Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

JULY 2000 

OEI-05-99-00072 

MEDICAID 

Post Payment Safeguards 
OFFICE OF INSPECTOR GENERAL 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, is to 

protect the integrity of the Department of Health and Human Services programs as well as the 

health and welfare of beneficiaries served by them. This statutory mission is carried out through a 

nationwide program of audits, investigations, inspections, sanctions, and fraud alerts. The 

Inspector General informs the Secretary of program and management problems and recommends 

legislative, regulatory, and operational approaches to correct them. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) is one of several components of the Office of 

Inspector General. It conducts short-term management and program evaluations (called 

inspections) that focus on issues of concern to the Department, the Congress, and the public. The 

inspection reports provide findings and recommendations on the efficiency, vulnerability, and 

effectiveness of departmental programs. 

OEI's Chicago Regional Office prepared this report under the direction of William C. Moran, 

Regional Inspector General and Natalie A. Coen, Deputy Regional Inspector General. Principal 

OEI staff included: 

REGION HEADQUARTERS 

John M. Traczyk, Project Leader Jennifer Antico, Program Specialist 

To obtain copies of this report, please call the Chicago Regional Office at 312-353-4124. 

Reports are also available on the World Wide Web at our home page address: 

http://www.hhs.gov/oig/oei/ 
<

<

EXECUTIVE SUMMARY 

PURPOSE 

This is the last of three reports describing Medicaid program safeguards. This report 

discusses post payment safeguards. The first report discusses proactive safeguards and 

the second describes claim processing safeguards. This report is intended to provide 

information about and increase awareness of Medicaid post payment safeguards. Post 

payment safeguards ensure that claims have been properly processed and adjudicated. 

POST PAYMENT SAFEGUARDS 

Remittance Notices furnish providers with information about services billed to Medicaid

using their name and provider number. Medicaid providers are asked to report any

discrepancies. Unfortunately, remittance notices are sometimes diverted to billing

companies or persons unknown to the provider.

Explanation of Benefits are sent to select Medicaid patients. They provide patients with

information about providers who billed Medicaid for services provided to them. Patients

are asked to verify that they have used or received the services billed to Medicaid.

Post Payment Reviews/Audits and Sampling are used to measure claim payment

accuracy, identify incorrectly paid claims, identify problematic policies and procedures and

provide feedback on the effectiveness of proactive and claims processing safeguards. 

Allegations of Fraud and Abuse are handled differently by each State we visited. 

Information is not uniformly captured; therefore, comparing data on Medicaid fraud and

abuse efforts is difficult. 

Payment Error Rates are used by some States to identify policy vulnerabilities and claims

processing vulnerabilities. 

OPPORTUNITIES FOR IMPROVEMENT 

Based on our prior studies and information gathered during this study, we encourage 

States to consider the following opportunities for improving program safeguards: 

< Improve provider remittance notice procedures. Current procedures do not 

always ensure that providers receive remittance notices. Some States believe that 

some remittance notices are diverted to third parties and never seen by the 

provider whose billing number was used to generate the claim. 

< Improve provider education. Every provider should understand that they will be 

held financially (and, in some cases, criminally and civilly) liable for any Medicaid 

program financial losses stemming from misuse of their provider number. 

Post Payment Safeguards 1 OEI-05-99-00072 
<

<

< Use valid sampling techniques to improve post payment audits. Using valid 

sampling enables States to accurately project the total payment error and 

overpayments made to a provider. 

< Ensure that some providers selected for post payment review are chosen at 

random. Random selection can have a deterrent effect on fraudulent and abusive 

billing and enables States to identify problematic providers who have circumvented 

their program safeguards. 

< Document educational contacts stemming from post payment audits. 

Recording education contacts helps establish that a provider have been made 

aware of unacceptable billing practices. 

< Improve their surveillance of providers found to have billing problems. 

States should verify that a provider has corrected unacceptable billing practices 

and has not simply found a way to circumvent Medicaid safeguards. 

< Work with Health Care Financing Administration (HCFA) to establish 

uniform definitions for audits, edits, reviews, claim counts, rejects, etc.. 

Clarifying these terms should allow the States and HCFA to compare and contrast 

efforts in safeguarding Medicaid. 

< Improve the handling of fraud and abuse allegations. Their should be written 

procedures for uniform handling of suspected fraud and abuse situations identified 

by Medicaid employees and subcontractor employees. 

