Department of Health and Human Services

OFFICE OF

INSPECTOR GENERAL

ADVERSE EVENTS IN 

REHABILITATION HOSPITALS: 

NATIONAL INCIDENCE AMONG 

MEDICARE BENEFICIARIES 

Daniel R. Levinson

Inspector General

July 2016

OEI-06-14-00110
EXECUTIVE SUMMARY: ADVERSE EVENTS IN REHABILITATION HOSPITALS: 

NATIONAL INCIDENCE AMONG MEDICARE BENEFICIARIES 

OEI-06-14-00110 

WHY WE DID THIS STUDY 

This report is part of a series on adverse events in healthcare settings, defined as harm resulting 

from medical care. Previous OIG work identified harm rates of about 30 percent in both acutecare hospitals and skilled nursing facilities (SNF), with an attendant toll on patient health and 

taxpayers’ costs, the latter amounting to billions of dollars annually. This report extends our 

work by evaluating care provided in rehabilitation (rehab) hospitals. Rehab hospitals are postacute providers that specialize in intensive rehabilitative care for patients recovering from illness, 

injury, or surgery. While in recent years stakeholders have paid considerable attention to patient 

safety in acute-care hospitals and increasingly in SNFs, less is known about adverse events in 

other health care settings. An increased understanding of adverse events that occur in this unique 

setting would better equip health care providers and other stakeholders in taking actions to 

improve the safety of patient care in rehab hospitals. 

HOW WE DID THIS STUDY 

We reviewed medical records to estimate the national incidence rate, preventability, and costs of 

adverse events in rehab hospitals. We reviewed a nationally representative sample of 

417 Medicare beneficiaries discharged from rehab hospitals in March 2012. 

WHAT WE FOUND 

An estimated 29 percent of Medicare beneficiaries experienced adverse or temporary harm

events during their rehab hospital stays, resulting in temporary harm; prolonged stays or transfers 

to other hospitals; permanent harm; life-sustaining intervention; or death. This harm rate is in 

line with what we found in hospitals (27 percent) and in SNFs (33 percent). Physician reviewers 

determined that 46 percent of these adverse and temporary harm events were clearly or likely 

preventable. Physicians attributed much of the preventable harm to substandard treatment, 

inadequate patient monitoring, and failure to provide needed treatment. Nearly one-quarter of 

the patients who experienced adverse or temporary harm events were transferred to an acute-care 

hospital for treatment, with an estimated cost to Medicare of at least $7.7 million in one month, 

or at least $92 million in one year, assuming a constant rate of hospitalization throughout the 

year.

WHAT WE RECOMMEND 

The incidence of adverse events in rehab hospitals is similar to that in acute-care hospitals and 

SNFs, as reflected in previous OIG findings, confirming the need and opportunity to 

significantly reduce the incidence of adverse events across health care settings. We recommend 

that the Agency for Healthcare Research and Quality (AHRQ) and the Centers for Medicare & 

Medicaid Services (CMS) raise awareness of patient safety issues in rehab hospitals and seek to 

reduce patient harm. This effort should include: (1) collaboration to create and disseminate a list 

of potential adverse events that occur in rehab hospitals and (2) the addition of information about 

potential adverse events in quality guidance to rehab hospitals. CMS and AHRQ concurred with 

our recommendations. 
 

TABLE OF CONTENTS

Objectives ....................................................................................................1

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

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

Findings........................................................................................................8

An estimated 29 percent of Medicare patients in rehab hospitals 

experienced adverse or temporary harm events...............................8

Forty-six percent of adverse and temporary harm events 

were preventable ...........................................................................11

Nearly one-quarter of the Medicare patients who experienced an 

adverse or temporary harm event in a rehab hospital were 

transferred to an acute-care hospital for treatment ........................12

Conclusion and Recommendations............................................................14

 Agency Comments and Office of Inspector General Response.....16

Appendixes ................................................................................................17

A: Methodology for Identifying Events and Determining 

Preventability .................................................................................17

B: Triggers Listed on the Trigger Tool Worksheet........................21

C: Estimates, Confidence Intervals, and Key Statistics................22

D: Rates of Adverse Events and Temporary Harm Events in 

Rehab Hospitals by Patient Days and by Admissions ...................24

E: Adverse Events and Temporary Harm Events Identified 

in the Sample..................................................................................25

F: Agency Comments....................................................................32

Acknowledgments......................................................................................35
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 1

OBJECTIVES

1. To estimate the incidence of adverse and temporary harm events for 

Medicare beneficiaries admitted to rehabilitation (rehab) hospitals for 

post-acute care. 

2. To assess the extent to which adverse and temporary harm events were 

preventable and identify contributing factors. 

3. To estimate the extent and cost of acute-care hospital admissions and 

emergency department visits that resulted from adverse and temporary 

harm events. 

BACKGROUND

Adverse Events in Health Care 

The term “adverse event” describes harm to a patient as a result of medical 

care, including the failure to provide needed care.1 An adverse event 

indicates that the care resulted in an undesirable clinical outcome not caused 

by underlying disease. Adverse events include medical errors and general 

substandard care that result in patient harm, such as infections caused by the 

use of contaminated equipment. However, adverse events do not always 

involve errors or poor quality of care and are not always preventable.2 

Office of Inspector General Reports on Adverse Events 

In a series of reports from 2008–2014, the Office of Inspector General 

(OIG) demonstrated that adverse events are common and costly to the 

Medicare program.3 In a 2010 study, OIG found that 27 percent of 

hospitalized Medicare beneficiaries experienced adverse or temporary 

harm events.4 Nearly half of the events were preventable, and care 

associated with events cost Medicare an estimated $4.4 billion a year. 

OIG also found that most hospital staff did not recognize or report patient 

harm when it occurred.5 In a 2014 study, OIG found that 33 percent of 

Medicare residents in post-acute Skilled Nursing Facility (SNF) stays 

____________________________________________________________ 

1

For the purposes of analysis in this report, we divide adverse events into two groups: 

adverse events and temporary harm events. We define temporary harm events as events that 

harmed patients and required medical intervention but did not cause lasting harm. 

2 R. M. Wachter, Understanding Patient Safety, Second Edition, McGraw-Hill, 2012, p. 17. 

3 OIG issued 11 reports regarding adverse events from 2008–2014, including reports about 

the incidence of adverse events, methods for identifying adverse events, hospital incident 

reporting systems, and public disclosure of event information. All reports are available at 

https://oig.hhs.gov/reports-and-publications/oei/a.asp#adverse_care. 

4 OIG, Adverse Events in Hospitals: National Incidence Among Medicare Beneficiaries, 

OEI-06-09-00090, November 2010. 

5 OIG, Hospital Incident Reporting Systems Do Not Capture Most Patient Harm, 

OEI-06-09-00091, January 2012. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 2

experienced adverse and temporary harm events.6 Over half (59 percent)

of these SNF events were preventable, and care associated with these 

events cost Medicare an estimated $2.8 billion in a single year. 

Post-Acute Care in Rehab Hospitals 

Rehab hospitals are independently run inpatient facilities that specialize in 

providing intensive rehabilitation therapy to patients recovering from 

illness, injury, or surgery.7 Patients entering rehab hospitals must be able 

to tolerate and benefit from at least 3 hours of therapy a day, 5 days a 

week.

8

 This limits the patient profile in these facilities to individuals who 

need and can tolerate a physically demanding therapy regimen following 

hospitalization. Commonly treated conditions in rehab hospitals include 

strokes, neurological disorders, and major lower extremity joint 

replacements (e.g., knee and hip replacements). Hospital-based 

rehabilitation units provide similar care and are reimbursed through the 

same prospective payment system but are managed as one part of a larger 

acute-care hospital. 

In fiscal year (FY) 2012, 234 rehab hospitals provided care to Medicare 

beneficiaries accounting for a total of $2.4 billion in Medicare spending. 

Table 1 compares rehab hospitals to other types of providers of post-acute 

rehabilitation services. The comparison is based on several metrics,

including the average amount reimbursed by Medicare per admission and 

the average length of stay. 

 Table 1: Medicare Services in Post-Acute-Care Providers (FY 2012) 

Total 

Number of 

Facilities

Total 

Number of 

Admissions

Average 

Length of 

Stay 

Average 

Reimbursement 

Per Admission

Rehab hospitals 234 139,526 13.0 days $17,164

Hospital-based rehab units 896 192,454 12.6 days $17,317

Long-term acute-care hospitals 420 140,463 26.2 days $39,493 

Home health agencies** 12,311 6.7 million 18.6 days $5,247 

SNFs 14,938 2.4 million 41.5 days* $12,329*

*These figures are the average of the top and bottom quartiles presented by Medicare Payment Advisorty 

Commission. 

**Figures for home health agencies are expressed by “episode of care” instead of by admission. 

Sources: Metrics for rehab hospitals and hospital rehab units are based on OIG analysis of Medicare claims data 

and metrics for other provider types are based on MedPAC, Report to the Congress: Medicare Payment Policy, 

March 2014.

____________________________________________________________ 

6 OIG, Adverse Events in Skilled Nursing Facilities: National Incidence Among Medicare 

Beneficiaries, OEI-06-11-00370, February 2014. 

