Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

CMS HAS YET TO ENFORCE 

A STATUTORY PROVISION 

RELATED TO RURAL HEALTH 

CLINICS 

Suzanne Murrin 

Deputy Inspector General for 

Evaluation and Inspections 

September 2014 

OEI-05-13-00290 
 

 

EXECUTIVE SUMMARY: CMS HAS YET TO ENFORCE A STATUTORY 

PROVISION RELATED TO RURAL HEALTH CLINICS 

OEI-05-13-00290 

WHY WE DID THIS STUDY 

The Rural Health Clinic (RHC) certification was created in 1977 to address the shortage 

of physicians in rural areas. RHCs had to meet two location requirements: (1) being 

located in rural areas and (2) being located in areas that have a shortage of health care 

providers. RHCs receive enhanced Medicare and Medicaid reimbursements for most 

services. 

Prior to the enactment of the Balanced Budget Act of 1997 (BBA), RHCs retained their 

certifications indefinitely. However, the BBA removed their permanent status and 

allowed for the termination of RHCs that no longer met the location requirements as long 

as they were not determined to be “essential provider” RHCs. 

A 2005 Office of Inspector General report found that nearly 300 RHCs did not meet the 

location requirements and that the Centers for Medicare & Medicaid Services (CMS) had 

not issued regulations that would allow RHCs to apply as essential-provider RHCs. 

HOW WE DID THIS STUDY 

We plotted RHC locations onto a digital map to determine whether RHCs met the two 

location requirements in 2013. Additionally, we used 2012 claims data to calculate the 

amount Medicare paid to the RHCs we determined did not meet the location 

requirements. Finally, we reviewed Federal regulations and interviewed CMS staff to 

determine whether essential-provider criteria had been established or were in the process 

of being established. 

WHAT WE FOUND 

Approximately 12 percent of RHCs no longer met the location requirements in 2013. 

Pursuant to the BBA, these RHCs should continue to qualify as RHCs—and receive 

enhanced reimbursement—only if they are determined to be essential providers. 

However, CMS has yet to issue final regulations that would allow RHCs that do not meet 

the location requirements to qualify as essential-provider RHCs. 

WHAT WE RECOMMEND 

More than 16 years have elapsed since Congress directed CMS to issue regulations that 

would allow RHCs that no longer meet location criteria to qualify as essential providers. 

Without these regulations, CMS can neither terminate RHCs nor identify them as 

essential providers in accordance with the BBA provision. Consequently, RHCs that no 

longer meet location criteria continue to receive enhanced reimbursement. To ensure that 

CMS can enforce the BBA provisions relating to RHCs, we recommend that CMS issue 

regulations to ensure that RHCs determined to be essential providers remain certified as 

RHCs. CMS responded to the report but neither concurred nor nonconcurred with our 

recommendation. 
 

TABLE OF CONTENTS 

Objective......................................................................................................1 

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

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

Findings........................................................................................................6 

Approximately 12 percent of RHCs no longer meet the location 

requirements .....................................................................................6 

CMS has yet to issue final regulations that would allow RHCs that 

do not meet the location requirements to qualify as essential 

providers ..........................................................................................7 

Conclusion and Recommendation ...............................................................8 

Agency Comments and Office of Inspector General Response .......9 

Appendixes ................................................................................................10 

A: Definitions and Criteria for Health Care Shortage Areas ........10 

B: Agency Comments ...................................................................12 

Acknowledgments......................................................................................13
 
 

 

 

 

 

 

 

OBJECTIVES 

1.	 To determine the extent to which Rural Health Clinics (RHCs) 

no longer meet the location requirements. 

2.	 To determine whether the Centers for Medicare & Medicaid 

Services (CMS) has taken steps to address a prior Office of 

Inspector General (OIG) recommendation to issue regulations 

defining the criteria for RHCs to be deemed “essential 

providers.” 

