Report Template Update: 04-03-08 

 Department of Health and Human Services

OFFICE OF 

INSPECTOR GENERAL 

 

CMS’S PROCESSING OF 

COMPLAINTS RECEIVED 

THROUGH THE 1-800-HHS-TIPS 

HOTLINE 

 

 

Daniel R. Levinson 

Inspector General 

March 2011 

OEI-07-09-00020 
INTRODUCTION 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS i 

 EXECUTIVE SUMMARY EXECUTIVESU MMARY 

OBJECTIVE

To assess the Centers for Medicare & Medicaid Services’ (CMS) 

processing of complaints received through the 1-800-HHS-TIPS hotline. 

BACKGROUND 

Many Offices of Inspector General (OIG) operate hotlines to respond to 

citizen and employee allegations of fraud, waste, or abuse in Federal 

programs. The Department of Health & Human Services (HHS) OIG 

maintains such a hotline (1-800-HHS-TIPS), for individuals to provide 

information that may assist in combating fraud, waste, or abuse in HHS 

programs (e.g., Medicare, Medicaid, child support enforcement, and 

Head Start). Individuals may call the hotline or send their written 

concerns by email, postal mail, or fax. 

We obtained a copy of the hotline complaint data in CMS’s information 

system as of March 2009. We identified 1,427 complaints that OIG 

forwarded to CMS in the first 6 months of 2008. From these, we 

selected a simple random sample of 120 complaints. We telephoned 

staff at each contractor assigned to the sampled complaints to inquire 

about what initial research the contractor performed to validate each 

complaint; how and when the contractor contacted the complainant; and 

what outcomes (e.g., recouping an overpayment from the provider) 

resulted from the contractor’s actions on the complaint. We also 

conducted structured telephone interviews with contractor staff, CMS 

central office staff, and CMS regional office staff about the complaint 

process. Finally, to check the status of complaints 1 year after we 

initially received the hotline complaint data, in March 2010 we obtained 

a copy of the hotline complaint data in CMS’s information system. 

FINDINGS 

At least 1 year after receiving complaints through the 

1-800-HHS-TIPS hotline, CMS had resolved the majority of them, 

but 12 percent remained unresolved. CMS has no requirements 

regarding the length of time within which contractors should resolve 

complaints. Our period of review allowed at least 1 year to elapse after 

CMS received the complaints from OIG. As of March 2010, interviews 

with contractors and a review of data in CMS’s information system 

confirmed that CMS resolved or closed administratively 88 percent of 

complaints received during the first 6 months of 2008. (Complaints are 
EXECUTIVE SUMMARY 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS ii 

closed administratively if they are below the dollar-amount threshold 

required for research or if the information in the complaint is 

insufficient to conduct further work.) Overall, 32 percent of complaints 

were confirmed as services billed in error. Eleven percent of complaints 

involved allegations of fraud. Contractors closed 11 percent of 

complaints administratively. For another 32 percent, contractors 

researched complaints and found no problems. Two percent of 

complaints were referred to another agency. CMS had not resolved 

12 percent of the complaints it received during our period of review. 

Long timeframes and inefficient processes delay starting work on 

complaints. For 58 percent of complaints, contractors reported starting 

work within 30 days of CMS’s receipt of the complaints from OIG, but 

for 29 percent of complaints, contractors took more than 4 months to 

start work. Included in the latter group are complaints that contractors 

were unaware had been assigned to them (22 percent of all complaints). 

Only following our inquiry did the contractors begin work on these 

complaints. CMS and contractor staff described processes that 

contribute to delays in transmitting complaints from the CMS central 

office to contractor staff. Such delays add to the time that it takes to 

resolve complaints. 

Lack of guidance and an inadequate information system hinder 

complaint processing. Some CMS and contractor staff reported the 

need for written guidance defining their roles and responsibilities for 

processing hotline complaints. Although CMS provides some guidance 

to contractors, some CMS and contractor staff stated that guidance is 

lacking for processing complaints from receipt through resolution. No 

written procedures for processing complaints exist at the level of the 

CMS central office; however, staff from two CMS regional offices 

reported developing standard operating procedures for handling 

complaints. Most contractors have developed internal policies and 

procedures for handling complaints; however, some contractors desired 

guidance from CMS. In addition, the status of complaints cannot be 

tracked in CMS’s information system. 
EXECUTIVE SUMMARY 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS iii 

RECOMMENDATIONS 

The 1-800-HHS-TIPS hotline is widely publicized as an avenue that 

individuals can use to provide information that may assist in combating 

fraud, waste, or abuse in Federal health care programs. While the extent 

of health care fraud is unknown, it is estimated to be in the billions of 

dollars each year. HHS emphasizes that Medicare beneficiaries are the 

front line of defense in detecting Medicare fraud because they have 

firsthand knowledge of the health care services they have received. 

When researched and resolved, hotline complaints can lead to 

recovering overpayments and identifying fraud. Therefore, it is 

important for CMS to have a clear and consistent approach to process 

hotline complaints. 

We recommend that CMS: 

Issue written guidance for processing hotline complaints. CMS should 

issue guidance defining the roles and responsibilities of CMS and 

contractor staff and timeframes for assigning, researching, and resolving 

complaints. 