7 A rehab hospital is eligible for Medicare payment through the Inpatient Rehabilitation 

Facility Prospective Payment System if it meets the criteria specified in 412.29, which 

includes a provision that at least 60 percent of a facility’s total inpatient population have one 

or more of 13 listed conditions.

8

 42 CFR § 412.622. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 3

Federal Efforts to Improve Quality and Safety in Rehab 

Hospitals

Accreditation and Routine Surveys. As it does for all other Medicare- and 

Medicaid-certified hospitals, the Centers for Medicare & Medicaid 

Services (CMS) oversees rehab hospitals’ compliance with a set of 

minimum quality and safety standards known as the Conditions of 

Participation (CoPs).9 Rehab hospitals may demonstrate compliance 

through accreditation by a Medicare-approved program or through 

periodic onsite surveys by a State survey agency.10 CMS provides 

guidance to these State agencies for conducting hospital surveys in its 

State Operations Manual (SOM), including guidance specific to the rehab 

setting.11 

Quality Assessment and Performance Improvement (QAPI). While many 

of the CoPs have an impact on quality, the QAPI CoP is the condition 

most explicitly focused on ensuring that facilities take actions to improve 

quality and safety.12 It requires rehab hospitals to “track medical errors 

and adverse patient events, analyze their causes, and implement preventive 

actions and mechanisms that include feedback and learning throughout the 

hospital.” To accomplish this, rehab hospitals must “measure, analyze, 

and track quality indicators, including adverse patient events, and other 

aspects of performance that assess processes of care, hospital service and 

operations.” 

Reporting of Quality Data. Congress established a quality reporting 

program for rehab hospitals and other post-acute-care providers in the 

2010 Patient Protection and Affordable Care Act (ACA).13 CMS refers to 

this program as the Inpatient Rehabilitation Facilities (IRF) Quality 

Reporting Program (QRP).14, 15 As part of the IRF QRP, CMS plans to 

adjust rehab hospital payment based on five quality measures, such as the 

percentage of residents with pressure ulcers that are new or worsened.16 

____________________________________________________________ 

9

The Secretary’s authority to establish the CoPs is at SSA, § 1861(e)(9). The current CoPs 

are defined at 42 CFR § 482. 

10 Social Security Act, §§ 1864 and 1865, 42 U.S.C. §§ 1395aa and 1395bb.

11 CMS, SOM, Appendix A - Survey Protocol, Regulations and Interpretive Guidelines for 

Hospitals, Pub. 100-07. 

12 42 CFR § 482.21. 

13 ACA, P.L. 111-148 § 3004(a); SSA § 1886(j)(7).

14 76 Fed. Reg. 47836, 47873–83 (Aug. 5, 2011). 

15 CMS, IRF Quality Reporting, October 24, 2014 update. Accessed at 

http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/IRFQuality-Reporting/ on October 29, 2014.

16 79 Fed. Reg. 45871, 45918 (Aug. 6, 2014). 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 4

In addition to the reporting required by the IRF QRP, the Improving 

Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) 

included new reporting requirements for post-acute-care providers, 

including rehab hospitals.17 Upon implementation, the IMPACT Act will 

require that rehab hospitals, along with other post-acute-care providers,

report data on falls resulting in injury, pressure ulcers, and other quality 

issues. 

METHODOLOGY

We estimated the incidence of adverse events (including temporary harm 

events) using a sample of Medicare patients who received inpatient care in 

rehab hospitals. Our study population was composed of Medicare 

beneficiaries discharged from rehab hospitals in March 2012. The 

beneficiaries were included only if a claim was submitted to Medicare and 

the stay began within 3 days of the beneficiary’s discharge from an acutecare hospital. 

We excluded beneficiaries who received care in hospital-based rehab units 

or through other post-acute-care providers. The hospital-based rehab units 

associated with the excluded beneficiaries in our sample constitute 80 

percent of IRFs.18 We chose to focus instead on the smaller number of 

independently run rehab hospitals in an effort to align our findings and 

recommendations with the unique situation of these providers, which may 

not have the same capacity to provide acute-level services and receive 

separate oversight by CMS. 

Sample Selection and Profile

Using Medicare claims data from the National Claims History (NCH) file, 

we selected a simple random sample of 417 Medicare beneficiaries out of 

the 12,328 beneficiaries who had rehab hospital stays that met the sample 

criteria defined above. Nine sample beneficiaries had two stays during 

March. In these cases, we reviewed both stays. As a result, the 417 

sample beneficiaries had 426 rehab hospital stays that ended in 

March 2012. The length of stay averaged 12.7 days.

Data Collection

We requested and received complete medical records for the sampled 

beneficiaries’ rehab hospital stays. As part of this request, we asked 

administrators from the rehab hospitals to provide discharge summaries 

and other key medical record documents from the acute-care hospital stays 

____________________________________________________________ 

17 IMPACT Act of 2014, P.L. 113-185 § 2(a), SSA § 1899B. The IMPACT Act has a 

phased implementation schedule, with full implementation for rehab hospitals expected 

by October 2018.

18 MedPAC, Report to the Congress: Medicare Payment Policy, March 2014, p. 243 – 244. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 5

that preceded the rehab hospital stays. We also requested discharge 

summaries and other key medical record documents for any acute-care 

hospital stay that occurred between the rehab hospital admission and 14 

days after discharge. In addition to collecting the medical records, we 

collected billing data for the rehab hospital stays and any associated 

payments to hospitals from Medicare inpatient and outpatient claims files.

Identification of Adverse and Temporary Harm Events. We conducted a 

two-stage medical record review to identify adverse events in the sampled 

records.19 The first stage was a screening process designed to identify 

beneficiaries who may have experienced an adverse event during their 

stay(s). During this stage, one of two registered nurses with extensive 

experience performing trigger tool reviews (referred to as “screeners”) 

reviewed the medical records of the sampled beneficiaries’ rehab and

acute-care hospital stays, as well as associated administrative data 

collected by OIG.20 The screeners flagged the records of 182 beneficiaries

who were likely to have experienced an adverse event. 

In the second stage, 1 or more of the 6 contracted physicians reviewed the 

medical records of the 182 beneficiaries flagged by screeners as likely to 

have experienced adverse events. The physicians examined the charts for 

possible adverse events and described these events using a structured data 

collection instrument. 

Data Analysis

We used the results of the review to generate estimates about adverse 

events in three categories: incidence of events, preventability of events, 

and Medicare cost associated with events. In addition to projected 

estimates, we described the sample when we had too few sample 

occurrences to make reliable projections. For more information on the 

estimates and corresponding 95-percent confidence intervals, see 

Appendix C. 

Event Incidence Analysis. To calculate incidence rates, we determined the 

percentage of sample Medicare rehab hospital patients who experienced at 

least one event (e.g., adverse event, temporary harm event) within the 

sample and projected the results to the population from which we selected 

the sample. 

Severity Analysis. The physician reviewers assigned each event to one of 

the five harm levels, using a modified version of the National 

Coordinating Council for Medication Error Reporting and Prevention 

____________________________________________________________ 

19 See Appendix A for a detailed description of the methodology used to identify adverse and 

temporary harm events. 

20 See Appendix B for a description of the tool the screeners used to review the records. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 6

(NCC MERP) Index. We make a distinction between “adverse events” 

(levels F-I on the index) and “temporary harm events” (level E on the 

index) to separate events that caused the most serious harm. Both groups 

represent harm to patients resulting from medical care or in a health care 

setting. (See Table 3.) 

Table 3: Modified Version of the NCC MERP Index for Categorizing Errors 

Used in the OIG Study of Adverse Events in Rehab Hospitals 

Level Description

Adverse 

Event

I Harm occurred that may have contributed to or resulted in patient death

H Harm occurred that required intervention to sustain the patient’s life

G Harm occurred that contributed to or resulted in permanent patient harm

F

Harm occurred that prolonged the stay or led to a transfer to a different 

rehab hospital, another post-acute facility, or an acute-care hospital for 

observation, emergency treatment, or inpatient care

Temporary 

Harm E Harm occurred that caused temporary harm that required intervention

Source: Modified version of the NCC MERP Index for Categorizing Errors, Medication Errors Council Revises 

and Expands Index for Categorizing Errors: Definitions of Medication Errors Broadened, Press Release, 

June 12, 2001.

Preventability Analysis. The physician reviewers also assigned each event 

to one of five preventability determinations—clearly preventable, likely 

preventable, unable to determine, likely not preventable, or clearly not 

preventable. We calculated percentages for each preventability 

classification and projected the results to the population from which we 

selected the sample. 

Medicare Cost Analysis. We conservatively estimated the amount 

Medicare paid for acute-care hospital stays and emergency department 

visits resulting from adverse events in rehab hospitals. We identified the 

Medicare cost of acute-care hospital stays and/or emergency department 

visits that occurred as a result of physician-identified adverse events. We 

projected this dollar amount to the population but present the lower bound 

of the 95-percent confidence interval associated with the cost estimate. 

We provide the conservative lower bound—instead of the point 

estimate—because the small number of sample occurrences made the 

point estimate unreliable. The actual amount paid by Medicare for 

adverse events in rehab hospitals is likely to be at least the value of the 

reported amount (the lower bound of the corresponding 95-percent 

confidence interval). Further, additional costs paid by Medicare or the 

beneficiary for followup care are not included. 