BACKGROUND 

Rural Health Clinics 

The RHC certification was created in 1977 to address the shortage of 

physicians in rural areas by providing enhanced reimbursement.1 To 

ensure that RHCs could be located only in rural areas with documented 

physician shortages, CMS specified two location-based criteria 

(hereinafter known as the location requirements) in the RHC Conditions of 

Participation.2 RHCs had to be (1) located in nonurbanized areas, as 

defined by the Census Bureau (hereafter referred to as rural areas), and 

(2) located in one of the following types of health care shortage areas, as 

defined by the Health Resources and Services Administration (HRSA):3 

 Primary Care Geographic Health Professional Shortage Area 

(HPSA)4 

 Primary Care Population Group HPSA5 

 Medically Underserved Area (MUA)6 

 Governor-designated and Secretary-certified shortage area under 

the Omnibus Budget Reconciliation Act of 19897 

For a detailed description of each type of shortage area, see Appendix A. 

1

 Rural Health Clinic Services Act of 1977, P. L. No. 95-210. 

2

 Conditions of Participation are requirements that providers must meet to participate in 

Medicare. 

3

 Social Security Act, § 1861(aa)(2); 42 U.S.C. § 1395x(aa)(2); CMS, Rural Health 

Clinic: Rural Health Fact Sheet Series, January 2013. HPSAs are subject to annual 

reviews (76 Fed. Reg. 68198 (Nov. 3, 2011)). MUAs are not subject to regular reviews 

(Negotiated Rulemaking Committee on the Designation of Medically Underserved 

Populations and Health Professional Shortage Areas: Final Report to the Secretary, 

October 31, 2011, p.18).
 4

 Public Health Services (PHS) Act, § 332(a)(1)(A). 

5 PHS Act, § 332(a)(1)(B).
 6 PHS Act, § 330(b)(3).
 7

 Section 6213(c). 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 1 
 

 

 

 

 

 

Most of the information that the RHC location requirements draw on 

is updated periodically. Census-defined urbanized areas are updated every 

10 years, following the decennial Census.8 HPSAs are updated 

approximately once every 4 years; HRSA prioritizes designations that are 

more than 3 years old for recertification.9

 Currently, MUAs are never 

updated.10 

RHCs receive enhanced reimbursements from Medicare and Medicaid. 

These enhanced reimbursements are based on costs.11 Medicare 

reimbursements to RHCs are subject to a per-visit payment limit, which 

was approximately $80 in 2013.12 Per-visit Medicare payment limits do 

not apply to RHCs that are part of a hospital with fewer than 50 beds.13 

In 2013, there were 4,019 RHCs providing services in 44 States in the 

United States. Medicare and beneficiaries paid approximately $1 billion 

for services provided at these RHCs. 

Creation of “Essential Provider” RHCs 

In 1996, both OIG and the Government Accountability Office (GAO) 

recommended that CMS ensure that the RHC certification apply only to 

facilities in areas that would otherwise be underserved, rather than in rural 

areas that are designated as health care shortage areas but have high 

concentrations of medical providers.14, 15 

In response to the OIG and GAO recommendations, the Balanced Budget 

Act of 1997 (BBA) removed RHCs’ permanent status and allowed for the 

creation of an exemption process for RHCs that would otherwise be 

8

 United States Census Bureau, 2010 Census Urban Area FAQs. Accessed at 

http://www.census.gov/geo/reference/ua/uafaq.html on May 23, 2014. 9 76 Fed. Reg. 68198 (Nov. 3, 2011). 

10 Negotiated Rulemaking Committee on the Designation of Medically Underserved 

Populations and Health Professional Shortage Areas: Final Report to the Secretary, 

October 31, 2011, p. 18. In March 2014, HRSA staff stated that they are in the process of 

promulgating an interim final rule that would set a recertification schedule for MUAs. 

11 CMS, Rural Health Clinic: Rural Health Fact Sheet Series, January 2013; Health 

Resources and Services Administration (HRSA), What are rural health clinics (RHCs)? 

Accessed at http://www.hrsa.gov/healthit/toolbox/RuralHealthITtoolbox/Introduction/ 

ruralclinics.html on May 23, 2014. 12 CMS, Announcement of the Medicare Rural Health Clinic (RHC) and Federally 

Qualified Health Center (FQHC) Payment Rate Increases, November 23, 2012. 