Upgrade its information system for processing hotline complaints. CMS 

should ensure that its information system tracks user activity on each 

complaint and alerts CMS when a complaint has not been assigned to a 

contractor. 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

In its written comments on the draft report, CMS concurred with our 

recommendations. In response to our first recommendation, CMS 

stated that it will create written guidance that defines the specific roles 

and responsibilities for CMS and its contractor staff to achieve greater 

clarity in administration of its database (i.e., its information system). 

Where they are not already established, CMS will establish timeframes 

for assigning, researching, and resolving complaints. CMS stated that 

it is revising its national contractor list to include contact names and 

contract numbers associated with the contractors. In response to our 

second recommendation, CMS stated that it is upgrading and updating 

its database with the following features: auditing mechanisms to track 

user activity, contractor assignments, and status of complaints; and the 

capacity to alert CMS when complaints have not been assigned. CMS 
EXECUTIVE SUMMARY 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS iv 

stated that it will work with OIG to establish an electronic method to 

deliver hardcopy evidence received from complainants concurrently with 

the electronic complaint. 
Report Template Update: 04-03-08 

 TABLE OF CONTENTS 

EXECUTIVE SUMMARY .....................................i

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 

FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 

At least 1 year after receiving complaints through the 

1-800-HHS-TIPS hotline, CMS had resolved the majority of 

them, but 12 percent remained unresolved . . . . . . . . . . . . . . . . . . . 7 

Long timeframes and inefficient processes delay starting work 

on complaints . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 

Lack of guidance and an inadequate information system hinder 

complaint processing. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 

RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 

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

APPENDIXES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 

A: Flowchart of Processing of Complaints Received Through 

the 1-800-HHS-TIPS Hotline and Referred 

to the Centers for Medicare & Medicaid Services . . . . . . . . . . 17 

 B: Point Estimates and Confidence Intervals . . . . . . . . . . . . . . . . 18 

 C: Agency Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 

ACKNOWLEDGMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Report Template Update: 04-03-08 

 

 

 INTRODUCTION 

OBJECTIVE 

To assess the Centers for Medicare & Medicaid Services’ (CMS) 

processing of complaints received through the 1-800-HHS-TIPS hotline. 

BACKGROUND 

Many Offices of Inspectors General (OIG) operate hotlines to respond to 

citizen and employee allegations of fraud, waste, or abuse in Federal 

programs. The Department of Health & Human Services (HHS) OIG 

maintains such a hotline (1-800-HHS-TIPS), which individuals can use 

to provide information that may assist in combating fraud, waste, or 

abuse in HHS programs (e.g., Medicare, Medicaid, child support 

enforcement, and Head Start). Individuals may call the hotline or send 

their written concerns by email, postal mail, or fax. 

The availability of the hotline is widely publicized on the Internet and 

in various publications, such as the CMS Medicare & You handbook 

distributed annually to Medicare beneficiaries. These media strongly 

encourage individuals to report suspicious activity, emphasizing that 

they can help stop fraud in HHS programs. The CMS Web site states 

that it is in the best interest of beneficiaries and of all citizens to report 

suspected fraud, as fraud increases health care costs. In addition, HHS 

emphasizes that Medicare beneficiaries are the front line of defense in 

detecting Medicare fraud because they have firsthand knowledge of the 

health care services they have received. Given the hotline’s prominence, 

it is vital that information reported to the hotline be thoroughly 

reviewed and appropriately addressed in a timely fashion. 

Written Procedures and Guidance 

Three groups process hotline complaints related to CMS programs: OIG 

hotline staff, CMS central and regional office staff, and contractor staff. 

OIG has developed two written guidance documents pertaining to the 

handling of hotline calls: OIG Hotline Program Orientation and OIG 

Hotline Screening Protocols. The CMS central office has not issued 

written procedures or guidance for processing hotline complaints. 

In the absence of written procedures or guidance from CMS, the 

information in this report regarding CMS’s complaint processing is 

based primarily on information that OIG obtained through verbal 

contacts made during this evaluation. For a flowchart of complaint 

processing as explained to and observed by OIG, see Appendix A. 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 1 
INTRODUCTION 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 2 

OIG Hotline Complaint Processing 

In 2008, the OIG hotline received approximately 124,000 telephone calls 

and 15,000 pieces of written correspondence. However, most contacts to 

the hotline do not result in complaints logged into the OIG hotline 

database. Using OIG’s written procedures, customer service 

representatives (CSR) determine whether an issue rises to the level of a 

complaint and whether it falls within OIG’s jurisdiction. For issues that 

fall outside OIG’s jurisdiction or that do not rise to the level of a 

complaint, CSRs provide individuals contacting the hotline with, 

whenever possible, another avenue to seek assistance, such as calling 

their State health and human services agencies or 1-800-MEDICARE. 

For example, if callers inquire about terminology on a Medicare 

Summary Notice (MSN), CSRs refer them to 1-800-MEDICARE. If 

callers have complaints involving Medicaid eligibility, CSRs refer the 

callers to State Medicaid agencies. In contrast, if a caller alleges that a 

Medicare beneficiary was billed for services not received, the CSR logs a 

complaint. 

When CSRs determine that a written or telephone contact rises to the 

level of a complaint, they enter information—including beneficiary 

contact information, provider contact information, and a summary of 

the complaint—into the OIG hotline database. The database 

automatically assigns a number to identify the complaint. When taking 

telephone complaints, CSRs do not conduct detailed inquiries with 

callers or call complainants back for followup. CSRs also do not update 

complainants on the disposition of individual complaints. 