< Develop training to help their employees and subcontractors identify 

potential fraud and abuse issues. Training would help ensure proper disposition 

and handling of allegations and help ensure proper referral of cases for in depth 

investigation. 

< Collect better data on payment error rates. Error rate data can be used to 

identify and address problematic providers, poor policies and vulnerable 

procedures. 

We intend to do additional in depth studies on post payment safeguards used by States. 

AGENCY COMMENTS 

The HCFA believes that the opportunities for improvement described in this report provide 

valuable information that will be shared with the State Medicaid programs. 

Post Payment Safeguards 2 OEI-05-99-00072 
TABLE OF CONTENTS 

PAGE 

EXECUTIVE SUMMARY

INTRODUCTION ..................................................... 4

POST PAYMENT SAFEGUARDS ........................................ 6

Remittance Notices ................................................... 6

Explanation of Benefits ................................................ 7

Post Payment Reviews/Audits ........................................... 7

Sampling Methodologies 

Provider Education 

Verification of Compliance 

Allegations of Fraud and Abuse ........................................ 10

Payment Error Rates ................................................. 10

OPPORTUNITIES FOR IMPROVEMENT ................................. 12

AGENCY COMMENTS ................................................ 14

APPENDIX A ....................................................... 15

Post Payment Safeguards 3 OEI-05-99-00072 
INTRODUCTION 

PURPOSE 

To provide information about and increase awareness of Medicaid post payment 

safeguards. 

BACKGROUND 

Medicaid is a health insurance program for certain low income and needy people. Within 

Federal limits, each State decides eligibility, benefit coverage, administrative practices, 

reimbursement and operational resource requirements. About 70 cents of every Medicaid 

dollar goes to institutional providers (hospitals, nursing homes). Thirty cents pays for 

non-institutional services (physician services, laboratory and radiology). Federal law 

requires States to pay for services provided by certain institutional providers and noninstitutional providers. State may elect to offer additional services such as dental care, 

podiatry care and prescription drugs just to name a few. 

The Health Care Financing Administration (HCFA) is responsible for administering 

Federal matching funds to the States and for legislation and regulations affecting Title 

XIX (commonly referred to as the Medicaid program). The HCFA also provides 

guidelines, technical assistance and periodic assessments of State programs. More than 

36 million recipients are enrolled in Medicaid. In 1991, 90 percent of these recipients 

were enrolled in fee-for-service (FFS) programs. By 1998, the number of recipients in 

FFS had decreased to 46 percent and enrollment in managed care plans increased to nearly 

54 percent. Nearly $169 billion was spent by the Federal Government and the States on 

Medicaid benefits in Fiscal Year 1998. 

States are required by legislation to make every effort to eliminate waste and illegitimate 

program expenditures. States are required to develop payment safeguards designed to 

protect their Medicaid funds from unscrupulous and fraudulent providers. 

Post Payment Safeguards 4 OEI-05-99-00072 
METHODOLOGY 

We visited or interviewed over the telephone State agencies responsible for administering 

the Medicaid program in the following eight States: 

California Florida Illinois 

Louisiana Maryland Oregon 

Pennsylvania Texas 

These States were selected for site visits because they account for nearly half of all 

Medicaid expenditures. They were also chosen for their geographic location. Our site 

visits were conducted during the spring of 1999. During our visits, we discussed program 

safeguards used by each State’s Medicaid program. We spoke to State Agency officials 

and, when appropriate, to State subcontractors. 

We did not discuss payment safeguards used by managed care organizations and State 

pharmacy programs. Our discussions focused on Medicaid fee-for-service program 

safeguards. We have not attempted to assess the effectiveness of each safeguard. 

This report is the last of three reports on Medicaid program safeguards. The first report 

discusses proactive safeguards, those measures taken to prevent fraud, abuse and waste 

before a claims is ever submitted for payment. The second discusses pre-payment/claim 

processing safeguards. 

The primary purpose of these reports was to compile a catalog of program safeguards 

used by State Medicaid programs. Every effort was made to prepare a comprehensive and 

complete list. Some disagreement as to what constitutes a program safeguard may exist 

and some safeguards may have been overlooked. Fragmentation of responsibility in many 

State Medicaid programs often makes it difficult to reach all of the people responsible for 

Medicaid program safeguards. Consequently, States, their subcontractors and others may 

have information about other safeguard measures not mentioned in this report. 