Accessed at http://www.cms.gov/Outreach-and-Education/Medicare-Learning-NetworkMLN/MLNMattersArticles/downloads/MM8119.pdf on May 23, 2014. 13 CMS, Rural Health Clinic: Rural Health Fact Sheet Series, January 2013. 14 OIG, Rural Health Clinics: Growth, Access, and Payment, OEI-05-94-00040, 

July 1996. 

15 GAO, Rural Health Clinics: Rising Program Expenditures Not Focused on Improving
 

Care in Isolated Areas, GAO-HEHS-97-24, November 1996. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 2 
 

 

 

 

terminated from the Medicare program. Prior to the BBA, RHCs that 

initially met the location requirements retained their RHC certifications 

indefinitely, effectively making the RHC certification permanent. The 

BBA specified the RHCs that were in areas that no longer qualified as 

nonurbanized areas or shortage areas would continue to qualify as RHCs 

only if they were determined to be “essential to the delivery of primary 

care services that would otherwise be unavailable in the geographic area 

served by the clinics” (hereafter referred to as essential-provider RHCs).16 

Further, the BBA specified that the Secretary of Health and Human 

Services should issue regulations that would establish the criteria used to 

determine essential-provider RHCs, and that those regulations should take 

effect no later than January 1, 1999.17 

Rulemaking Process 

Agencies like CMS must follow the Administrative Procedure Act, which 

governs rulemaking. Typically, an agency must publish a proposed rule in 

the Federal Register and invite the public to comment on it. The agency 

uses the proposed rule and public comments as the basis for the final rule, 

which it publishes—along with the date the rule goes into effect—in the 

Federal Register.18 

The Medicare Prescription Drug, Improvement, and Modernization Act 

(MMA), which became law on December 8, 2003, made a change to the 

rulemaking process for all agencies within the Department of Health and 

Human Services, including CMS. Specifically, the MMA established that 

no more than 3 years may pass between the publication of a proposed rule 

or interim final and the publication of a final rule except under exceptional 

circumstances. In the event of such circumstances, a notice of the 

different timeline must be published in the Federal Register.19 

Related Work 

OIG has a body of work that examines the location of RHCs. In addition 

to its 1996 report, OIG issued a report in 2005 that found that, in 2003, 

279 RHCs were not located in rural areas or in health care shortage areas 

and that RHCs were often located near other health care providers.20 OIG 

recommended on the basis of these findings that CMS issue regulations 

16 Balanced Budget Act of 1997, P.L. No. 105-33 § 4205(d)(3)(A). New RHCs are still 

required to meet the original location requirements—that is, they must be located in rural 

areas and in designated health care shortage areas.
 17 Balanced Budget Act of 1997, P.L. No. 105-33 § 4205(d)(4)(C)(ii). 18 5 U.S.C. § 553.
 19 Medicare Prescription Drug, Improvement, and Modernization Act of 2003, P.L.
 

No. 108-173 § 902(a)(1).
 20 OIG, Status of the Rural Health Clinic Program, OEI-05-03-00170, August 2005. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 3 
 

defining essential-provider criteria for RHCs. In its May 2005 comments 

on our report, CMS concurred with the recommendation and stated that it 

intended to issue new rules for RHCs in early 2006. 

METHODOLOGY 

Scope 

We analyzed RHC locations to identify those that in 2013 were no longer 

located in rural areas or in health care shortage areas. We excluded RHCs 

with locations that we were unable to confidently determine. We also 

calculated the amount that Medicare and beneficiaries paid to RHCs in 

2012. 

We focused on the 2005 OIG report’s recommendation that CMS issue 

regulations defining essential-provider criteria for RHCs. 

Data Collection and Analysis 

We requested from HRSA a list of RHC addresses and corresponding 

latitudes and longitudes. HRSA created this list using a three-step process: 

(1) compiling addresses for all RHCs enrolled in Medicare in 2013, using 

CMS’s Certification and Survey Provider Enhanced Reports (CASPER); 

(2) running these addresses through the address standardizer 

Trillium 13.5;21, 22 and (3) identifying latitudes and longitudes for these 

standardized addresses using Esri’s StreetMap Premium 2013.23 There 

were 4,019 RHCs on this list. 