Forwarding complaints for resolution. In 2008, hotline calls and 

correspondence resulted in approximately 6,200 complaints. OIG 

hotline staff forward complaints to either an OIG field office or the 

appropriate HHS staff division or operating division (e.g., CMS) or other 

Federal agency for resolution. OIG forwarded approximately 

2,400 complaints to field offices for followup, forwarded more than 

3,000 complaints to CMS, and distributed the balance of the complaints 

among other HHS operating divisions and other Federal agencies. 

An OIG analyst reviews the CSR’s data entry for quality control and 

prints a cover sheet that includes the complaint number, beneficiary 

and provider contact information, and a summary of the complaint. If 

any hardcopy documents (e.g., letters or MSNs) accompany the 

complaint, the analyst attaches them to the cover sheet. OIG staff 

package the cover sheets and documents and mail them in batches to 
INTRODUCTION 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 3 

CMS. OIG also sends an electronic file containing complaint 

information to an information technology (IT) staff member at the CMS 

central office. 

CMS Complaint Processing 

Staff in CMS’s central and regional offices, as well as staff at Medicare 

claims processing contractors (hereinafter referred to as claims 

processing contractors), process complaints referred to CMS by OIG. 

CMS staff and claims processing contractors use an information system 

(a Microsoft Access database) to assign, research, and resolve OIGreferred complaints. The database includes each complaint’s unique 

identifier, date of intake by OIG, date of entry into CMS’s information 

system, date of the complaint’s assignment to a CMS regional office and 

to a claims processing contractor, closure date, and resolution code (if 

applicable). 

Assigning complaints. An IT staff member at the CMS central office 

receives the electronic file from the OIG hotline and uploads it to the 

CMS information system. Using the provider address information in 

the complaint, the information system electronically assigns the 

complaint to the appropriate CMS regional office.1

When a batch of new complaints is pending in the database, an IT staff 

member concurrently sends an electronic notice to alert CMS regional 

office staff and claims processing contractors to assign complaints. 

After receiving the notice, claims processing contractors review the 

complaints. Typically, a claims processing contractor assigns to itself 

any complaints involving claims that it originally paid, a process known 

as “self-assigning.” Any complaints not self-assigned in this manner are 

assigned electronically among the contractors by the CMS regional 

office staff. 

Staff in the CMS central office mail the hardcopy complaint packages to 

the appropriate regional offices. Regional office staff then mail the 

packages to the appropriate claims processing contractors. 

Researching and resolving complaints. Claims processing contractors 

conduct initial research on each complaint to determine such things as 

the amount paid for the claim and patterns of complaints related to an 

1 If the complaint is related to durable medical equipment (DME) or the provider address 

is not available, the complaint is assigned to the CMS regional office that corresponds 

geographically to the beneficiary address. 
INTRODUCTION 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 4 

individual provider. CMS requires claims processing contractors to 

research complaints for services with a claim paid amount of $100 or 

greater. Complaints for services of less than $100 must be retained and 

tracked for 1 year. If a claims processing contractor receives three 

complaints on the same provider within 1 year, the contractor is 

required to conduct an in-depth review of all related complaints.2 

CMS directs claims processing contractors to, within certain 

timeframes, (1) review complaint documentation and (2) determine 

whether fraud and/or abuse is suspected.3 If claims processing 

contractors suspect fraud and/or abuse, they must forward the 

complaint to the Program Safeguard Contractor or Zone Program 

Integrity Contractor (hereinafter referred to as program integrity 

contractors) within 45 business days of receipt of the complaint or 

within 30 business days of receiving medical records, whichever is 

later.4 

To resolve complaints, claims processing contractors use a variety of 

research techniques, such as calling the beneficiary or provider and 

reviewing the claims history.5 Although claims processing contractors 

may begin working on complaints as soon as they are electronically 

assigned, any hardcopy documents associated with a complaint may not 

be available for several weeks because of processing and mailing time. 

CMS does not specify a timeframe within which contractors must 

resolve complaints. 

Updating complaint status. When a complaint is resolved, claims 

processing contractors or program integrity contractors update the 

status of the complaint to “closed” in the CMS database. After this 

update, no further action is taken on a complaint. Some claims 

processing and program integrity contractors notify the complainant of 

the resolution by letter; however, this is not a CMS requirement. 

Periodically, a CMS IT staff member provides OIG with an electronic 

file of the complaint information in CMS’s information system. An OIG 

2 CMS Program Integrity Manual, ch. 4, § 6.2. 

3 CMS Program Integrity Manual, ch. 4, § 6.2. 

4 A provider has 45 days to submit medical records to the contractor. 

5 We use the term “resolve” to indicate that Medicare contractors have completed the 

actions that they are able to take on complaints. For some complaints, these actions may be 

limited, especially if the contractors are unable to contact complainants. 
INTRODUCTION 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 5 

staff member uploads this information to the OIG hotline database, 

thereby updating the status of complaints in OIG’s records. 

METHODOLOGY 

Scope 

This evaluation includes a sample of complaints received through 

1-800-HHS-TIPS during the first 6 months of 2008 that OIG referred to 

CMS. This evaluation excludes complaints that OIG forwarded to its 

field offices, other HHS operating divisions, and other Federal agencies, 

as well as complaints that CMS received from sources other than 

1-800-HHS-TIPS. We did not evaluate OIG hotline processes, including 

its intake process, nor did we evaluate the accuracy of the process of 

forwarding the complaints. 