Limitations

The methodology presents several limitations. First, all findings related to 

identified events are limited to the population from which we selected the 

sample. Specifically, findings reflect only rehab hospital stays that ended 

in March 2012 and began within one day of the beneficiary’s discharge 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 7

from a hospital. Beneficiaries who received care in hospital-based rehab 

units are excluded.21 Second, it is unlikely that the study identified all 

adverse events within the sample of rehab hospital patients. To the extent 

that we did not identify all adverse events, omissions may be the result of 

incomplete documentation in the medical records or a failure of the 

reviewers to correctly identify the patient harm. Third, the cost estimate 

does not include all costs of care associated with adverse events, including 

additional care after the hospitalizations (such as physician office visits),

or increased payments to the rehab hospitals. 

Standards

This study was conducted in accordance with the Quality Standards for 

Inspection and Evaluation issued by the Council of the Inspectors General 

on Integrity and Efficiency. 

____________________________________________________________ 

21 Some rehab hospitals are co-located with an acute-care provider but are managed 

independently. These rehab hospitals were included in our sampling frame. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 8

FINDINGS

An estimated 29 percent of Medicare patients in rehab 

hospitals experienced adverse or temporary harm 

events

Approximately 3 in 10 Medicare beneficiaries who had rehab hospital 

stays that ended in March 2012 experienced at least one adverse or 

temporary harm event during their stays (29 percent).22 The events fall 

into two groups depending on the level of harm to the patient: adverse 

events and temporary harm events (see Table 4). 

Table 4: Number of Adverse and Temporary Harm Events within the 

Sample by Level of Harm 

Event Type Level of Harm on the Modified NCC MERP Harm Index Number within 

Sample (n=158)

Adverse 

Events

I-level: Contributed to or resulted in patient death 3

H-level: Required intervention to sustain the patient’s life 7

G-level: Contributed to or resulted in permanent patient harm 3

F-level: Resulted in prolonged rehab hospital stay or transfer 

to an acute-care hospital for observation, emergency 

treatment, or inpatient care.

33 

Temporary 

Harm Events

E-level: Harm occurred that caused temporary harm that 

required intervention 112

Source: OIG analysis of rehab hospital stays for 417 Medicare beneficiaries discharged in March 2012.

Ten percent of Medicare patients in rehab hospitals 

experienced adverse events

Ten percent of Medicare patients experienced adverse events during their 

stays in rehab hospitals. Adverse events caused harm that led to a 

prolonged rehab hospital stay or transfer to an acute-care hospital; caused 

permanent harm; required a life-sustaining intervention; or contributed to 

or resulted in death (i.e., equivalent to categories F–I on the modified 

NCC MERP Index). We estimate that 1,271 post-acute Medicare rehab 

hospital patients in our study population experienced at least one adverse 

event during their stays.

An additional 18 percent of Medicare patients in rehab 

hospitals experienced temporary harm events

Another 18 percent of Medicare patients experienced a temporary harm

event during their stays in rehab hospitals. Temporary harm events 

required medical intervention but did not prolong the stays, necessitate 

____________________________________________________________ 

22 The combined adverse event and temporary harm event rate (29 percent) exceeds the sum 

of the adverse event rate (10 percent) and temporary harm event rate (18 percent) because of 

rounding. For these and all other estimates presented in this report, see Appendix D for point 

estimates and confidence intervals. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 9

transfer to an acute-care hospital, or life-saving intervention, nor did it 

cause permanent harm or contribute to death (i.e., equivalent to E-level 

harm on our modified NCC MERP Index). We estimate that 2,247 postacute Medicare rehab hospital patients who did not experience an adverse 

event experienced at least 1 temporary harm event during their stays. 

Because these patients did not experience events causing harm equivalent 

to F – I on the harm index, they are not included in the adverse event rate. 

Less than 1 percent of Medicare patients in rehab hospitals 

experienced events that contributed to their deaths 

We estimate that 3 of 411 rehab hospital patients (0.7 percent) experienced 

adverse events that contributed to or resulted in their death. Two 

additional patients in our sample died during their stays, but those deaths 

were not associated with an adverse event. One adverse event that 

contributed to death involved a patient with cancer recovering in the rehab 

hospital from a recent cerebral hemorrhage. That patient experienced a 

central line-infection characterized by sepsis-like symptoms (i.e., 

hypotension and lethargy) that resulted in death. The physician review 

team determined that this event was likely preventable. In a second case, 

a patient recovering from a lymphoma-related shortness of breath and 

night sweats contracted pneumonia. The pneumonia was not initially 

recognized by staff and therefore the necessary treatment was delayed. 

Without timely treatment, the pneumonia led to sepsis along with severe 

hypotension that contributed to the patient’s death. The reviewers 

determined this event to be clearly preventable. The third event, 

determined to be clearly not preventable, involved an elderly patient who 

experienced partial paralysis and difficulty swallowing after a major 

stroke. A feeding tube was placed, but the patient experienced chronic 

aspirations. The aspirations led to pneumonitis and the family decided to 

withhold treatment and place the patient in hospice care. 

Less than 2 percent of Medicare patients in rehab hospitals 

experienced at least one “cascade” event, wherein multiple, 

related events occurred in succession

We estimate that 1.7 percent of rehab hospital patients experienced a 

“cascade” event. A cascade event is defined as a series of multiple, related 

adverse or temporary harm events that are considered a single event for 

the purpose of analysis. In one cascade event, a patient recovering from a 

knee arthroplasty (replacement) became severely dehydrated as a result of 

a newly acquired Clostridium difficile infection. The dehydration led to 

multiple, related events, including acute kidney injury, hyponatremia (a 

low sodium concentration in the blood), significant delirium, and 

metabolic acidosis (a pH imbalance caused by accumulation of acid). 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 10

Medication and patient care led to most harm affecting 

patients; infections were the least frequent cause of harm

Consistent with findings in previous OIG studies of adverse events, 

medication and patient care led to most of the adverse and temporary harm 

events affecting patients. The most frequent events within the sample 

were medication-induced delirium and pressure ulcers. Table 5 presents 

the percentage of events within each of three clinical categories and lists 

subcategories of events found within the sample.

 Table 5: Adverse and Temporary Harm Events by Clinical Category 

Adverse and Temporary Harm Events by Clinical Category Number of Sample 

Events within Category

Events Related to Medication* 46% (72)

Delirium or change in mental status due to medications 24

Hypoglycemic events related to medication 9

Hypotension secondary to medication 7

Constipation, obstipation, or ileus from medication 6

Allergic reaction to medication 5

Diarrhea secondary to medication 4

Excessive bleeding due to medication 4

Dehydration and related electrolyte disorders associated with medication 3

Nausea and vomiting secondary to medications 3

Thrush 3

Other 4

Events Related to Patient Care* 40% (63)

Pressure ulcer 14

Constipation, obstipation, or ileus 9

Skin tear, abrasion, or breakdown (other than pressure ulcer) 9

Exacerbations of preexisting conditions, including those resulting from omissions of 

care

8

Fall associated with patient care 6

Device trauma or malfunction 4

Dehydration and related electrolyte disorders associated with patient care 3

Venous thromboembolism, deep vein thrombosis (DVT), or pulmonary embolism (PE) 3

Allergic reaction to equipment (e.g., tape) 2

Edema or volume overload 2

Other 3

Events Related to Infections* 15% (23)

Catheter-associated urinary tract infection (CAUTI) 5

Soft tissue or other nonsurgical infection 4

Clostridium difficile infection 3

Surgical site infection (SSI) 3

Sepsis 2

Aspiration pneumonia and other respiratory infections 2

Other 4

*The sum of the percentages in this table exceed 100 percent because of rounding. See Appendix C for point estimates and 95-

percent confidence intervals. 

Source: OIG analysis of rehab hospital stays for 417 Medicare beneficiaries discharged in March 2012.
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 11

Forty-six percent of adverse and temporary harm 

events were preventable

Physicians determined that 46 percent of the adverse and temporary harm 

events combined were preventable, and 51 percent were not preventable. 

Physicians were unable to make determinations for the remaining events 

because of incomplete documentation or complexities in the patients’ 

conditions. Table 6 presents the percentage of events in each category of 

preventability. 

Table 6: Adverse and Temporary Harm Events by Preventability 

Determination 

Preventability Assessment Percentage 

of Events 

Preventable—Harm could have been avoided through improved assessment 

or alternative actions 46%

Clearly preventable 8%

Likely preventable 38%

Not preventable—Harm could not have been avoided given the complexity of 

the patient’s condition or care required 51%

Clearly not preventable 6%

Likely not preventable 46%

Unable To Determine Preventability 3%

As a result of rounding, subgroups for the ‘not preventable’ category do not total 51 percent. 

See Appendix C for point estimates and 95-percent confidence intervals.

Source: OIG analysis of rehab hospital stays for 417 Medicare beneficiaries discharged in March 2012.

When deciding whether an event was preventable, the reviewers consulted 

a list of contributing factors and selected the factors that best defined their 

rationale for the preventability determination. Table 7 (on the next page) 

provides the preventability rationales cited by the reviewers for all events 

in the sample. 