We excluded 498 RHCs from our analysis because they were geocoded 

only to the city, State, or ZIP Code level, rather than to the address level.24 

We felt that these levels of geocoding were not precise enough to 

determine whether these RHCs met the location requirements. 

We mapped the latitudes and longitudes of the remaining 3,521 RHCs 

onto a digital map using ArcGIS. We used this map, along with the 

2013 boundaries of urbanized areas and health care shortage areas, to 

identify RHCs that did not meet the location requirements. 

21 The CASPER database includes data generated from certification surveys and includes 

information such as provider addresses and enrollment dates. 22 Trillium 13.5 standardizes name and address elements and corrects spelling and other 

errors. 

23 StreetMap Premium is an enriched street dataset that works with Esri’s ArcGIS 

software to allow for geocoding, routing, and turn-by-turn directions. Geocoding is the 

process of turning standard addresses into latitude and longitude coordinates.
 24 These 498 RHCs had complete addresses but the geocoding software could map their 

locations with confidence only to the center of a city, State, or ZIP Code. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 4 
 

Using data from CMS’s 2012 Outpatient Standard Analytic Files—the 

most recent complete claims data—we calculated the amount Medicare 

and beneficiaries paid to RHCs that did not meet the location 

requirements. 

Finally, we reviewed Federal regulations and interviewed CMS staff to 

determine whether essential-provider criteria had been established or were 

in the process of being established. 

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. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 5 
 

FINDINGS 

Approximately 12 percent of RHCs no longer meet the 

location requirements 

Of the 3,521 RHCs included in our analysis, 434 no longer meet the 

location requirements. Fifty-nine percent of these RHCs are located in 

areas not designated as shortage areas. Another 39 percent of these RHCs 

are located in urbanized areas. The final 2 percent were located in areas 

that were neither rural nor designated as shortage areas. Medicare and 

beneficiaries paid approximately $132 million to these RHCs in 2012. 

Table 1 provides the number of RHCs that do not meet the location 

requirements and the amounts paid by Medicare and beneficiaries in 2012. 

Table 1: Number of RHCs that did not meet the location requirements and 

amounts paid to them by Medicare and beneficiaries 

Characteristics of RHCs that did not 

meet the location requirements 

Number of 

RHCs 

Amount paid by Medicare and 

beneficiaries to these RHCs 

Located in a rural area but not in a health 

care shortage area 257 $84.6 million 

Located in a health care shortage area 

but not in a rural area 169 $46.7 million 

Located in neither a health care shortage 

area nor a rural area 8 $0.8 million

 Total 434 $132.1 million 

Source: OIG analysis of 2013 RHC locations and 2012 outpatient claims data, 2014. 

The number of RHCs that no longer meet the location requirements has 

increased by approximately 56 percent since 2003, when OIG found that 

279 RHCs did not meet the location requirements. 

RHCs may no longer meet location requirements because health care 

shortage areas and urbanized areas change periodically. HPSAs are 

updated approximately every 4 years; urbanized areas are updated every 

10 years, following the decennial Census. 

Pursuant to the BBA, RHCs that no longer meet the location requirements 

should continue to qualify as RHCs only if they are determined to be 

essential providers. 

CMS has yet to issue final regulations that would allow 

RHCs that do not meet the location requirements to 

qualify as essential providers 

Sixteen years have passed since Congress directed CMS to issue 

regulations outlining the criteria that RHCs could use to qualify as 

essential providers, and CMS has not finalized such regulations. CMS has 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 6 
 

 

 

twice promulgated proposed rules, but neither rule was finalized by the 

Department of Health and Human Services. There remains no final rule 

establishing essential-provider criteria for RHCs. As such, RHCs continue 

to operate without the option to apply as essential providers. 