Sample and Data Sources 

We obtained a copy of the complaint data in CMS’s information system 

as of March 2009. We identified 1,427 complaints that OIG forwarded 

to CMS from January 1 to June 30, 2008. From these, we selected a 

simple random sample of 120 complaints. One year later, in 

March 2010, we obtained a copy of CMS’s information system to check 

the status of complaints at the completion of our data collection. Our 

period of review allowed at least 1 year to elapse after CMS received the 

complaints. 

Data Collection 

Contractor staff. We telephoned staff at each claims processing and 

program integrity contractor (hereinafter referred to as contractor) 

assigned to the sampled complaint(s) to inquire about the initial research 

that the contractor performed on the complaint. We asked contractors 

how and when they contacted the complainant and what outcomes 

(e.g., recouping an overpayment from the provider) resulted from the 

contractors’ actions on complaints. At the same time that we contacted 

contractors about sampled complaints, we conducted structured telephone 

interviews with them about the complaint process. We asked about any 

challenges they had encountered, any circumstances that had impeded 

timely resolution of complaints, and any suggested solutions. We 

interviewed staff from 24 contractors (14 claims processing contractors 

and 10 program integrity contractors). 

CMS central and regional office staff. Upon completing our interviews with 

contractors, we conducted structured interviews with CMS central office 

staff and staff involved in complaint processing from each of the 10 CMS 
INTRODUCTION 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 6 

regional offices.6 We asked CMS staff whether they had encountered any 

challenges when processing complaints, whether any processing changes 

were anticipated or underway, and how feasible the solutions that 

contractors suggested were.

Analysis 

We analyzed contractors’ responses to determine the actions they 

reported taking to resolve the sampled complaints. To ensure that our 

analysis included the most up-to-date information, we used the 

March 2010 version of CMS’s information system to determine the 

reported status of sampled complaints. 

Using data from contractor interviews and data in CMS’s information 

system, we projected the amount of time that elapsed between CMS’s 

receipt of complaints and contractors’ receipt of complaints. 

Limitations 

Using data from CMS’s information system, we contacted the contractor 

assigned to the sampled complaint. In many instances, the contractor 

stated that the complaint had been transferred to another contractor, 

but the contractor to which it had been transferred reported that it had 

no record of the complaint. For this reason, we could not determine 

which contractor researched and/or resolved 16 of the complaints 

(13 percent). Therefore, the information about these 16 complaints is 

limited to data in CMS’s information system. We note that the 

timeframe of our fieldwork intersected with the transition from legacy 

claims processing contractors to Medicare Administrative Contractors 

(MAC), which may have made it more complex for OIG and CMS to 

determine which contractor was responsible for a complaint.7

Standards 

This study was conducted in accordance with the Quality Standards for 

Inspection and Evaluation approved by the Council of the Inspectors 

General on Integrity and Efficiency. 

6 One CMS regional staff member has responsibility for complaint processing in two 

regions. 

7 Section 911 of the Medicare Prescription Drug, Improvement, and Modernization Act of 

2003 requires that CMS replace fiscal intermediary and carrier contracts (legacy claims 

processing contractors) with competitively procured contracts that conform to the Federal 

Acquisition Regulation. P.L. 108-173 § 911, Social Security Act, § 1874A, 42 U.S.C. 

1395kk-l. CMS was given 6 years (between 2005 and 2011) to complete the transfer of 

claims processing activities to MACs. 
Report Template Update: 04-03-08 

 

 

At least 1 year after receiving complaints 

through the 1-800-HHS-TIPS hotline, CMS had 

resolved the majority of them, but 12 percent 

 remained unresolved

 FINDINGS 

As of March 2010, interviews with 

contractors and a review of data in 

CMS’s information system 

confirmed that CMS had resolved 

or closed administratively 

88 percent of complaints. However, CMS had not resolved 12 percent of 

complaints received during the first 6 months of 2008.8 CMS has no 

requirements regarding the length of time within which contractors 

should resolve complaints. Our period of review allowed at least 1 year 

to elapse after CMS received the complaints. 

Of the 15 unresolved complaints, 6 were allegations of fraudulent 

Medicare billing, 6 were complaints of services not rendered, 2 were 

allegations of unlicensed providers, and 1 was a complaint regarding 

unsafe conditions at a clinic. One complaint of services not rendered 

alleged that a hospice provider visited a beneficiary’s home once, but the 

beneficiary decided not to “sign up with their program.” The beneficiary 

received a MSN stating that Medicare paid the provider more than 

$10,000. 

CMS resolved 88 percent of complaints received during the first 6 months 

of 2008 

Overall, 32 percent of complaints were confirmed as services billed in 

error, such as rental charges that continued after the supplier picked up 

a hospital bed from the beneficiary’s home. Contractors collected 

$35,487.60 in overpayments based on these sampled complaints. 

Eleven percent of complaints involved allegations of fraud, such as 

medical studies and tests billed using stolen Medicare identification 

numbers. Outcomes of these complaints included an arrest of a 

provider, termination of a provider from Medicare, seizure of a 

provider’s bank account, and a large monetary settlement with a 

provider. Contractors closed 11 percent of complaints administratively 

(i.e., the complaint was below the $100 threshold, or the information in 

the complaint was not sufficient to conduct further work). For another 

32 percent, contractors researched complaints and found no problems. 