Among the preventable events for sampled rehab hospital patients, the 

reviewers frequently cited as factors the provision of appropriate treatment 

in a substandard way and failure to adequately monitor a patient’s 

progress. In one case of a preventable event, an elderly patient admitted to 

an rehab hospital after a stroke (a cerebrovascular accident, or CVA) and a 

recent diagnosis of hypertension experienced medication- related transient 

neurological symptoms (e.g., weakness and unsteady gait). The physician 

reviewer attributed these symptoms to an unnecessarily aggressive and 

poorly monitored use of an antihypertensive medication (amlodipine). 

The rehab hospital significantly increased the dose within 24 hours of 

starting the medication. The patient’s symptoms resolved after the rehab 

hospital staff reduced the dose of the antihypertensive. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 12

Table 7: Preventability Rationales for Adverse and Temporary Harm Events 

within Sample

Preventability Rationale (n=158) Number of Times 

Cited By Reviewers

Preventable Events

Appropriate treatment was provided in a substandard way 28

Error was related to medical judgment, skill, or patient management 23

The patient’s progress was not adequately monitored 18

Necessary treatment was not provided 17

Patient care plan was inadequate 17

Not Preventable Events

Patient was highly susceptible to event because of health status 48

Event occurred despite proper assessment and procedures followed 29

Patient’s diagnosis was unusual or complex, making care difficult 12

Care provider could not have anticipated event given information available 9

The counts in this table exceed the total number of events because the reviewers often gave multiple rationales.

Source: OIG analysis of rehab hospital stays for 417 Medicare beneficiaries discharged in March 2012.

Not preventable events often occurred with patients who were highly 

susceptible to a particular type of event or experienced the events despite 

staff efforts to avoid harm. In many of these cases, the reviewers noted 

that the clinicians in the rehab hospitals took reasonable precautions to 

prevent the event. In one case, a patient recovering from a stroke (a left 

side subcortical infarction with right-sided weakness) experienced 

permanent (G-level) harm after refusing to take prescribed medications 

(i.e., clopidogrel and enoxaparin sodium) that might have prevented a 

recurrent stroke. Without appropriate medications, the patient experienced 

an extension of the prior stroke, resulting in increased—and permanent—

right-sided weakness. The reviewers determined that in light of the 

patient’s decision, the event was not preventable by the staff. 

Nearly one-quarter of the Medicare patients who 

experienced an adverse or temporary harm event in a 

rehab hospital were transferred to an acute-care 

hospital for treatment

We estimated that 3,518 Medicare rehab hospital patients experienced at 

least 1 adverse or temporary harm event. Of these patients, an estimated 

828 (23.5 percent) went to an acute-care hospital for treatment as a result 

of the events. This includes both those admitted as inpatients and those 

who had outpatient emergency department visits only.23 These patients 

____________________________________________________________ 

23 Within the sample, there were 28 patients who had hospital admissions or emergency 

department visits. Twenty-five of these patients were admitted (some of the admissions 

followed an emergency department visit), and three were treated in the emergency department 

only. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 13

constitute 7 percent of all Medicare beneficiaries who had rehab hospital 

stays that ended in March 2012. 

We estimate that acute-care hospital admissions and emergency 

department visits resulting from adverse and temporary harm events for 

Medicare beneficiaries with rehab hospital stays ending in March 2012 

cost Medicare at least $7.7 million.24 Assuming that Medicare spending 

on hospitalizations due to adverse and temporary harm events in rehab 

hospitals remained constant throughout the year, Medicare inpatient 

expenditures would amount to at least $92 million annually.

25 These 

estimates do not include related costs paid by Medicare or other payers—

including beneficiaries—for followup medical care needed as a result of 

an event. 

____________________________________________________________ 

24 As noted in the methodology section of this report, we present the estimate of cost as the 

lower bound of the confidence interval. See Appendix C for the point estimate and 95-percent 

confidence intervals. 

25 The annual cost estimate of $92 million assumes that Medicare expenditures for adverse 

and temporary harm events in rehab hospitals remained constant at $7.7 million in each month 

of the year. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 14

CONCLUSION AND RECOMMENDATIONS

The findings in this report confirm the need and opportunity to 

significantly reduce the incidence of adverse events in rehab hospitals, 

thereby improving the quality of care that patients receive. Using the 

information presented in this report, health care providers and other 

stakeholders should take actions to further understand the causes of 

adverse events in rehab hospitals and reduce the incidence and impact of 

these events. We found that 29 percent of Medicare beneficiaries 

experienced adverse events or temporary harm events during their rehab 

hospital stays, resulting in temporary harm; prolonged stays or acute-care 

hospitalizations; permanent harm; life-sustaining intervention; or death. 

This harm rate is similar to those in our previous findings for hospitals 

(27 percent) and SNFs (33 percent). Forty-six percent of events in rehab 

hospitals were preventable, which is again similar to our previous results 

for hospitals (44 percent) and SNFs (59 percent). Hospitalizations 

necessitated by the events increased costs to Medicare by at least 

$7.7 million in a single month, or $92 million, annualized, in 2012, 

suggesting the opportunity for savings from reducing the incidence of 

adverse events that occur in rehab hospitals. 

The similarity of results across multiple health care settings suggests that 

research and interventions to reduce adverse and temporary harm events 

may be applicable across settings. In our prior reports on adverse events, 

we made a series of recommendations to AHRQ, the coordinating body 

for health care quality improvement, and to CMS, the largest health care 

payer and Federal overseer. In response, AHRQ and CMS expressed a 

commitment to implement our recommendations and pursue strategies to 

improve care. In this report, we recommend that AHRQ and CMS 

implement similar strategies for improved patient safety in rehab hospitals. 

AHRQ and CMS should raise awareness of adverse events in 

rehab hospitals and work to reduce harm to patients

In response to OIG recommendations in our earlier reports on adverse 

events in hospitals and SNFs, AHRQ and CMS began collaborating to 

create a list of potentially reportable adverse events to educate health care 

staff and to measure facility performance. CMS also began developing 

surveyor training to assist State survey agencies in assessing safety 

practices in SNFs; and, AHRQ and CMS worked to reconcile conflicts 

between the Patient Safety and Quality Improvement Act of 2005 and 

CMS’s QAPI requirements. Broadening these and other patient safety 

improvement efforts to include rehab hospitals would ensure that safe care 

practices promoted in acute-care hospitals and SNFs would extend to other 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 15

post-acute-care providers. Agency response to this recommendation 

should address the following two subrecommendations: 

 AHRQ and CMS should collaborate to create and promote a list of 

potential rehab hospital events – Staff identification of patient harm 

is critical to the success of patient safety efforts in rehab hospitals, 

giving staff the opportunity to correct problems and reduce harm, as 

well as report problems contributing to events. AHRQ and CMS 

should ensure that rehab hospital staff are able to identify a broad 

range of adverse and temporary harm events. Toward that end, AHRQ 

and CMS should collaborate to create and disseminate a list of 

potentially reportable events for rehab hospitals. The list should go 

beyond conventional post-acute-care issues (e.g., falls, pressure ulcers) 

and include a comprehensive range of possible patient harm, 

emphasizing the unique case mix in rehab hospitals and the 

rehabilitation needs of affected patients. Appendix E of this report 

provides descriptions of events such a list could include. The list may 

be extended to be consistent with the full body of research on this 

topic and should incorporate the unique challenges of this setting 

rather than duplicating lists of SNF or hospital events. 

 CMS should include information about potential events and 

patient harm in its quality guidance to rehab hospitals – To 

participate in the Medicare program, rehab hospitals must comply with 

the CoPs for hospitals, including requirements for a QAPI program to

improve facility performance. CMS reported to OIG in 2013 that it is 

testing draft interpretive guidelines for surveyors related to QAPI, 

including guidance for surveyors assessing facility efforts to improve 

patient safety. CMS should expand this effort to include information 

on potential events in rehab hospitals and continue to seek 

opportunities to provide patient safety guidance relevant to rehab 

hospitals. Guidance should include a definition of “adverse events;” a 

list of potential adverse events for staff education on the range of harm 

that patients can experience; strategies for detecting, measuring, and 

preventing adverse events; and, best practices for improving staff 

recognition and reporting of adverse events. Issuing similar guidance 

to rehab hospitals, acute-care hospitals, and SNFs may improve 

communication and collaboration regarding shared safety concerns 

and patient transitions among facilities. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 16

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE

CMS and AHRQ concurred with our recommendations. CMS responded that it will 

continue to collaborate with AHRQ and other partners to identify and address 

adverse events in rehab hospitals, including development of a list of potential rehab 

hospital events and expansion of the current QAPI guidance to include information 

specific to rehab hospitals. CMS also plans to look into using the Quality 

Improvement Organization Program to assist with quality improvement efforts in 

rehab hospitals. AHRQ responded that it will work with CMS to identify adverse 

events in rehab hospitals, as it has done for other healthcare settings. AHRQ also 

believes it would be helpful to review the types of events identified in this report to 

determine how they relate to the current AHRQ Common Formats. If AHRQ 

identifies a need, it will consider adding new event options in future updates to the 

Common Formats. We look forward to receiving updates from CMS and AHRQ 

regarding their progress in implementing these recommendations. Appendix F 

contains the full text of comments from both agencies.
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 17

APPENDIX A

Methodology for Identifying Events and Determining 

Preventability 

We conducted a two-stage medical record review to identify adverse and 

temporary harm events (for the purposes of this section, we refer to adverse 

events and temporary harm events as “events”). In the first stage, two 

registered nurses (referred to as “screeners”) identified sample beneficiaries 

who were likely to have experienced events during their rehab hospital stays. 