In addition, the CMS staff who are responsible for developing and 

overseeing RHC-related policies state that they are not currently planning 

to reissue the more recent of the two proposed rules or to develop a 

replacement. Because CMS did not finalize the most recent proposed rule 

within 3 years of its publication date, the agency would need to reissue the 

proposed rule and go through the rulemaking process again. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 7 
 

 

CONCLUSION AND RECOMMENDATION 

More than 16 years have elapsed since Congress directed CMS to issue 

regulations to ensure that only RHCs determined to be essential providers 

remain certified as RHCs, and more than 8 years have elapsed since CMS 

told OIG that it planned to issue the regulations. Although CMS has 

promulgated proposed rules regarding essential-provider criteria for 

RHCs, it has yet to publish a final rule establishing these criteria. 

Meanwhile, the number of RHCs that do not meet the location 

requirement has increased by 56 percent since 2003. 

To ensure that CMS can enforce the BBA provisions relating to RHCs, we 

recommend that CMS: 

Issue regulations to ensure that RHCs determined to be 

essential providers remain certified as RHCs. 

The BBA requires that RHCs that no longer meet the location 

requirements and that are not determined to be essential providers be 

terminated from the program. However, CMS has yet to issue regulations 

defining essential-provider criteria for RHCs; consequently, all RHCs 

remain certified as RHCs and continue to receive enhanced Medicare and 

Medicaid reimbursements. CMS should issue these regulations so that 

only RHCs determined to be essential providers continue to receive 

enhanced reimbursements. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 8 
 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

CMS responded to the report but neither concurred nor nonconcurred with 

our recommendation. 

We continue to encourage CMS to issue regulations to ensure that RHCs 

determined to be essential providers remain certified as RHCs, as doing so 

will help protect Medicare and Medicaid dollars from going to providers 

that no longer qualify for the enhanced reimbursements that RHCs 

receive. Without regulations that define essential provider criteria, all 

RHCs—including those that no longer meet the location requirements— 

remain certified and continue to receive enhanced Medicare and Medicaid 

reimbursements. We will routinely follow up with CMS about 

implementing this recommendation. 

For the full text of CMS’s comments, see Appendix B. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 9 
 

 

 

APPENDIX A 

Definitions and Criteria for Health Care Shortage Areas 

1.	 A Primary Care Geographic Health Professional Shortage Area 

(HPSA) must: 

o	 Be a rational area for the delivery of primary care medical 

services; 

o	 Meet one of the following conditions: 

 Have a population to full-time-equivalent primary care 

physician ratio of at least 3,500:1, or 

 Have a population to full-time-equivalent primary care 

physician ratio of less than 3,500:1 but greater than 

3,000:1 and have unusually high needs for primary 

health care services or insufficient capacity of existing 

primary care providers. 

o	 Demonstrate that primary medical professionals in contiguous 

areas are overutilized, excessively distant, or inaccessible to the 

population under consideration.25 

2.	 A Primary Care Population Group HPSA must: 

o	 Reside in an area in that is rational for the delivery of primary 

medical care services as defined in the Federal code of 

regulations. 

o	 Have access barriers that prevent the population group from 

use of the area’s primary medical care providers. 

o	 Have a ratio of persons in the population group to number of 

primary care physicians practicing in the area and serving the 

population group ratio of at least 3,000:1. 

25 Public Health Services (PHS) Act, § 332(a)(1)(A); 42 CFR pt. 5, Appendix A, pt. 1; 

HRSA, Primary Medicare Care HPSA Designation Overview. Accessed at 

http://bhpr.hrsa.gov/shortage/hpsas/designationcriteria/primarycarehpsaoverview.html on 

April 8, 2014. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 10 
 

 

 

 

o	 Members of federally recognized Native American tribes are 

automatically designated. Other groups may be designated if 

the meet the basic criteria described above.26 

3.	 A Medically Underserved Area (MUA) is: 

o Defined by the Index of Medical Underservice (IMU). 

 The IMU scale is from 0 to 100, where 0 represents 

completely underserved and 100 represents best served 

or least underserved. 

 Under the established criteria, each service area found 

to have an IMU of 62.0 or less qualifies for designation 

as an MUA. 

o	 The IMU involves four variables—ratio of primary medical 

care physicians per 1,000 population, infant mortality rate, 

percentage of the population with incomes below the poverty 

level, and percentage of the population age 65 or over. 