Two percent of complaints were referred to another agency. Table 1 

describes the resolutions of sampled complaints as reported by 

contractors. 

7 

8 Appendix B presents the point estimates and confidence intervals for all statistics. 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 
FINDINGS 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 8 

Table 1: Resolutions of Complaints as Reported by Contractors 

Description of Resolution 

Number of 

Sampled 

Complaints 

(n=120) 

Percentage of 

Complaints 

Allegations researched; no problems found 38 31.7% 

Service(s) billed in error 38 31.7% 

Allegations involved fraud 13 10.8% 

Allegations involved services with claim paid amounts of 

less than $100; complaints closed and retained for 

provider tracking 

7 5.8% 

Information in allegations insufficient; complaints closed 

with no action 6 5.0% 

Complaints referred to another agency 3 2.5% 

Subtotal, resolved complaints 105 87.5% 

Unresolved 15 12.5% 

 Total 120 100.0% 

Source: OIG analysis of contractor interviews and March 2010 version of CMS’s information system, 2010.

Complaint research and resolution. Contractors used a variety of 

methods to research and resolve complaints. For the sampled 

complaints, this included reviewing medical records or other 

documentation requested from the provider, reviewing data in the 

contractor’s internal systems, and interviewing complainants or 

providers by telephone. 

Some complainants submitted hardcopy documents (e.g., MSNs, 

photographs, letters) in support of their allegations. Staff from 17 of the 

24 contractors reported problems with receiving such documents. 

Contractors reported seeing notes in the database saying that 

complainants had submitted hardcopy documents but not receiving the 

documents for 30 to 90 days after complaint assignment, if at all. Not 

receiving the documents can impede resolution of a complaint or cause 

the contractor to request the same documents from the complainant. 

Staff from 2 of the 24 contractors stated that they received hardcopy 

documents after a complaint had been closed and that they had to 

reopen the complaint to evaluate whether the documents changed the 

resolution. In addition to contractors, staff from all 10 CMS regional 
FINDINGS 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 9 

offices reported challenges with handling hardcopy documents, 

including not receiving them in a timely manner and the potential for 

them to be lost.

Complainant contact. Contractors contacted complainants by telephone 

or postal mail for 45 complaints.9 The reasons for contacting 

complainants included acknowledging that a complaint was received 

(9 complaints), interviewing complainants to gain information 

(14 complaints), and notifying complainants of resolution 

(26 complaints). 

Not all contractors notify complainants of the outcomes, and CMS does 

not require them to do so. For a complaint that results in the 

contractor’s adjustment of the provider claim payment (e.g., a complaint 

resolved as “service(s) billed in error”), the beneficiary receives a revised 

MSN indicating the amount of the adjustment. Some contractors 

consider the revised MSN as a notice to the beneficiary (who may or 

may not be the complainant) of the complaint’s resolution. In addition, 

upon receiving a revised MSN, some beneficiaries place another call to 

the hotline because they misinterpret the information on the revised 

MSN as meaning that the provider received an additional payment for 

services. 

Long timeframes and inefficient processes 

delay starting work on complaints 

For a complaint to be resolved, it 

must be assigned to and 

acknowledged by the contractor 

that paid the claim for the service 

in question. Inefficient processes contribute to the delay in assigning 

complaints to contractors, thereby adding to the time it takes to resolve 

complaints. 

For 58 percent of complaints, contractors reported starting work within 

30 days of CMS’s receipt of the complaints from OIG, but for 29 percent of 

complaints, contractors took more than 4 months to start work 

The number of days between the date that a complaint was uploaded to 

CMS’s information system and the date that the contractor reported 

starting work on it ranged from 0 (i.e., uploaded and work started on 

the same day) to 660 days, with an average of 163 days. On average, 

9 Contractors contacted some complainants for more than one reason. 
FINDINGS 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 10 

more than 5 months elapsed between CMS’s receiving complaints from 

OIG and contractors’ starting work on them. 

Table 2 provides an overview of the time it took for contractors to start 

work on complaints after they were uploaded to CMS’s information 

system. Contractors took more than 120 days to start work on 

29.1 percent of complaints. The bulk of the complaints in this 

category—22 percent of all complaints—are those that contractors were 

unaware had been assigned to them. Only following our inquiry did the 

contractors start work on these complaints. During our interview with 

one contractor, OIG staff assisted the contractor staff in identifying 

complaints assigned to them by walking them through certain fields in 

the database. The contractor had been looking only for complaints 

listed under one region, but the contractor was in fact assigned to 

complaints from multiple regions. 

Table 2: Timeframes for Contractors To Start Work on Complaints 

Timeframes for Contractors To Start Work on 

Complaints After Upload to CMS Information 

System 

Number of 

Sampled 

Complaints 

(n=117) 

Percentage of 

Complaints 

Same day–30 days 68 58.1% 

31–120 days 15 12.8% 

Greater than 120 days 34 29.1% 

Source: OIG analysis of contractor interviews and March 2010 version of CMS’s information system, 2010.