In the second stage, physicians reviewed the records for the subset of 

beneficiaries flagged by screeners as likely to have experienced events. 

Each record was reviewed by a screener and, if flagged, reviewed by a 

physician. 

Screening for Beneficiaries Who Likely Experienced Events. To identify 

beneficiaries who were likely to have experienced events during their stays, 

screeners reviewed complete medical records for the rehab hospital stays and 

other information in their records. The other information included discharge 

summaries, lab results, and other key documents from the medical records of 

the acute-care hospital stays that preceded the sampled stays. We also 

requested discharge summaries; history and physical examinations; and 

emergency department or observation unit medical records from any hospital 

stays or emergency department visits that followed the selected admission 

and occurred up to 14 days after discharge from the rehab hospital. In

addition, we reviewed the claims data for the preceding and subsequent 

hospital stays and emergency department visits. 

To standardize their reviews, we required screeners use a trigger tool to 

identify triggers in the medical record. The trigger tool was based on the IHI 

Global Trigger Tool (GTT) instrument and was modified for the post-acute 

rehab hospital environment. If screeners found a trigger, they explored the 

record further to determine whether events occurred and, if so, documented 

the level of harm. Of the 417 beneficiaries in the sample, screeners 

“flagged” 182 beneficiaries’ records (44 percent) for physician review. 

The screening process enabled us to reduce the number of cases requiring 

second-level review of the full medical records by a physician. As in the 

other OIG studies of adverse event incidence, physician reviewers indicated 

that the results of the screening methods helped them to readily identify 

potential events for consideration.

Physician Identification of Events within Flagged Rehab Hospital Records. 

One of 6 contracted physicians reviewed the medical records for each of the 

182 beneficiaries flagged in the initial screening. The physician reviewers 

represented a variety of specializations and experience: a 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 18

neurologist/physiatrist with experience as a medical director of a rehab 

hospital, an infectious disease specialist, a cardiologist, an orthopedic 

surgeon, an internal medicine specialist, and a geriatrician with extensive 

experience as a SNF medical director. All six had many years of clinical 

experience, and five had prior experience in detecting adverse events in 

retrospective medical record reviews. Four of the six served as physician 

reviewers for the 2010 OIG study of adverse events in hospitals, and five of 

the six served as physician reviewers for the 2014 OIG study of adverse 

events in SNFs.

To identify events experienced by patients during their stays, the 

physicians reviewed results of the screeners’ reviews as well as all the 

information made available to the screeners. In addition to reviewing 

records from the rehab hospitals, the physicians reviewed documents and 

data from any preceding and subsequent hospital stays to look for 

evidence of events that occurred during the rehab hospital stays. 

Over 10 weeks, physician reviewers examined the 191 records of the 

182 beneficiaries flagged by screeners. Physician reviewers used a 

structured medical review protocol that required them to describe each harm 

event and specify the level of harm experienced by the patient. Harm was 

categorized in accordance with a modified version of the NCC MERP Index 

of Categorizing Medication Errors (see Table 3).

We recorded all events that physician reviewers determined to be attributable 

to care provided during the rehab hospital stays. We excluded events that 

were part of the underlying disease process, occurred before the beneficiary 

entered the rehab hospital, or were attributable to the care provided in a 

preceding hospitalization. When an initial event caused a series of related 

and dependent events, we combined the events into a “cascade” event and 

counted it as a single event. When a patient experienced a specific type of 

event more than once during a stay (e.g., two episodes of hypoglycemia), we 

counted them as a single event if the second event occurred within 7 days of 

the first and occurred under the same circumstances. We counted them as 

separate events if the second event occurred more than 7 days after the first 

or if the circumstances that led to the event were substantially different. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 19

Determining Preventability for Each Event. Physician reviewers included an 

assessment of the extent to which events were preventable and factors that 

contributed to events. They used a five-point response scale, described in 

Table A-1. Assessing an event as clearly preventable or clearly not 

preventable required a greater degree of certainty on the part of the reviewer. 

Although the five-point scale enabled physicians to make more precise 

determinations, we collapsed the clearly and likely subcategories in our 

primary statistics. 

Table A-1: Preventability Scale for Categorizing Adverse Events 

Likelihood That Event Could Have Been Prevented:

Preventable

Events

Clearly Preventable—Patient harm could definitely have been avoided through 

improved assessment or alternative actions.

Likely Preventable—Patient harm could have been avoided through improved 

assessment or alternative actions.

Not 

Preventable

Events

Likely Not Preventable—Patient harm could not have been avoided given the 

complexity of the resident’s condition or the care required. 

Clearly Not Preventable—Patient harm could definitely not have been avoided 

given the complexity of the resident’s condition or the care required. 

Unable to 

Determine 

Events

Unable to Determine—Physicians were unable to determine preventability 

because of incomplete documentation or case complexity. 

Physician reviewers used a decision algorithm to improve consistency in 

making preventability determinations. We worked with the reviewers to 

develop the algorithm during practice reviews consisting of a series of 

questions that led the reviewers to a suggested response. Questions 

addressed issues such as whether there was a medical error, whether the 

event could have been anticipated, and how frequently the event occurs 

given proper care. Physicians did not automatically accept the suggested 

response, but determined whether it was appropriate in the particular case. 

To make distinctions about the circumstances in each case, physicians used 

their clinical experience and judgment. They considered all evidence in the 

medical records, including staff actions and the residents’ conditions. 

Physicians also used information about accepted standards of care, the 

frequency with which certain events occurred despite appropriate assessment 

and care, the physicians’ individual clinical experiences, guidance developed 

during the review process, and group discussion of cases. Using a list of 

contributing factors gleaned from prior research and experience in prior OIG 

studies of adverse event incidence, physicians indicated the rationale for 

each determination and provided a narrative description for each case.

Consistency Discussions and Review. Throughout our medical records 

review, we facilitated nine conference calls during which physician 

reviewers discussed the review protocol and sample cases that either were 

complex or had possible implications for other cases. The goal of these calls 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 20

was to reach consensus on difficult and complex cases and to establish 

consistency among reviewers. On the calls, physicians solicited the opinions 

of the other panelists to help make determinations on difficult cases. During 

the weekly conference calls, we required physicians to discuss all clearly 

preventable and clearly not preventable determinations and events that 

potentially contributed to a patient’s death, and we encouraged them to bring 

other cases for discussion if they had difficulty or felt the cases would 

inform other determinations. Physicians also often brought cases to group 

discussion if they involved care specific to another physician’s 

specialization. We documented the discussions and conclusions made during 

these weekly calls, continually revising a written physician guidance 

document to further promote consistency. Physicians reviewed or discussed 

the majority of the identified events as well as possible events, which the 

group ultimately determined did not meet the study threshold. 

Following the medical records review, we analyzed the identified events, 

harm-level determinations, and preventability determinations to identify any 

inconsistencies and discussed these with physician reviewers. This process 

resulted in changes to the initial determinations of some events. 
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 21

APPENDIX B

Triggers Listed on the Trigger Tool Worksheet 

Table B-1: Trigger Tool Worksheet 

Care Module Triggers Care Module Triggers (continued)

C1 Acute mental status change C26 Diagnostic radiology or imaging studies

C2 Aspiration C27 Care-Other

C3 Call to physician or family members Medication Module Triggers

C4

Code, Rapid Response Team (RRT), or Emergency 

Medical Services (EMS)

M1 Abnormal electrolytes

C5 Death M2 Abrupt medication stop

C6 Drop in hemoglobin/hematocrit M3 Anti-emetic use

C7 Studies for emboli, PE or DVT M4 Diphenhydramine (Benadryl) use 

C8 Fall M5 Elevated international normalized ration (INR)

C9 Family complaint M6 Glucose <50, Glucagon or Dextrose supplement 

C10 Any infection M7 Abrupt onset hypotension

C11 New or increased diuretics M8 Naloxone (Narcan) use

C12 High or low body temperature M9 Sodium Polystyrene (Kayexalate administration)

C13 Stroke or transient ischemic attack in rehab hospital M10 Abnormal drug levels

C14 New onset of incontinence M11 Thrombocytopenia

C15 Insertion or use of urinary catheter M12 Total WBC < 3,000 or >12,000

C16

Functional Independence Measure  [FIM score] 

decrease or no change from admission to discharge

M13 Vitamin K administration (Aqua-Mephyton)