Post Payment Safeguards 5 OEI-05-99-00072 
POST PAYMENT SAFEGUARDS 

Unlike other safeguards used by State Medicaid programs, post payment safeguards do 

not prevent patients from receiving excessive or medically unneeded services and they do 

not prevent erroneous payments from being made to providers. Often referred to as the 

pay and then chase method, post payment safeguards examine the accuracy of payments 

that have already been made to providers. Providers who have been paid incorrectly are 

notified and asked to refund the identified overpayment(s). Providers with egregious 

claims activity may be referred for further investigation. 

REMITTANCE NOTICES 

State Medicaid program policies stipulate that payments can only be made to the actual 

provider of medical care and services. Medicaid payments are made in the name of the 

provider and sent to a ‘pay-to-address’ designated by the provider. Payments can be 

directed to a billing agency, but the actual payment is made out in the name of the 

provider. 

Remittance notices play a key role in State post payment safeguards. All of the States we 

visited send remittance notices to providers. Remittance notices furnish providers with 

information about services billed to Medicaid using their provider number. They provide 

specific information about patients, services billed, adjudication decisions and payments. 

Providers, who review their remittance notices, should detect additions, deletions and 

modifications of claims submitted to Medicaid using their provider number. 

Remittance notices, like payments, are often directed to someone other than the provider 

of care shown on the claim submitted for Medicaid reimbursement. Several States told us 

that they have found cases where providers never saw the payments and remittance 

notices ostensibly issued to them. Medicaid payments and remittance notices have been 

diverted to billing companies or addresses unknown to the provider whose billing number 

was used to generate claims. 

State Medicaid programs cannot identify billing agents and the providers who use their 

services. Seven of the eight States in our sample do not contact providers to verify that 

they have actually authorized a billing agent/agency, clinic or other health provider to 

submit claims to Medicaid on their behalf. Florida surveyed physicians and asked them to 

verify their clinic affiliations. Analysis of the responses resulted in the termination of more 

than 100 clinics and physicians for irregular billing practices and projected savings of at 

least $15 million. 

Post Payment Safeguards 6 OEI-05-99-00072 
EXPLANATION OF BENEFITS 

Another post payment safeguard used by States is the Explanation of Benefits (EOBs). 

Unlike remittance notices, EOBs are sent to select Medicaid patients rather than to 

providers. The EOBs provide patients with information about providers who billed 

Medicaid for services ostensibly provided to them. Medicaid EOBs identify providers and 

provide information about the nature of services that were billed to Medicaid. Medicaid 

patients are asked to verify that they have used the services of the provider and received 

the services billed to Medicaid. Pennsylvania and Illinois follow up on all undeliverable 

EOBs to determine why they were returned. 

Not all Medicaid patients receive EOBs. States are only required to send EOBs to a 

random sample of patients. Some States target patients who received specific services 

(e.g., electrocardiograms, x-rays) or received services from a particular type of provider 

(e.g., podiatrist, dentist). Other States send EOBs to all recipients when targeting specific 

services or providers. In all cases, patients are asked to review the EOBs and notify the 

State Medicaid program of any discrepancies. 

Several States felt that EOBs were not an effective program safeguard. States mentioned 

that patients often turn to providers if they have any questions or concerns about the items 

on their EOB. They also mentioned that many patients cannot read or understand the 

EOB and that the overall response rate is low. Nonetheless, all eight States in our sample 

conduct reviews to determine if a potential problem exists whenever a patient notifies 

them of a suspected billing discrepancy. 

POST PAYMENT REVIEWS/AUDITS 

State Medicaid programs are required to conduct post payment reviews. In a perfect 

system, findings from post payment reviews would help State Medicaid programs: 

< measure claim payment accuracy, 

< identify incorrectly paid claims, 

< identify problematic policies and procedures, 

< identify providers who defraud or abuse the system, 

< respond to problem areas and to formulate new policies quickly, 

< provide feedback on the effectiveness of safeguards in the claims 

processing system, and, 

< provide feedback to those persons responsible for proactive safeguards. 

States use post payment audits to identify problematic providers. If problems are confined 

to a small number of providers, many Medicaid programs flag the provider and place them 

on prepayment review. If the problems are wide spread, Illinois and Louisiana believe 

that redesigning program policies and procedures is more cost effective than monitoring 

each provider. 