CMS’s processes for transmitting complaints to contractors are ad hoc and 

inefficient 

The processing, distribution, and assignment of complaints described by 

CMS and contractors contribute to delays in transmitting complaints 

from the CMS central office to contractors. Such delays add to the time 

it takes to resolve complaints. 

 Batch processing—Complaints are not immediately available to 

contractors when OIG sends the complaints to CMS. An IT staff 

member at the CMS central office must first upload the batch of 

complaints to CMS’s information system; this may add days or 

weeks to the date that the complaints are available to contractors to 

research and resolve. 
FINDINGS 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 11 

 Incomplete distribution list—After uploading the complaints, an IT 

staff member sends electronic notices to the CMS regional office 

staff and to the MACs for which the IT staff member has email 

addresses. However, a CMS IT staff member stated that CMS’s 

electronic distribution list for sending notice of new complaints does 

not contain all contractors. Staff from only 5 of 14 claims processing 

contractors reported that they receive electronic notices of pending 

complaints. Staff from the remaining nine contractors reported that 

they check the information system daily or weekly to determine 

whether new complaints have been assigned to them. 

 Inconsistent timing of complaint assignment—Staff from the 

10 CMS regional offices electronically assign any remaining 

complaints that contractors did not self-assign. Staff from two CMS 

regional offices said that the timing of their assignment of 

complaints is determined by their workload. Staff at a third 

regional office said that they assign complaints within 10 days of the 

electronic notice. Staff from four CMS regional offices indicated that 

they are unsure how long they should wait (to give contractors a 

chance to self-assign complaints) between receiving the electronic 

notice of new complaints and assigning unassigned complaints. 

Lack of guidance and an inadequate information 

system hinder complaint processing 

Long timeframes and inefficient 

processes contribute to delays in 

contractors’ starting work on 

complaints, whereas a lack of 

guidance and an inadequate information system hinder complaint 

processing. Some CMS and contractor staff reported the need for 

written guidance defining their roles and responsibilities for processing 

hotline complaints. Although CMS provides some guidance to 

contractors, some CMS and contractor staff stated that guidance is 

lacking for processing complaints from receipt through resolution. In 

addition, the status of complaints cannot be tracked in CMS’s 

information system. Because there is little written guidance to inform 

CMS and contractor staff on their roles and responsibilities for 

processing complaints and an inadequate information system, CMS and 

contractor staff use inconsistent processes to handle complaints. 
F INDINGS INDINGS 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 12 

CMS and contractor staff lack written guidance defining staff roles and 

responsibilities for processing complaints 

CMS staff. Staff from 8 of 10 CMS regional offices reported that they 

have not received written guidance defining their responsibilities with 

respect to hotline complaints. These staff told us they believed that 

written guidance would improve their work and would ensure consistent 

processes across regions. Staff from one regional office remarked, “It’s 

hard to determine exactly what we’re supposed to do. It’s not all cut 

and dried.” Staff from the other two CMS regional offices told us that 

the guidance they were following had been developed by their regional 

offices as a standard operating procedure; it was not established or 

disseminated by the CMS central office. 

Staff from only three CMS regional offices reported receiving training in 

handling complaints. These individuals reported that the training was 

conducted by their predecessors or other regional staff. Absent written 

guidance and training, many regional staff reported relying on their 

colleagues in other regions for direction and advice. As staff from one 

regional office stated, a typical interaction with a colleague in another 

region might be “to discuss how a particular complaint should be 

handled, since the procedures to resolve [complaints] are not set in 

stone.” 

Regional staff mentioned specific content areas that should be covered 

in the written guidance, such as how to determine to which line of 

business (e.g., Medicare Parts A, B, C, or D, or Medicaid) a complaint 

refers and how to transfer complaints to other contractors when they 

are misassigned or require handling by a program integrity contractor. 

Although staff from all 10 CMS regional offices reported having a 

contact list for contractors, they reported that these lists were 

self-developed and not national in scope. Without written guidance, it is 

difficult for CMS regional staff to assign complaints to the correct 

contractor. 

Contractor staff. Nearly all contractors identified the Program Integrity 

Manual and their internally developed policies and procedures as 

sources of written guidance. However, one-third of contractors reported 

that further guidance on contractor responsibilities could improve their 

operations. For example, staff from one contractor stated, “We are 

unsure about all of our responsibilities. We would like to know what 

CMS explicitly expects us to do.” Staff from another contractor 

remarked, “[We would like] procedures on how CMS would like to see 
Report Template Update: 04-03-08 

 

 

complaints handled, to ensure we are in compliance with what CMS 

wants.” Staff from two CMS regional offices echoed the need for clearer 

guidance to contractors. 

Challenges with CMS’s information system hinder complaint processing 

Staff from each of the 10 CMS regional offices and staff from 15 of the 

24 contractors responded that they have encountered challenges 

working with CMS’s information system. Those most frequently 

mentioned were the inability to track the status of the complaint and 

the inability to determine which contractor is assigned to the complaint, 

as a complaint can be transferred from one contractor to another. This 

affects the ability of CMS and contractor staff to determine what work 

has been done on the complaint and the status of any transfers of the 

complaint to another contractor. As staff from one contractor 

summarized, “We need to be able to know which complaints are actually 

assigned to us and what the status is of each complaint.” Also, when a 

complaint involves more than one provider type (e.g., a physician and a 

DME provider), the information system is unable to indicate that more 

than one contractor is assigned. 

