionnaire about internal controls.  We also selected a purposive sample of 30 
items from the Units inventory list of 67 items maintained in the Units office and 
verified those items onsite. 
Interviews with Key Stakeholders 
In June and July 2022, we interviewed key stakeholders, including officials in OPI, an 
MCO, BHDDH, CHFR, and the U.S. Attorneys Office.  We also interviewed a manager 
and a special agent from OIGs Office of Investigations who work with the Unit.  We 
focused these interviews on the Units relationship and interaction with the 
stakeholders, as well as opportunities for improvement.  We used the information 
collected from these interviews to develop subsequent interview questions for Unit 
management and other staff.   
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Onsite Interviews with Unit Management and Other Selected 
Staff 
We conducted structured interviews with the Units management and other selected 
staff in August 2022.  Of the Unit management, we interviewed the Director, the 
Managing Attorney, and the Supervisor of Investigations.  Of the other staff, we 
interviewed one attorney, four investigators, and the paralegal/case coordinator.  In 
addition, we interviewed the supervisor of the Unitthe Deputy Chief of the Criminal 
Division of OAG.  We asked these individuals questions related to (1) Unit operations; 
(2) Unit practices that contributed to the effectiveness and efficiency of Unit 
operations and/or performance; (3) opportunities for the Unit to improve its 
operations and/or performance; (4) clarification regarding information obtained from 
other data sources; and (5) the Units training and technical assistance needs. 
Onsite Review of Case Files 
To craft a sampling frame, we requested that the Unit provide us with a list of cases 
that were open at any time during FYs 20192021 and include the status of each case; 
whether the case was criminal, civil, or global; and the dates on which the case was 
opened and closed, if applicable.  The total number of cases was 232.  
We excluded all global cases from our review of the Units case files because global 
cases are civil false claims actions that typically involve multiple agencies, such as the 
U.S. Department of Justice and a group of State MFCUs.  We excluded 130 global 
cases, leaving 102 case files.  
We then selected a simple random sample of 56 cases from the population of 102 
cases.  This sample was selected to allow us to make estimates of the overall 
percentage of case files with various characteristics with absolute precision of no 
more than +/- 10 percent at the 95-percent confidence level.  However, during our 
onsite review of case files, we found that five cases in our sample were ineligible for 
inclusion in our review due to inaccuracies in the case list supplied by the Unit.  These 
five cases consisted of global civil cases that were mislabeled as nonglobal or cases 
that were found to be outside of the review period.  As a result, our effective sample 
size was reduced to 51 cases.   
We reviewed the 51 case files for adherence to the relevant performance standards 
and compliance with statutes, regulations, and policy transmittals.  During the review 
of the sampled case files, we consulted Unit staff to address any apparent issues with 
individual case files, such as missing documentation. 
Review of Unit Submissions to OIG and the National Practitioner 
Data Bank 
We also reviewed all convictions submitted to OIG during the review period (nine) 
and all adverse actions submitted to the NPDB during the review period (nine).  We 
reviewed whether the Unit submitted information on all sentenced individuals and 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection  
OEI-07-22-00370   Detailed Methodology | 25    
entities to OIG for program exclusion and all adverse actions to the NPDB for FYs 