C17 Resident incident or accident M14 Antibiotics started in the rehab hospital

C18 Pressure ulcer M15 Increasing pain medication needs

C19 Emergency department visit M16 Administration of parenteral fluid

C20

Transfer to acute-care hospital, observation unit, or 

unplanned transfer to another rehab hospital

M17 Medication-Other

C21 Restraint use Procedure Module Triggers

C22 Rising serum creatinine P1 Postoperative/post-procedure complication

C23 Urinary retention P2

Procedure reintubation/new Biphasic Positive Airway 

Pressure (BiPAP) / new Continuous Positive Airway 

Pressure (CPAP)

C24 New onset diarrhea P3 Procedure-Other

C25 Prolonged constipation 

Source: OIG, Adverse Events in Inpatient Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110).
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 22

APPENDIX C

Estimates, Confidence Intervals, and Key Statistics 

Table C-1: Beneficiary Level Estimates, Confidence Intervals, and Key Statistics 

Estimate Description

Sample 

Size (n) Percentage 

95-Percent 

Confidence Interval

Frequency 

95-Percent

Confidence Interval

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Event Experiences for All Beneficiaries

Experienced at least one adverse event 417 10.3% 7.8% 13.6% 1271 916 1626 1

Experienced at least one temporary 

harm event and did not experience an 

adverse event 

417 18.2% 14.8% 22.2% 2247 1796 2698 2

Experienced at least one adverse event 

or at least one temporary harm event 417 28.5% 24.5% 33.0% 3518 2991 4046 3

Experienced only preventable adverse 

and temporary harm events 417 15.1% 12.0% 18.8% 1863 1444 2281 4

Experienced only preventable adverse 

events 417 6.7% 4.7% 9.5% 828 535 1120 5

Experienced only preventable 

temporary harm events and no adverse 

events 

417 7.9% 5.7% 10.9% 976 660 1291 6

Experienced adverse events that 

contributed to death* 417 0.7% 0.2% 2.2% -- -- -- 7

Experienced transfer to an acute-care

hospital because of an adverse or 

temporary harm event

417 6.7% 4.7% 9.5% 828 535 1120 8

Experienced a cascade adverse event* 417 1.7% 0.8% 3.4% 207 57 357 9

Beneficiaries Who Experienced at Least One Adverse Event or One Temporary Harm Event

Experienced at least one transfer to an 

acute-care hospital that was the result 

of an adverse or temporary harm event 

119 23.5% 16.8% 31.9% 828 535 1120 10

* We are unable to reliably project the frequency estimates for this item because of the small number of sample occurrences.

Source: OIG analysis of rehab hospital stays and Medicare claims for 417 Medicare beneficiaries discharged in March 2012.

Table C-2: Estimates, Confidence Intervals, and Key Statistics

Estimate Description

Sample 

Size (n) Percentage 

95-Percent

Confidence Interval

Lower 

Bound

Upper 

Bound

Clinical Category for All Adverse and Temporary Harm Events

 Medication adverse and temporary harm events 158 45.6 % 37.9% 53.2% 11

 Patient care adverse and temporary harm events 158 39.9% 31.9% 47.8% 12

 Infection adverse and temporary harm events 158 14.6% 9.2% 19.9% 13

Preventability Classification for All Adverse Events and Temporary Harm Events

 Preventable adverse and temporary harm events 158 46.2% 38.0% 54.4% 14

o Clearly preventable adverse and temporary harm events 158 8.2% 3.7% 12.8% 15

o Likely preventable adverse and temporary harm events 158 38.0% 29.9% 46.1% 16

 Not preventable adverse and temporary harm events 158 51.3% 42.9% 59.6% 17

o Clearly not preventable adverse and temporary harm events 158 5.7% 2.2% 9.2% 18

o Likely not preventable adverse and temporary harm events 158 45.6% 37.7% 53.5% 19

 Unable to determine adverse and temporary harm events 158 2.5% 0.1% 4.9% 20

Source: OIG analysis of RH stays and Medicare claims for 417 Medicare beneficiaries discharged in March 2012.
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 23

Table C-3: Estimates, Confidence Intervals, and Key Statistics 

Estimates of Acute-Care Hospitalizations and Medicare Payments Associated 

with Adverse Events in Rehab Hospitals Total 

95-Percent

Confidence Interval

Lower 

Bound

Upper 

Bound

Acute-care hospitalizations associated with adverse and temporary harm events 887 564 1210 90

Medicare payment for acute-care hospitalizations associated with adverse events in RHs $16,325,640 $7,670,132 $24,981,147 88

Source: OIG analysis of rehab hospital stays and Medicare claims for 417 Medicare beneficiaries discharged in March 2012
 

Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries (OEI-06-14-00110) 24

APPENDIX D

Rates of Adverse Events and Temporary Harm Events in 

Rehab Hospitals by Patient Days and by Admissions 

Health care facilities commonly measure adverse events by incidence 

density, which takes into account the period during which patients are 

observed. For example, incidence density is often used in measuring 

healthcare-acquired infections because risk can increase with the length of 

exposure to the health care environment.26 IHI, a nonprofit advisory group 

to hospitals, cites advantages to using incidence density metrics over 

standard incidence rates that measure the number of events per patient.27

 

IHI reports that measuring total events by patient days or hospital 

admissions enables hospitals to count multiple events experienced by the 

same beneficiary. 

The sample of 417 Medicare beneficiaries discharged during 

March 2012 included 426 total rehab hospital stays and a combined total 

of 5,400 patient days in the facilities. We calculated patient days by 

subtracting the admission date for each rehab hospital stay from its 

discharge date. Table D-1 provides ratios for adverse events and 

temporary harm events in the sample per 1,000 patient days and per 100 

admissions.

Table D-1: Rates of Adverse and Temporary Harm Events in the Sample by 

Patient Days and Rehab Hospital Admissions

Category Per 1,000 

Patient Days

Per 100 

Admissions

Adverse events 9 11

Temporary harm events 21 26

Adverse and temporary harm events combined 29 37

Source: OIG analysis of rehab hospital stays for 417 Medicare beneficiaries discharged in March 2012

____________________________________________________________ 

26 K.M. Arias, Outbreak Investigation, Prevention, and Control in Health Care Settings, 

Second Edition, 2009, Jones and Bartlett Publishers, pp. 330–331.

27 IHI, IHI Global Trigger Tool for Measuring Adverse Events, Second Edition, 2009, p. 13.
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 25

APPENDIX E

Adverse Events and Temporary Harm Events Identified in the Sample 

Tables E-1 and E-2 contain information about adverse events and temporary harm 

events identified in the sample, including description, harm level, and 

preventability. Table E-1 contains information about adverse events 

(46 adverse events).28 Table E-2 contains information about temporary harm 

events (112 events). 

Table E-1: Adverse Events by Clinical Category, Harm Level, and Preventability (n=46) 

Adverse Event Harm 

Level Preventability

Adverse Events Related to Medication (18)

Delirium or change in mental status due to medications (5)

1. Multiple episodes of unresponsiveness secondary to benzodiazepine (clonazepam) and 

hypnotic (zolpidem) requiring an emergency reversal agent (flumazenil) H CP 28

2. Confusion and lethargy secondary to opioids (oxycodone and tramadol) that extended stay F LNP 30

3. Lethargy and syncopal episode secondary to opioid (hydrocodone/acetaminophen) resulting in 

transfer to an acute-care hospital F LP 47

4. Confusion and agitation secondary to opioids (oxycodone) resulting in transfer to an acute-care 

hospital F LNP 129

5. Cascade in which medication-induced confusion and agitation secondary to benzodiazepine 

(lorazepam) led to patient pulling urinary catheter with resultant injury and bleeding F LP 133

Excessive bleeding due to medication (3)

1. Bleeding from gastric ulcers secondary to anticoagulants (warfarin and aspirin) resulting in 

transfer to an acute-care hospital H CP 54

2. Gastrointestinal hemorrhage secondary to anticoagulants (dabigatran and aspirin) resulting in 

transfer to an acute-care hospital F CNP 73

3. Peri-incisional hematoma in thigh secondary to multiple anticoagulants (warfarin, aspirin, and 

enoxaparin sodium) F CP 121

Hypotension secondary to medication (3)

1. Hypotensive-event (syncope) secondary to beta-blocker used to treat multiple conditions,

including hypertension (metoprolol), resulting in transfer to an acute-care hospital F LP 86

2. Hypotension secondary to medication used to treat fluid retention (hydrochlorothiazide) F LNP 148

3. Orthostatic hypotension secondary to medication used to treat hypertension (hydralazine) F LP 161

Dehydration and related electrolyte disorders associated with medication (2)

1. Hyperkalemia secondary to diuretic and antihypertensive (spironolactone) H LP 63

2. Acute renal failure, hyperkalemia (high potassium), and dehydration secondary to diuretics

resulting in transfer to an acute-care hospital F CP 130

Diarrhea secondary to medication (2)

1. Diarrhea and dehydration secondary to antibiotics and resulting in transfer to an acute-care 

hospital F LNP 110

2. Diarrhea and dehydration from antibiotic F LNP 1003

Continued on next page.