We encountered similar challenges when attempting to identify which 

contractors had been assigned to the sampled complaints. When we 

selected the sample of complaints for review in April 2009, CMS’s 

information system identified no contractor for 24 percent of the sample. 

We used other information in the system to attempt to identify the 

assigned contractor, but for 13 percent of the sampled complaints we 

were unable to do so. 

Contractors reported that they do not use the information system to 

track activities on complaints during their review of allegations; rather, 

they use their internal databases for this purpose. Staff from six 

contractors reported that the CMS information system has inadequate 

fields to store information. 

Staff from four regional CMS offices reported maintaining a record of 

hotline complaints (e.g., an Excel spreadsheet) separate from CMS’s 

information system. These staff reported using such a record for a 

variety of purposes, such as tracking hotline complaint numbers, dates 

of contractor assignment, and dates that hardcopy documentation 

arrives in the regional office and is sent to the contractor. Staff from 

one CMS regional office stated that the information system needs to be 

changed so that for each complaint, it would track which contractor took 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 13 
FINDINGS 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 14 

action, when the action occurred, and why the action was taken, so that 

staff will not have to maintain separate records for these purposes.
Report Template Update: 04-03-08 

 

 

 RECOMMENDATIONS 

CMS widely publicizes the 1-800-HHS-TIPS hotline as an avenue that 

individuals may use to provide information that may assist in 

combating fraud, waste, or abuse in Federal health care programs. 

Health care fraud is estimated to be in the billions of dollars each year. 

HHS emphasizes that Medicare beneficiaries are the front line of 

defense in detecting Medicare fraud because they have firsthand 

knowledge of the health care services they have received. 

At least 1 year after receiving complaints through the 1-800-HHS-TIPS 

hotline, CMS had resolved the majority of them, but 12 percent 

remained unresolved. Long timeframes and inefficient processes delay 

starting work on complaints. Additionally, lack of guidance and an 

inadequate information system hinder complaint processing. 

When researched and resolved, hotline complaints can lead to 

recovering overpayments and identifying fraud. Therefore, it is 

important for CMS to have a clear and consistent approach in place to 

process hotline complaints. 

To address these findings, we recommend that CMS: 

Issue written guidance for processing hotline complaints 

CMS should issue guidance defining the roles and responsibilities of 

CMS and contractor staff and timeframes for assigning, researching, 

and resolving complaints. If applicable, CMS may need to amend 

appropriate contracts to reflect any new contractor requirements, 

responsibilities, and/or timeframes. As part of the guidance, CMS 

should create and maintain a national contact list of contractors, 

including staff names, contact information, and contract numbers 

associated with each contractor. Such a list would assist CMS and 

contractor staff in accurately assigning and transferring complaints to 

contractors. 

Upgrade its information system for processing hotline complaints 

CMS should ensure that its information system tracks user activity on 

each complaint and that the system can handle complaints that have 

multiple provider types and contractors. It should alert CMS when 

complaints have not been assigned. CMS should establish an electronic 

method to deliver hardcopy documents submitted by complainants so 

they are received at the same time as the complaints. 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 15 
Report Template Update: 04-03-08 

 

R E C O M M E N D A T I O N S 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

In its written comments on the draft report, CMS concurred with our 

recommendations. In response to our first recommendation, CMS 

stated that it will create written guidance that defines the specific roles 

and responsibilities for CMS and its contractor staff to achieve greater 

clarity in administration of its database (i.e., its information system). 

Where they are not already established, CMS will establish timeframes 

for assigning, researching, and resolving complaints. CMS stated that 

it is revising its national contractor list to include contact names and 

contract numbers associated with the contractors. As appropriate, CMS 

will amend contracts to reflect any new contractor requirements, 

responsibilities, or timeframes. In response to our second 

recommendation, CMS stated that it is upgrading and updating the 

database with the following features: auditing mechanisms to track 

user activity, contractor assignments, and status of complaints; the 

ability to handle complaints that have multiple provider types and 

contractors; and the capacity to alert CMS when complaints have not 

been assigned. CMS stated that it will work with OIG to establish an 

electronic method to deliver hardcopy evidence received from 

complainants along with the electronic complaint. We did not make any 

changes to the report based on CMS’s comments. The full text of CMS’s 

comments on the draft report can be found in Appendix C.

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 16 
Report Template Update: 04-03-08 

 

 

 APPENDIX ~ A 

Flowchart of Processing of Complaints Received Through the 

1-800-HHS-TIPS Hotline and Referred to the Centers for 

Medicare & Medicaid Services* 

Hardcopy

CMS central office staff sort documents

and mail to regional office staff**

Electronic

CMS central office IT staff upload file to CMS

database, and complaints are electronically

assigned to CMS regional offices; regional office

staff and contractors are electronically notified of

new complaints

Regional office staff sort documents and

mail to appropriate contractor and assign

remaining complaints to contractors**

Contractor staff self-assign complaints in their

jurisdiction; regional office staff assign remaining

complaints

Contractor staff research and resolve

complaints; notify complainants of

resolution; update status of the

complaints in the CMS database

Concurrently, OIG mails to CMS central office the

complaint cover sheet and hardcopy documentation

packages and sends an electronic file of complaint

information to CMS IT staff

Complainant calls or writes to the hotline; OIG

determines whether the issue rises to the level of a

complaint; if it does, information is entered into OIG

hotline database; OIG analyst reviews database

information and generates a cover sheet for each

complaint

*CMS. 