20192021.  We also assessed the timeliness of the submissions to OIG and the NPDB.   
Onsite Review of Unit Operations 
During the onsite inspection, we observed the workspace and operations of the Units 
office in Providence.  We observed the Units office and meeting spaces; security of 
data and case files; location of select equipment; and the general functioning of the 
Unit. 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection  
OEI-07-22-00370   Detailed Methodology | 26    
APPENDICES 
Appendix A: Unit Referrals by Source for Fiscal Years 20192021 
 
FY 2019  FY 2020  FY 2021  3-Year Total 
Abuse or  Abuse or  Abuse or  Abuse or 
Referral Source  Fraud  Fraud  Fraud  Fraud  Total 
Neglect  Neglect  Neglect  Neglect 
Anonymous  2  0  3  3  1  3  6  6  12 
Center for Health 
Facilities Regulation  3  73  1  149  5  88  9  310  319 
(CHFR) 
Department of 
Behavioral Healthcare, 
Developmental  2  31  3  7  3  10  8  48  56 
Disabilities, and 
Hospitals (BHDDH) 
HHS-OIG  2  0  2  0  0  0  4  0  4 
Law enforcement
0  2  1  0  0  1  1  3  4 
other 
Long-Term Care 
0  0  0  0  1  0  1  0  1 
Ombudsman 
Managed care 
0  1  1  0  0  0  1  1  2 
organizations (MCOs)1 
Medicaid agency, 
Office of Program  6  0  1  0  11  0  18  0  18 
Integrity (OPI)1 
Private citizen  1  2  0  1  1  1  2  4  6 
Provider  0  1  0  0  0  0  0  1  1 
Provider association  0  1  0  0  0  0  0  1  1 
Other2  19  0  31  0  22  0  72  0  72 
Subtotal  35  111  43  160  44  103  122  374  496 
Total  146  203  147  496 
Source: OIG analysis of Unit Annual Statistical Reports, FYs 20192021. 
1 Most of the Units managed care referrals were received via OPI, rather than directly from MCOs.  Referrals from OPI include managed care 
referrals that originated from MCOs. 
2 The Unit indicated that Other referrals were primarily received from the National Association of Medicaid Fraud Control Units (NAMFCU).  
These were global civil cases received from the NAMFCU global case committee. 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection  
OEI-07-22-00370   Appendix A | 27   Appendix B: Point Estimates and 95-Percent Confidence Intervals of 
Case File Reviews 
95-Percent
Confidence Interval 
Estimate Description  Sample Size  Point Estimate  Lower  Upper 
Percentage of all cases closed at the time of OIGs 
51  72.55%  61.76%  81.37% 
review 
Percentage of all closed cases that had supervisory 
32  93.75%  81.37%  98.04% 
approval to close 
Percentage of eligible cases that contained any 
48  39.58%  28.43%  50.98% 
documentation of supervisory reviews 
Percentage of eligible cases that contained no 
48  60.42%  49.02%  71.57% 
documentation of supervisory reviews 
   Source: OIG analysis of Rhode Island MFCU case files, 2022. 
   Note: The 95-percent confidence intervals for these estimates exceed 10-percent absolute precision. 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection  
OEI-07-22-00370   Appendix B | 28  Appendix C:  Unit Comments
STATE OF RHODE ISLAND 
OFFICE OF THE ATTORNEY GENERAL 
150 South Main Street  Providence, RI 02903 
(401) 274-4400  www.riag.ri.gov 
Peter F. Neronha, 
Attorney General 
March 13, 2023 
Ms. Ann Maxwell 
Deputy Inspector General for Evaluation and Inspections 
Office of Inspector General 
Department of Health and Human Services 
Room 5660 Cohen Building 
330 Independence Avenue, SW 
Washington, DC 20201 
Via Email to: Susan.Burback@OIG.hhs.gov 
Re: Rhode Island Medicaid Fraud Control Unit: 2022 Inspection, OEI-07-22-00370 
Dear Deputy Inspector Maxwell: 
Thank you for sharing HHS-OIG's draft report, Rhode Island Medicaid Fraud Control 
Unit: 2022 Inspection, OEI-07-22-00370, dated February 10, 2023, The Attorney 
General has asked me to respond on his behalf to the information you provided, 
We appreciate the time that the Office of Inspector General (OIG) put h1to the review of 
our Medicaid Fraud Control Unit's (the Unit) operations and we share OIG's goal of 
ensuring that the Unit's activities are in compliance with the requirements of the 
program and any relevant policies and procedures. We thank the review team for 
recognizing that the MFCU maintains strong relationships with its State partners, has 
maintained an adequate volume and quality of case referrals, and has strong fiscal 
controls. 