 The value of each of these variables for the service area 

is converted to a weighted value, according to 

established criteria. 

 The four values are summed to obtain the area’s IMU 

score.27 

4.	 A Governor-designated and Secretary-certified shortage area is an area 

designated by the chief executive office of the State and certified by 

the Secretary as an area with a shortage of personal health services.28 

26 Public Health Services (PHS) Act, § 332(a)(1)(B); 42 CFR pt. 5, Appendix A, pt. 2,
 

HRSA, Primary Medicare Care HPSA Designation Overview. Accessed at
 

http://bhpr.hrsa.gov/shortage/hpsas/designationcriteria/primarycarehpsaoverview.html on
 

April 8, 2014. 

27 PHS Act § 330I(a)(4); 42 CFR § 51c.102(e); HRSA, Medically Underserved Areas/ 

Populations. Accessed at http://www.hrsa.gov/shortage/mua/index.html on
 

April 8, 2014. 

28 Omnibus Budget Reconciliation Act of 1989 P. L. No. 101-239 § 6213(c); HRSA, 

Medically Underserved Areas/ Populations. Accessed at 

http://www.hrsa.gov/shortage/mua/index.html on April 8, 2014. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 11 
APPENDIX 8 

Agency Comments 

DEPARTMENT OF HEALTH & HUMAN SERVICES Center.s for Medh::are & Medicaid Services 

---~----·-------- ---­ Administrator 

Washington. DC 20201 

DATE: AUG 0 8 2014 

TO: Daniel R. Levinson 

In.spector General 

FROM: Mai\lyn 1/avellller 

Administi'ulruSUBJECT: Office oflnspector General (O!G) Draft Report: CMS Has Yet to Enforce a 

Statutory Provision Related to Rural Health Clinics, (OE!-05-J J-00290) 

Thank you for the opportunity to review and comment on the subject report. Rural Health 

Clinics (RHCs) were created in 1997 to address the shortage of physicians in ntral areas. RHCs 

must meet two location requirements: 1) they must be located in ntral areas. and 2) they must be 

located in areas that have a shortage of health care providers. RHCs receive enhanced Medicare 

and :V1edicaid payment for most services. 

The O!G found that approximately !2 percent of RHCs no longer met the location requirements 

in 20! 3. Pursuant to the Balanced Budget Act of 1997, OIG indicates that these RHCs should 

only continue to qualify as RHCs and receive enhanced reimbursement if they are determined to 

be "essential providers"- However, OIG indicated that the Centers for Medicare & Medicaid 

Services (CMS) has yet to issue final regulations that would allow RHCs that do oot meet the 

!oc;Uion requirements to quality as essential providers. 

The OIG's recommendation and CMS' response to that recommendation arc discussed below. 

t;)TG Recommendation 

The O!G recommends that CMS issue regulations to ensure that RHCs determined to be essential 

providers remain certitied as RHCs_ 

CMS Response 

The CMS thanks OIG for their efforts on this issue, 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 12 
 

ACKNOWLEDGMENTS 

This report was prepared under the direction of Ann Maxwell, Regional 

Inspector General for Evaluation and Inspections in the Chicago regional 

office, Thomas Komaniecki, Deputy Regional Inspector General, and 

Laura Kordish, Deputy Regional Inspector General. 

Lisa Minich served as the team leader for this study, and Hilary Slover 

served as the lead analyst. Other Office of Evaluation and Inspections 

staff from the Chicago regional office who conducted the study include 

Elliot Curry. Central office staff who provided support include 

Kevin Farber, Kevin Manley, and Christine Moritz. 

CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics (OEI-05-13-00290) 13 
Office of Inspector General

http://oig.hhs.gov 

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

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

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

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

investigations, and inspections conducted by the following operating components: 

Office of Audit Services 

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

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

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

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

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

mismanagement and promote economy and efficiency throughout HHS. 

Office of Evaluation and Inspections 

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

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

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

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

reports also present practical recommendations for improving program operations. 

Office of Investigations 

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

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

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

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

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

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

Office of Counsel to the Inspector General 

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

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

legal support for 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.