Post Payment Safeguards 7 OEI-05-99-00072 
While States use different criteria for selecting providers for post payment review, most 

select providers whose practice differs substantially from that of their peers. These 

“outliers” have been the primary focus of most State post payment efforts. Most States 

compare providers by specialty and location. They review data on use of specific 

diagnostic codes, procedures, numbers of patients, prescriptions and other criteria when 

deciding which providers to review. Florida, Illinois, Louisiana and Texas also review 

providers whose practice patterns are near the norm for their peer group. 

All of the States we visited rely on their Survey and Utilization Review Subsystem 

(S/URs) to target some, or all, providers for post payment audit.1 The S/URs is an 

integral part of each States Medicaid safeguards. Some States claim that the parameters 

built into S/URs are not easily changed and the system is only capable of producing 

standardized reports and, in itself, does not provide adequate tools to address today’s 

sophisticated fraud and abuse schemes. Despite such feelings about S/URs, six of the 

States we visited do not appear ready to change to neuro networks and other detection 

systems. 

Some States have downloaded claim information to personal computers. They are using 

personal computer based S/URs to do ad hoc queries to refine and enhance their ability to 

identify providers and areas for more in-depth post payment study. Some States have 

enhanced their personal computer capabilities by combining S/URs with decision support 

systems. These programs allow States more flexibility in analyzing claim data. This in 

turn helps them to better focus their post payment reviews. 

Each State Medicaid program conducts their post payment reviews/audits differently. 

Some States only audit 10 claims per provider, some focus on specific procedures billed to 

Medicaid, others use random sampling to produce results that can be projected to the 

universe and a few sample all claims, or target certain procedures for review. 

Onsite visits to providers selected for post payment review/audit are rare. Most requests 

for needed audit information are handled by mail. In most States, onsite visits to providers 

are made only when the State determines that a serious problem may exist. When States 

do make onsite visits, they often notify the provider in advance as to which patient records 

they will review during their visit. 

Of our eight States, Louisiana is the only one that routinely makes unannounced visits to 

providers selected for post payment review. During the onsite visit they obtain medical 

records and other documentation needed to determine whether the claim was paid 

correctly. Louisiana conducts nearly all of its post payment reviews by going onsite to 

1 The S/URs is a sub component of the Medicaid Management Information System (MMIS). The 

S/URs examines paid claims and produces pre-formatted management reports that identify billing patterns 

which may be problematic. 

Post Payment Safeguards 8 OEI-05-99-00072 
review and copy patient records. Providers are not notified as to which records will be 

reviewed. Louisiana believes that their onsite visits help them to identify bogus providers 

and deters providers from creating or modifying records required for post payment 

reviews. 

Post Payment Sampling Methodology 

Three States we visited do not use sampling methods to select claims for post payment 

review/audit. These States claim that projections based on sampling do not hold up to 

court challenges. Consequently, these States do not extrapolate the results of their post 

payment audits to the universe of claims. Providers are only asked to repay Medicaid the 

specific amounts identified during post payment review as incorrectly paid. This often 

results in a mere slap on the wrist because the number of claims reviewed during a post 

payment audit can be very small involving as few as 10 claims. 

Five of our States use random sampling techniques to project overpayments to the 

universe of claims submitted. Some select a random sample of claims, and others use a 

random sample of patients seen by a specific provider. Others select a sample of specific 

procedure codes, diagnostic codes, etc. These States follow accepted sampling techniques 

and believe that legal challenges to their projects based on sampling will be upheld by the 

courts. 

Provider Education 

An integral part of the post payment review process involves provider notification as to 

the results of the post payment review. State notices to providers contain information 

about the outcome of the Medicaid audit, identify incorrectly paid services and provide 

information about the underlying laws, regulations and policies that govern payment. 

States also advise providers of expected changes in their Medicaid billings that would 

ensure future compliance. 

All of the States we visited make educational contacts with providers whose claims were 

found to have been incorrectly paid. States conduct their educational contacts at the 

provider’s office, over the telephone or through the mail. Six of the States we visited 

claim that they document the content of their educational contacts by sending a letter to 

the provider. Of the eight States, only Maryland mentioned that they save educational 

contact letters in the provider’s file. They use these letters to establish that providers were 

contacted about unacceptable billing practices and that they were given information on 

how to correct their aberrant billing. 