____________________________________________________________ 

28 Patient harm is classified according to a modified version of the NCC MERP Index for Categorizing 

Errors (E–I) presented in Table 3. Preventability determinations were selected from the following 

options: CP for clearly preventable, LP for likely preventable, LNP for likely not preventable, CNP for 

clearly not preventable, and UTD for unable to determine.
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 26

Table E-1: Adverse Events by Clinical Category, Harm Level, and Preventability (n=46) 

(Continued) 

Adverse Event Harm 

Level Preventability

Adverse Events Related to Medication (18) (continued)

Nausea and vomiting secondary to medications (2)

1. Nausea, cramping, and vomiting due to medications given to treat constipation (magnesium 

hydroxide) and gastrointestinal symptoms (metoclopramide) resulting in transfer to an acute-care

hospital

F LNP 17

2. Nausea and vomiting due to opioid pain medication (hydrocodone) F LP 165

Hypoglycemic events related to medication (1)

1. Multiple, severe symptomatic hypoglycemic episodes characterized by a period of 

unresponsiveness and blood glucose of 29 resulting in transfer to an acute-care hospital H LP 25

Adverse Events Related to Patient Care (17)

Exacerbations of preexisting conditions and other deteriorating medical conditions (7)

1. Omission of care led to congestive heart failure exacerbation resulting in transfer to an 

acute-care care hospital F CP 40

2. Sudden onset of acute respiratory decompensation resulting in transfer to an acute-care hospital H LNP 55

3. Insufficient treatment of a preexisting left subcortical infarction due to patient refusing medication

led to an extension of the infarction resulting in transfer to an acute-care hospital caused in part

by patients refusal to comply with associated medication regimen

G LNP 56

4. Gastric ulcer found by esophagogastroduodenoscopy (EGD) while on aspirin and steroids F LNP 104

5. Cascade event in which failure to monitor progressive dysphagia led to dehydration resulting in 

transfer to an acute-care hospital related to poor transition of care with failure to provide BiPAP in 

patient with Obstructive Sleep Apnea

F LP 109

6. Cardiac arrest requiring Advanced Cardiovascular Life Support (ACLS) and transfer to 

acute-care hospital H CP 179

7. Acute change in motor function with worsening lethargy (possible CVA) resulting in transfer to an 

acute-care hospital F UTD 183

Dehydration and related electrolyte disorders associated with patient care (2)

1. Acute renal injury due to inadequate management of fluid intake resulting in dehydration and

transfer to an acute-care hospital F LP 58

2. Significant dehydration due to inadequate hydration resulting in hospitalization F CP 182

Pressure ulcer (2)

1. Progression of stage II pressure ulcer on buttocks to a stage IV pressure ulcer G CP 172

2. Progression of stage I pressure ulcer on heel to a stage IV ulcer G CP 177

Venous thromboembolism, DVT, or PE (2)

1. Common femoral vein DVT resulting in transfer to an acute-care hospital F LNP 80

2. DVT resulting in transfer to an acute-care hospital F LNP 125

Other patient-care events (4)

1. Allergic reaction (pruritus) to post-surgical tape F LNP 4

2. Cascade in which continuous passive movement (CPM) and anticoagulation (warfarin and 

enoxaparin sodium) led to bleeding and worsening contracture resulting in transfer to an acutecare hospital.F LP 21

3. Hemorrhagic cystitis in patient associated with Foley catheter and anticoagulant (warfarin) F LP 10

4. Dehiscence of surgical wound F UTD 93

Adverse Events Related to Infections or Antibiotics (11)

Catheter-associated urinary tract infection (CAUTI) (3)

1. Catheter-associated urinary tract infection (Escherichia coli) F LP 46

2. Catheter-associated urinary tract infection (Enterobacter) F LP 106

3. Catheter-associated urinary tract infection resulting in transfer to an acute-care hospital F LNP 107

Continued on next page.
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 27

Table E-1: Adverse Events by Clinical Category, Harm Level, and Preventability (n=46) 

(Continued) 

Adverse Event Harm 

Level Preventability

Adverse Events Related to Infections (11) (continued)

Clostridium difficile infection (2)

1. Clostridium difficile infection secondary to antibiotics F LP 35

2. Cascade event in which a Clostridium difficile infection (while being treated with ciprofloxacin) 

led to significant dehydration, acute kidney injury, hyponatremia, confusion, and metabolic 

acidosis resulting in transfer to an acute-care hospital

F LP 85

Sepsis (2)

1. Cascade event in which delayed recognition of pneumonia led to sepsis and then severe 

hypotension resulting in transfer to an acute-care hospital and finally death I CP 29

2. Cascade event in which a urosepsis (characterized by increasing confusion) developed into 

septic shock, which led to kidney failure and hypotension resulting in transfer to an acute-care 

hospital

H LP 160

Other infection adverse events (4)

1. Recurrent aspiration in post-stroke patient with feeding tube resulted in the patient's death I CNP 19

2. Peripherally inserted central catheter infection characterized by sepsis-like symptoms 

(hypotension, lethargy) resulting in transfer to an acute-care hospital and, finally, death I LP 84

3. Deep pelvic infection resulting in transfer to an acute-care hospital F LP 187

4. Cascade event in which aspiration pneumonia led to hypotension resulting in transfer to an 

acute-care hospital F LP 117

Source: OIG analysis of rehab hospital stays for 417 Medicare beneficiaries discharged in March 2012.
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 28

Table E-2: Temporary Harm Events by Clinical Category and Preventability (n=112)

Temporary Harm Event Preventability

Temporary Harm Events Related to Medication (54)

Medication-induced delirium or other change in mental status (19)

1. Confusion and disorientation from medication used to treat overactive bladder (oxybutynin) LNP 6

2. Multiple episodes of oversedation due to opioids in patient complicated by patient stealing and selfadministering additional medications LNP 8

3. Significant drowsiness and unresponsiveness secondary to antipsychotic (quetiapine) LNP 14

4. Significant confusion due to opioids (oxycodone/acetaminophen) LP 15

5. Multiple episodes of confusion secondary to opioids (oxycodone) and hypnotic (zolpidem) LNP 16

6. Multiple episodes of confusion and decreased cognitive performance secondary to opioids 

(hydromorphone) LNP 33

7. Significant lethargy secondary to antipsychotic (haloperidol) LP 45

8. Lethargy and anxiety secondary to antidepressant (serotonin antagonist and reuptake inhibitor (SARI)) LP 52

9. Confusion and lethargy secondary to opioid pain medication (hydrocodone/acetaminophen) LP 78

10. Delirium secondary to medication used to treat Parkinson's disease (carbidopa/levodopa) LNP 135

11. Lethargy and confusion secondary to multiple medications, including an opioid analgesic 

(hydrocodone/acetaminophen), an atypical antipsychotic (quetiapine), and a benzodiazepine 

(clonazepam).

LP 137

12. Weakness and imbalance secondary to medication used to lower blood pressure (amlodipine) LP 147

13. Lethargy secondary to opioid pain medications (hydromorphone and fentanyl) LNP 153

14. Lethargy secondary to opioid pain medication (hydromorphone) UTD 154

15. Lethargy, increased confusion and belligerence secondary to antihistamine (hydroxyzine) used to treat 

worsening of chronic dermatitis LNP 159

16. Hallucinations secondary to hypnotic (zolpidem) LP 164

17. Confusion secondary to benzodiazepine (alprazolam) LP 171

18. Lethargy secondary to opioid pain medication (oxycodone/acetaminophen) LP 173

19. Sedation and lethargy secondary to antianxiety medications (benzodiazepines) CP 175

Hypoglycemic events related to medication (8)

1. Asymptomatic hypoglycemia with a blood glucose of 47 LNP 31

2. Severe episode of hypoglycemia with a blood glucose of 25 LNP 37

3. Multiple episodes of asymptomatic hypoglycemia with blood glucose readings of 38 and 41 LP 57

4. Symptomatic blood glucose characterized by cold and clammy skin and a blood glucose of 47 LP 66

5. Asymptomatic hypoglycemic episode with a blood glucose of 39 LNP 74

6. Symptomatic hypoglycemic episode characterized by cold, clammy skin and lethargy and labile blood 

glucose with a blood glucose of 45 LNP 90

7. Symptomatic hypoglycemia characterized by blood glucose of 65 and nausea secondary to insulin 

management LNP 122

8. Asymptomatic hypoglycemia characterized by blood glucose of 44 secondary to insulin management LNP 167

Constipation, obstipation, and ileus from medication (6)

1) Significant and prolonged constipation due to pain medications LNP 9

2) Significant constipation secondary to opioid pain medication (hydrocodone/acetaminophen) LP 139

3) Significant constipation associated with post-surgery opioid pain medication (oxycodone) CNP 144

4) Significant constipation associated with post-surgery opioid pain medication (oxycodone) CNP 145

5) Significant constipation associated with post-surgery opioid pain medication 

(hydrocodone/acetaminophen) LNP 158

6) Constipation LNP 1002

Continued on next page.
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 29

Table E-2: Temporary Harm Events by Clinical Category and Preventability (n=112) (Continued)

Temporary Harm Event Preventability

Temporary Harm Events Related to Medication (54) continued

Allergic reactions to medications (5)

1. Allergic reaction to antibiotic LNP 111

2. Allergic reaction to antibiotic (nitrofurantoin) CP 120

3. Allergic reaction (rash) secondary to antibiotic (cephalexin) LNP 136

4. Allergic reaction (multiple episodes of itching) secondary to opioid pain medication (hydromorphone) CP 143

5. Allergic reaction (itching and hives) to melatonin CNP 166

Hypotension secondary to medication (4)