We recognize that the review team identified certain areas of improvement for the Unit. 
As this letter will demonstrate, we share the review team's goals of improving the 
operations of the MFCU, and we are committed to meeting the highest standards of 
performance expected of the program.  As requested, this letter contains the Unit's 
response to the recommendations contained in the report. 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection
OEI-07-22-00370                                                      Appendix C | 29 RECOMMENDATION ONE: Assess whether the Office of the Attorney General's case 
management system can be modified to fully meet the Unit's needs, and if appropriate, 
seek approval to implement its own case management system. 
RESPONSE: The Unit Concurs with this recommendation. 
The Unit has already initiated discussions and an internal evaluation with the Deputy 
Director of Information Technology for the Attorney General's Office to determine 
whether the Office's CMS vendor could modify the Office's existing CMS system to meet 
the Unit's needs.  Depending on the functionality and cost associated with modification 
of our current CMS system, the Office may also evaluate acquiring a separate CMS for 
the Unit.  The Unit Director has also sought input from MFCUs in other states regarding 
the effectiveness of their case management systems.  The Office's ability to implement 
significant modifications to our existing CMS system, or acquisition of a new system, 
will of course depend on availability offederal and state funding. 
RECOMMENDATION TWO: Establish policies and/or procedures to ensure that case 
files are maintained in an effective manner. 
RESPONSE: The Unit concurs with this recommendation but does not 
concur with the finding that sixtypercent ofcase files did not contain 
documentation ofperiodic supervisory reviews. 
The Unit is currently drafting a written policy for effectively organizing case files in a 
consistent format and for maintaining case files across the Unit's multiple repositories. 
The new policy will have a consistent format for organization of routine case 
information as well as time frames for updating each repository during an investigation. 
The Unit met remotely, on a monthly basis, on all open investigations during the time 
period from March 2020 through June 2021, due to the public health emergency 
pandemic. When the Unit returned to in person work, in June 2021, the Unit changed 
the meetings to every two months. The Supervisors could not document the Supervisors 
review in the files because the Unit was working r.emotely.  Footnote 30, in HHS-OIG's 
draft report, appears to address this issue and states that 3 ofthe 48 applicable cases 
were exclusively open during the period in which the Unit was working remotely. 
However, all open investigations were reviewed while the Unit worked remotely, not just 
cases opened after February 2020 and closed prior to August 2021, as noted in footnote 
30. 
RECOMMENDATION THREE: Develop a plan to ensure that case files include 
documentation ofperiodic supervisory reviews and update the Unit's policies and 
procedures manual to describe the Unit's current practices for periodic supervisory 
reviews. 
RESPONSE: The Unit concurs with this recommendation. 
The Unithas a practice of meeting everytwo months, during which the Supervisors and 
Investigators review and discuss the status and next steps ofthe Unit's abuse 
2 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection
OEI-07-22-00370                                                   Appendix C | 30 investaingfrdaa tuiidno vness tiTghUaent hiiators ne sc.ec nrtelaywt reidtp toael ni cy, 
incliutndh eUedn i pto'lsia cnpidre osc emdaunrureaeslfl ,e tchtUein nipgtr 'asct ice. 
Durtihnegrs eevm ieeewt itnhges D,oi rSr uepcetroIvrn ivseisnwtgii clgolain tssotre ntly 
documietnnh ctea  fislete h tahtie n vestwiadgsia stciauonsnods u etldti hnneee  sxtte ps 
int hien vestigation. 
RECOMMENDFAOTUIUROp:N d aittpeso  liacnpidre osc emdaunrutearosl e  flect 
currpernatc tices. 
RESPONSET:h eU nicto ncuwrist thhi sr ecommendation. 