Saving educational contact letters in the provider’s file enables Medicaid to determine how 

often they have asked the provider to correct their billing practices. They are also useful 

in showing that a provider knew the law, regulations and policies but changed their 

behavior to avoid detection. A State Medicaid program may need to use this 

documentation of provider contacts to justify a referral for criminal or civil investigation 

or administrative removal of the provider from their program. 

Post Payment Safeguards 9 OEI-05-99-00072 
Verification of Compliance 

Three of the eight States we visited, verify that providers have changed their billing 

behavior following notification that their past billing practices were unacceptable. Some 

States simply examine information about the number of claims that edit for the specific 

problem. Others not only examine edit counts but also conduct another claim audit to 

ensure that the past problems have been corrected and to ensure that the provider has not 

simply changed their billing to avoid detection. 

ALLEGATIONS OF FRAUD AND ABUSE 

States receive allegations of fraud and abuse from a number of internal and external 

sources. Each of the States in our sample handles these allegations differently. One State 

only records cases accepted for further investigation by its internal program integrity unit. 

Consequently, the State has no records that would indicate the total fraud and abuse 

workload addressed by its employees. States that do keep records on all allegations 

appear to be in a better position to identify providers with multiple allegations. These 

States are also in a better position to measure their fraud and abuse workload and the 

disposition of that workload. 

Processes used to control and resolve allegations of fraud and abuse appear weak. Some 

States have not done a good job in educating their employees concerning fraud and abuse 

and the procedures for handling such complaints. States appear to be out of the loop 

when it comes to fraud and abuse training and establishing criteria to ensure proper 

handling of such allegations. At the 1999 National Health Care Anti-fraud and Abuse 

conference, only 10 States sent representatives. Most State attendees were from State 

agencies other than Medicaid. Only three States sent Medicaid personnel to the 

conference to learn about emerging fraud schemes and safeguards to protect their 

programs from such schemes. 

PAYMENT ERROR RATES 

Payment error rates include anything from inadvertent mistakes to outright fraud. We 

know of no studies that have quantified what portion of the payment error rate is 

attributable to fraud. Some States have, however, estimated provider billings for services 

that were insufficiently documented, medically unnecessary, incorrectly coded or noncovered. The prevalence of fraud in the State Medicaid programs remains unknown. 

Post Payment Safeguards 10 OEI-05-99-00072 
Three of the eight States we contacted had attempted to determine their Medicaid 

payment error rate. All used a State Agency, independent of the Medicaid program, to 

estimate the overall claim payment error rate. Initial estimates of payment error ran up to 

15 percent, considerably higher than final estimates which fell in the 3 to 5 percent range. 

States that have attempted to quantify their payment error rate do so by selecting a 

weighted sample using provider type and claims volume. Their sample was drawn from 

the universe of fee-for-service providers and does not include managed care claims, 

pharmaceutical claims or long-term care claims. 

The remaining States have not conducted an independent audit of their Medicaid claims to 

determine payment accuracy. They rely on post payment audits conducted by their claims 

processing department, program integrity unit or subcontractor to determine payment 

error rates. In one State, the State comptroller uses statistical samples to determine 

whether providers (pharmacies, managed care organizations and long- term care facilities) 

have been correctly paid. The comptroller does not assess the medical necessity of 

services provided but merely determines whether safeguards in the system work as 

intended. 

Post Payment Safeguards 11 OEI-05-99-00072 
OPPORTUNITIES 

IMPROVEMENT 

FOR 

Post payment safeguards examine the accuracy of claims that have already been processed. 

These safeguards have a sentinel effect and help deter provider fraud and abuse. 

Comparing data may result in an inaccurate picture of a State’s efforts to decrease claim 

payment errors and to prevent fraud and abuse. Based on information obtained from this 

inspection and past studies, we encourage States to: 

Improve their provider remittance notice procedures. 

Some States believe that some remittance notices are diverted to third parties and never 

seen by the provider whose billing number was used to generate the claim. Current 

policies and procedures do not ensure that the provider will actually receive a remittance 

notice. Providers, who do receive them, may not review them for accuracy. The Florida 

Medicaid Agency’s effort to verify physician practice address(es) and clinic affiliations 

uncovered provider number misuse, fraud and abuse. Other States should consider a 

similar project not only to detect fraud and abuse but also to underscore provider 

responsibility to protect their billing number(s) and to review remittance notices.2 

Improve provider education. 