1. Orthostatic hypotension secondary to diuretic (furosemide) LP 61

2. Symptomatic bradycardia due to beta-blocker (metoprolol)-induced hypertension LNP 76

3. Orthostatic hypotension secondary to medication used to treat hypertension (hydralazine) LNP 87

4. Cascade event in which dehydration and medication used to treat hypertension (Lisinopril) led to 

hypotension and then acute kidney injury LP 156

Thrush (3)

1. Esophageal Candida infection secondary to antibiotics LNP 50

2. Esophageal Candida infection secondary to immunosuppressant (prednisone) used to treat inflammatory 

diseases LNP 114

3. Oral thrush CNP 151

Adverse reaction to medication (nonallergic or not otherwise specified) (2)

1. Excessive night sweats secondary to opioid pain medication (oxycodone) LNP 11

2. Irritation of larynx secondary to inhaler-delivered asthma medication (fluticasone/salmeterol) LNP 83

Diarrhea secondary to medication (2)

1. Multifactorial diarrhea secondary to antibiotics, stool softeners, and enteral feeding CNP 42

2. Significant diarrhea secondary to stool softener (docusate sodium) LP 62

Other medication temporary harm events (5)

1. Hyponatremia secondary to medication used to treat hypertension and congestive heart failure by treating 

fluid retention (hydrochlorothiazide) LP 150

2. Bleeding from surgical incision site with associated decreased hemoglobin secondary to anticoagulants 

(clopidogrel and rivaroxaban) LP 72

3. Fall associated with lethargy secondary to opioid (hydrocodone/acetaminophen) and opiate (morphine 

sulfate) pain medications LNP 79

4. Nausea and vomiting due to medications (pantoprazole) given to treat gastro esophageal reflux disease LP 67

5. Urinary retention secondary to antihistamine (diphenhydramine) LP 174

Temporary Harm Events Related to Patient Care (46)

Pressure ulcers (12)

1. Multiple, stage I pressure ulcers on sacrum, coccyx and buttocks LP 5

2. Stage I pressure ulcer on buttocks LP 24

Continued on next page.
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 30

Table E-2: Temporary Harm Events by Clinical Category and Preventability (n=112) (Continued) 

Temporary Harm Event Preventability

Temporary Harm Events Related to Patient Care (46) (continued) 

Pressure ulcers (12) (continued) 

3. Stage I pressure ulcer on heel LP 43

4. Progression of pressure ulcer from redness to excoriation with redness LNP 44

5. Unstageable pressure ulcer on rear of leg LNP 49

6. Stage I/II pressure ulcer on leg due to poor-fitting prosthesis LP 51

7. Progression of Stage I pressure ulcer on right heel to Stage II LP 69

8. Stage II pressure ulcer on buttocks LP 94

9. Stage I pressure ulcers on heels LP 108

10. Stage II pressure ulcer at coccyx LP 132

11. Stage I pressure ulcer on sacral coccyx LP 141

12. Unstageable pressure ulcer on heel (described as without breakdown) LNP 170

Constipation or obstipation from patient care (9)

1. Constipation with x-ray evidence of small bowel ileus during stay UTD 20

2. Symptomatic constipation and ileus secondary to inadequate bowel care LP 38

3. Symptomatic constipation and ileus characterized by nausea, vomiting, and abdominal distention LNP 82

4. Prolonged constipation secondary to inadequate bowel care LP 95

5. Significant constipation with impaction LNP 100

6. Symptomatic constipation with x-ray showing fecal stasis LNP 102

7. Significant constipation documented by abdominal x-ray LNP 105

8. Significant constipation with impaction CNP 116

9. Obstipation with impaction associated with inadequate bowel care LP 140

Skin tear, abrasion, or breakdown (other than pressure ulcer) and other minor skin event (8)

1. Skin tear with fungal infection that developed under brace LP 7

2. Skin abrasions on elbows and knees LNP 59

3. Rash on thorax, hip, and buttocks LNP 60

4. Skin tears on right elbow and buttocks LNP 103

5. Skin excoriation on buttocks LP 119

6. Excoriation on buttocks and scrotum attributed to medication-induced delirium and agitation LNP 134

7. Skin tears on legs LNP 138

8. Skin tear on leg LNP 184

Fall associated with patient care (6)

1. Fall with injury (bruising) to lower back and head LNP 53

2. Fall resulting in skin tear on left leg LNP 127

3. Fall with injury to nose (laceration) LNP 131

4. Fall with minor injuries to hip (pain) and head (temporal area swelling) LNP 142

5. Fall from bed with minor injuries (elbow, knees, and small skin tear) LP 162

6. Fall from wheelchair with minor injury to head and skin tear on knee LNP 176

Device trauma or malfunction (4)

1. Clotted arteriovenous shunt (dialysis access device) LP 34

2. Trauma due to multiple failed Foley catheter insertions LP 163

3. Hematuria secondary to intermittent catheterization LNP 185

4. Skin ulcer under head of penis due to intermittent urinary catheterization LNP 186

Continued on next page.
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 31

Table E-2: Temporary Harm Events by Clinical Category and Preventability (n=112) 

Temporary Harm Event Preventability

Temporary Harm Events Related to Patient Care (46) (continued)

Edema or volume overload (2)

1. Temporary edema at intravenous needle insertion site following blood infusion LNP 1

2. Volume overload manifested by shortness of breath and lower extremity pitting edema LP 23

Other patient care temporary harm events (5)

1. Allergic reaction (skin irritation) to medical adhesive tape LNP 146

2. Superficial burn on chest from hot beverage CNP 32

3. Mild renal impairment and dehydration related to fluid management and trimethoprim and 

sulfamethoxazole

LNP 128

4. Muscle strain with chest wall pain due to belt used in therapy LNP 81

5. Significant DVT in right lower extremity despite appropriate prophylaxis in patient with history of DVT LNP 112

Temporary Harm Events Related to Infections (12)

Soft tissue or other nonsurgical infection (4)

1. Yeast infection related to persistent moisture in the perineal area LP 68

2. Yeast infection and rash under breast LNP 75

3. Blisters and erythema on right thigh LP 126

4. Erythema of the scrotum LNP 169

Surgical site infection (SSI) (3)

1. Superficial infection that developed on existing wound site LP 3

2. Surgical site infection at site of hip surgery LP 71

3. Cellulitis on left leg LNP 96

Catheter-associated urinary tract infection (2)

1. Catheter-associated urinary tract infection (Citrobacter freundii) LNP 13

2. Catheter-associated urinary tract infection LNP 101

Other (3)

1. Clostridium difficile infection secondary to antibiotics LNP 64

2. Scabies (pruritic bumps on back and hand) LNP 115

3. Vaginal candidiasis LNP 1001

Source: OIG analysis of rehab hospital stays for 417 Medicare beneficiaries discharged in March 2012.
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 32

APPENDIX F

Agency Comments: Centers for Medicare and Medicaid Services 
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 33
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 34

Agency Comments: Agency for Healthcare Research and Quality 
 

Adverse Events in Inpatient Rehabilitation Facilities (OEI-06-14-00110) 35

ACKNOWLEDGMENTS

This report was prepared under the direction of Kevin K. Golladay, Regional 

Inspector General for Evaluation and Inspections in the Dallas regional office and 

Ruth Ann Dorrill, Deputy Regional Inspector General.

Amy Ashcraft and Jeremy Moore served as team leaders for this study. Other 

principal Office of Evaluation and Inspections staff from the Dallas regional 

office who contributed to the report include Maria Balderas and Nathan Dong. 

Central office staff who provided support include Heather Barton, Mandy Brooks, 

Evan Godfrey, Althea Hosein, and Joanne Legomsky.
Office of Inspector General

http://oig.hhs.gov 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95452, as 

amended, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of individuals served by those programs. 

This statutory mission is carried out through a nationwide network of audits, investigations, 

and inspections conducted by the following operating components: 

Office of Audit Services 

The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting 

audits with its own audit resources or by overseeing audit work done by others. Audits 

examine the performance of HHS programs and/or its grantees and contractors in carrying 

out their respective responsibilities and are intended to provide independent assessments of 

HHS programs and operations. These assessments help reduce waste, abuse, and 

mismanagement and promote economy and efficiency throughout HHS. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 

HHS, Congress, and the public with timely, useful, and reliable information on significant 

issues. These evaluations focus on preventing fraud, waste, or abuse and promoting 

economy, efficiency, and effectiveness of departmental programs. To promote impact, OEI 

reports also present practical recommendations for improving program operations. 

Office of Investigations 

The Office of Investigations (OI) conducts criminal, civil, and administrative investigations 

of fraud and misconduct related to HHS programs, operations, and individuals. With 

investigators working in all 50 States and the District of Columbia, OI utilizes its resources 

by actively coordinating with the Department of Justice and other Federal, State, and local 

law enforcement authorities. The investigative efforts of OI often lead to criminal 

convictions, administrative sanctions, and/or civil monetary penalties. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to 

OIG, rendering advice and opinions on HHS programs and operations and providing all 

legal support for OIG’s 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.