**Sorting and mailing often occur after electronic notice. 

Source: Office of Inspector General (OIG) interviews, 2009.

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 17 
Report Template Update: 04-03-08 

 

 

 APPENDIX ~ B 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 18 

Table B-1: Point Estimates and Confidence Intervals

Statistic Sample 

Size 

Point 

Estimate 

95-Percent 

Confidence Interval 

Percentage of complaints not resolved by the Centers for Medicare 

& Medicaid Services (CMS) 

120 12.5% 7.8%–19.5% 

Percentage of complaints resolved by CMS 120 87.5% 80.5%–92.2% 

Percentage of complaints with allegations researched and no problems 

found 

120 31.7% 24.2%–40.2% 

Percentage of complaints confirmed as services billed in error 120 31.7% 24.2%–40.2% 

Percentage of complaints confirmed as illegal activity 120 10.8% 6.5%–17.5% 

Percentage of complaints with allegations involving services with claim 

paid amounts of less than $100; complaints closed and retained for 

provider tracking 

120 5.8% 2.9%–11.5% 

Percentage of complaints with insufficient allegation information; 

complaints closed with no action 

120 5.0% 2.3%–10.5% 

Percentage of complaints referred to another agency 120 2.5% 0.8%–7.2% 

Average number of days between the date that complaints were 

uploaded to CMS’s information system and the date that contractors 

reported starting work on them 

117 163.2 days 121.2 days–205.3 days 

Percentage of complaints that contractors were unaware had been 

assigned to them 

120 21.7% 15.4%–29.7% 

Percentage of complaints on which contractors started work the same 

day to 30 days after CMS uploaded them to its information system 

117 58.1% 49.3%–66.5% 

Percentage of complaints on which contractors started work between 

31 days and 120 days after CMS uploaded them to its information 

system 

117 12.8% 8.0%–19.9% 

Percentage of complaints on which contractors started work more than 

120 days after CMS uploaded them to its information system 

117 29.1% 21.8%–37.6% 

Source: Office of Inspector General (OIG) analysis of simple random sample of 120 complaints forwarded from OIG to CMS, 2010.
A P PEN D x c 


AGENCY COMMENTS 

DEPARTMENT OF HEALTH & HUMAN SERVICES Centers tor Medicare & Medicaid Services 

Administrator 

Washington. DC 20201 

JAN 1 9 2011 

DATE: 

TO: Daniel R. Levinson 

Inspector General 

FROM.: Donald M. Berwick, M.D. 

Administrator 

SUBJECT: 	 Office ofInspector General (OIG) Draft Report: "eMS' Processing of 

Complaints Received Through the I-SOO-HHS-TIPS Hotline" (OEl-07-09-00020) 

The Centers for Medicare & Medicaid Services (eMS) appreciates the opportunity to review and 

comment on the Office of Inspector General (orG) draft report entitled "eMS' Processing of 

Complaints Received through the I-SOO-HRS-TIPS Hotline." The purpose of this report was to 

evaluate complaints received through the 1-800-HHS-TIPS Hotline, which individuals may llse 

to provide infonnation that may assist in combating fraud, waste, and abuse in the Department of 

Health and Human Services programs (Le., Medicare, Medicaid, Head Start and child support 

enforcement). 

The eMS takes complaints received from the 1-800-HHS-TJPS Hotline and from other sources 

seriously. These complaints play an important role in helping eMS and OIG in reducing and 

fighting fraud, waste, and abuse in the Medicare Program. Some complaints lead to new 

investigations and/or are incorporated into existing investigations. These complaints are also 

used to support revocation. deactivation, and/or suspension actions taken against providers and 

suppliers. 

The report accurately reflects the current process by which eMS and its contractors handle these 

referrals and in identifying the areas where improvement is needed. CMS has already begun 

working to update, standardize, and improve the current internal handling and oversight 

monitoring procedures to address a number ofthe concerns expressed in the report. Additional 

system changes are in development that will allow more effective screening, tracking of user 

activity, contractor assignments, and complaint status. We are working with OIG on many of 

these changes. 

We appreciate the orG's efforts in working with eMS to assist in the complaints process. Our 

response to each orthe 010 recommendations follows. 

OEI·07·09·00020 CMS's PROCESSING OF COMPLAINTS RECEIVED THROUGH 1·800·HHS·TlPS 19 
APPENDIX ~ C 

Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 20 
Report Template Update: 04-03-08 

 

 

 O E I - 0 7 - 0 9 - 0 0 0 2 0 C M S ’ S P ROCESSING OF C OMPLAINTS RECEIVED T HROUGH 1-800-HHS-TIPS 21 

 ACKNOWLEDGMENTS 

This report was prepared under the direction of Brian T. Pattison, 

Regional Inspector General for Evaluation and Inspections in the 

Kansas City regional office, and Deborah K. Walden, Deputy Regional 

Inspector General. 

Tricia Fields served as the team leader for this study. Other principal 

Office of Evaluation and Inspections staff from the Kansas City regional 

office who contributed to the report include LCDR Mike Garner and 

Dennis Tharp; central office staff who contributed include Robert 

Gibbons, Scott Manley, Megan Ruhnke, and Arianne Spaccarelli. 
Report Template Update: 04-03-08 

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.