Every provider should understand that they will be held financially (and, in some cases, 

criminally and civilly) liable for any Medicaid program financial losses stemming from 

misuse of their provider.3 

Improve post payment audits. 

Selecting 10 claims for post payment review from a provider’s entire billing history may be 

a vulnerability. States need to be aware that a problem found more than one claim when 

using very small sample sizes may indicate a more extensive problem and not simply 

random error. States that find one or more problems in a small sample should expand 

their reviews and focus on the problem area(s). 

2 For more information see Medical Billing Software and Processes Used to Prepare Claims. 

OEI-05-99-00100 

3 Ibid. 

Post Payment Safeguards 12 OEI-05-99-00072 
Use valid sampling techniques. 

States that claim barriers exist to their use of random sampling should discuss those 

barriers with HCFA and other States. Moreover, States might want to consider 

conducting a small probe sample before investing resources in a larger statistically valid 

sample that can be used to project overpayments. 

Ensure that some providers selected for post payment review are chosen at random. 

More emphasis should be placed on random selection and less focus on providers whose 

practice exceeds that of their peers. States should examine providers near their peer 

norm. They should also review providers with little or no billing to determine if they are 

still a legitimate Medicaid provider. Random selection can have a deterrent effect on 

fraudulent and abusive billing and enables States to identify problematic providers who 

have circumvented their program safeguards. 

Document educational contacts stemming from post payment audits. 

Problems found during claim reviews should be discussed directly with the provider either 

in person or over the telephone. These conversations should be memorialized in a 

certified letter to the provider and a copy maintained in a specific State file. This 

demonstrates that the provider was made aware of the problem(s) should additional action 

be required.4 

Improve their surveillance of providers found to have billing problems. 

States could conduct another audit to ensure that the provider corrected the unacceptable 

billing practices identified in the initial post payment audit. These follow up reviews/audits 

could be used to ensure that the provider has indeed changed his billing practices and has 

not found a way to circumvent Medicaid safeguards. 

Work with HCFA to establish uniform definitions for audits, edits, reviews, claim 

counts, rejects, etc. 

Clarifying these terms should allow the States and HCFA to compare and contrast efforts 

in safeguarding Medicaid. 

4 Additional information can be found in our report entitled, Carrier Fraud Units. 

OEI-05-94-00470. 

Post Payment Safeguards 13 OEI-05-99-00072 
Improve the handling of fraud and abuse allegations. 

Their should be written procedures for handling suspected fraud and abuse identified by 

Medicaid employees and subcontractor employees. A single point within the State 

Medicaid program should be responsible for addressing fraud and abuse concerns raised 

by State Agency employees and their subcontractors. 

Develop training to help their employees and subcontractors identify potential fraud 

and abuse issues. 

Employees should be trained to recognize potential fraud and be able to differentiate fraud 

from abuse.5 Training should enable employees to determine if discrepancies on claims 

are material. Erroneous claim information that does not affect payment probably is not 

fraud or abuse. On the other hand, erroneous information that results in payment when 

the true information results in no, or a lower, payment may be significant. Improved 

training would help ensure proper disposition and handling of allegations and help ensure 

proper referral of cases for in depth investigation. 

Collect better data on payment error rates. 

Some States have used payment error rate data to identify and address problematic 

providers, poor policies and vulnerable procedures. Reliance on subcontractor measures 

of payment accuracy may be a vulnerability. States should periodically conduct their own 

measures of payment error. The States should also work with HCFA to establish criteria 

for classifying payment errors (i.e., medically unnecessary, service billed is greater/less 

than supported by the medical record, no documentation to support service, etc.). 

AGENCY COMMENTS 

We received comments on this report from HCFA. The HCFA believes that the opportunities for 

improvement described in this report provide valuable information that will be shared with the 

State Medicaid programs. The full text of HCFA’s comments can be found in Appendix A. 

5 Additional information about processing allegations of fraud and abuse can be found in our 

report entitled, Carrier Fraud Units. OEI-05-94-00470. 

Post Payment Safeguards 14 OEI-05-99-00072 
APPENDIX A 

HCFA Comments on this Report 

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Post Payment Safeguards 18 OEI-05-99-00072