ThUen hiatus p daittpesod l iacnpidre osc emdaunrutearosle   flceuctr rjeonbt  
descrijpotbi odanunstod,ir  egsa,n isztartuicAotlnsulatr lwae iff.bl  epl r ovtihdee d 
manuaanwldi  dlolc umtehtnahtthe  ayrv eev iaenwader fadem  ilwiiaitrthA . nu  pdated 
manusahlob uecl odm plbeyMt aerd3c1 h2,0  23.
RECOMMENDFAITVIAEOs:Ns  tehsdesu  toitfeh sSe u perovIfin svoers taingidaf t ions, 
warradnetveeadpl ,lo tapron e  dhuicnseo  nmanadguet.ri ieasl  
.R ESPONSET:h eU nicto ncuwirtsh t hirse commendation. 
ThUen hiatas s sewshseetidhht ea trsh a ep propriateo pfmr ixo/fenssumstbiaeoffrn  al 
teoffi cieannetdffl eyc tiinvveelsiyttc isag saTethsUee.n   hiatr se asstihgen ed 
SuperIvnivseisntgai ugdaitdtouirtnt'igoSse  e sin oFrr aIundv estFiagtaAitsmoahar,s ,   
wealtsla  ksetnet pmoso  reeffi ciemnatnlatyghi een  tparkoecw ehsiwsci hil nlc rtheea se 
SuperovIfin svoerso tnai'vgsaa itlifoarob tihlmeiartn ya gdeurtiiWhaeillse i. mt a bye  
toloa itnte h biusd cgyecttlso ee  aedkd itFTiEosfon rFa Y2l 3 t, hOeffi cwei elvla liutast e 
operatthyiieostan dorse   terwmhienttehoa e sforkr a  dditFTiEosfon rFa Yl2  4t,o  
incluadnae d ditiinovneaslta iugdaiattnooodrrar/,t    toTrhneessyte.a  ffiandgd itions 
wiollcf,o  udrespee,on nGd e neArsasle ampbplyr oval. 
RECOMMENDSAITITXOa:Nk s et etpeosn  stuhrcaeot n viacntadid ovneasrc stei ons 
arree potrFote edde ralw iptathhreiat npn perrostp irmieafrtaem es. 
RESPONSET:h eU nicto ncuwrist thh irse commendation. 
ThUen hiatas l retaadksyet net pocs o rtrheteci tm ely orafed pvoearrctstietin toogh n es  
OIaGn NdP DBA.d ditiotnhUaenl hilatyms ,e  moritahlpiirsza ecidtan wi  rciet ten 
polwihciymc ahk celseth aaartl a ld vearcstemi uosnbtser   eporfetdeedpr aatrlot  ners 
wit3h0di any osra, ss  ooansp r acticable. 
RECOMMENDSAETVIEOTNNa: ks et etptosr  aacnvkde  rifyU ntsihttama teff e t 
requirieinmt tesrn atipsnl ianng.  
RESPONSET:h eU nicto ncuwirtsh t hirse commendation. 
ThUen hiatds r aftawe rdi tten tptorr oaaccnevkdde  urtrihefyUa  ntsi ttma effeth te  
requirietnmh Ueenn itttsr' asip nlianng.  
3 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection
OEI-07-22-00370    Appendix C | 31 As the newly appointed Director ofthe MFCU, I am committed to ensuring compliance 
with all regulations and recommendations as they pertain to the MFCU.  The Rhode Island 
Attorney General's Office looks forward to continued collaboration with HHS-OIG.  Please 
do not hesitate to contact me should you have any follow up questions. Thank you for your 
time and consideration. 
Sincerely, 
Gi,l\_~\AL, ~~~ 
, _,,,~1/,\k v--~C  \\,,  \.L 
Genevieve M. Allaire Johnson  \-
Director 
Medicaid Fraud Control and Patient Abuse 
Rhode Island Office ofAttorney General 
150 South Main Street 
Providence,RI 02903 
Cc Peter F. Neronha, Attorney General 
Adi Goldstein, Deputy Attorney General 
Stephen Dambruch, Criminal Division Chief 
4 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection
OEI-07-22-00370                                                                                             Appendix C | 32 ACKNOWLEDGMENTS AND CONTACT 
Acknowledgments 
Susan Burbach of the Medicaid Fraud Policy and Oversight Division served as the 
team leader for this study and Sarah Smith served as the lead analyst.  Others in the 
Office of Evaluation and Inspections who conducted the study include Jordan Swoyer.  
Office of Evaluation and Inspections headquarters staff who provided support include 
Robert Gibbons and Sarah Swisher.  
We would also like to acknowledge the contributions of two special agents from the 
Office of Investigations, and a peer reviewer from another State MFCU. 
This report was prepared under the direction of Brian Whitley, Regional Inspector 
General for Evaluations and Inspections in the Kansas City regional office, and Dana 
Squires and Abbi Warmker, Deputy Regional Inspectors General, as well as in 
consultation with Richard Stern, Director of the Medicaid Fraud Policy and Oversight 
Division. 
Contact 
To obtain additional information concerning this report, contact the Office of Public 
Affairs at Public.Affairs@oig.hhs.gov.  OIG reports and other information can be found 
on the OIG website at oig.hhs.gov. 
Office of Inspector General 
U.S. Department of Health and Human Services 
330 Independence Avenue, SW 
Washington, DC 20201 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection  
OEI-07-22-00370   Acknowledgments and Contact | 33   
ABOUT THE OFFICE OF INSPECTOR GENERAL 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 
95-452, as amended, is to protect the integrity of the Department of Health and 
Human Services (HHS) programs, as well as the health and welfare of beneficiaries 
served by those programs.  This statutory mission is carried out through a nationwide 
network of audits, investigations, and inspections conducted by the following 
operating components: 
The Office of Audit Services (OAS) provides auditing services for HHS, 
either by conducting audits with its own audit resources or by overseeing audit work 
done by others.  Audits examine the performance of HHS programs and/or its 
grantees and contractors in carrying out their respective responsibilities and are 
intended to provide independent assessments of HHS programs and operations.  
These audits help reduce waste, abuse, and mismanagement and promote economy 
and efficiency throughout HHS. 
The Office of Evaluation and Inspections (OEI) conducts national 
evaluations to provide HHS, Congress, and the public with timely, useful, and reliable 
information on significant issues.  These evaluations focus on preventing fraud, waste, 
or abuse and promoting economy, efficiency, and effectiveness of departmental 
programs.  To promote impact, OEI reports also present practical recommendations 
for improving program operations. 
The Office of Investigations (OI) conducts criminal, civil, and administrative 
investigations of fraud and misconduct related to HHS programs, operations, and 
beneficiaries.  With investigators working in all 50 States and the District of Columbia, 
OI utilizes its resources by actively coordinating with the Department of Justice and 
other Federal, State, and local law enforcement authorities.  The investigative efforts 
of OI often lead to criminal convictions, administrative sanctions, and/or civil 
monetary penalties. 
The Office of Counsel to the Inspector General (OCIG) provides 
general legal services to OIG, rendering advice and opinions on HHS programs and 
operations and providing all legal support for OIGs internal operations.  OCIG 
represents OIG in all civil and administrative fraud and abuse cases involving HHS 
programs, including False Claims Act, program exclusion, and civil monetary penalty 
cases.  In connection with these cases, OCIG also negotiates and monitors corporate 
integrity agreements.  OCIG renders advisory opinions, issues compliance program 
guidance, publishes fraud alerts, and provides other guidance to the health care 
industry concerning the anti-kickback statute and other OIG enforcement authorities. 
Rhode Island Medicaid Fraud Control Unit: 2022 Inspection  
OEI-07-22-00370   About the Office of Inspector General | 34