Department of Health and Human Services

OFFICE OF

INSPECTOR GENERAL

OVERSIGHT OF PRIVATE 

HEALTH INSURANCE 

SUBMISSIONS TO THE 

HEALTHCARE.GOV 

PLAN FINDER

Daniel R. Levinson 

Inspector General

April 2013

OEI-03-11-00560 
EXECUTIVE SUMMARY: OVERSIGHT OF PRIVATE HEALTH INSURANCE 

SUBMISSIONS TO THE HEALTHCARE.GOV PLAN FINDER

OEI-03-11-00560

WHY WE DID THIS STUDY 

The HealthCare.gov Plan Finder is the first comprehensive, online portal that assists consumers in 

comparing their health insurance coverage options. All private health insurers in the individual and 

small group markets are required to submit information to populate the Plan Finder. The data 

collection conducted by the Centers for Medicare & Medicaid Services (CMS) to populate the Plan 

Finder represents the first national attempt to identify these insurers and the products and plans they 

offer. To realize the benefits of expanded consumer information, the data displayed on the Plan Finder 

must be complete and accurate. 

HOW WE DID THIS STUDY

We reviewed CMS’s policies and procedures, survey responses, and interview responses regarding 

oversight of insurers’ data submissions. We selected a purposive sample of 98 small group products 

and 94 individual plans displayed on the Plan Finder for its November 2011 and January 2012 updates, 

respectively. For each sampled product and plan, we identified aberrant or inconsistent data displayed 

on the Plan Finder and determined whether displayed data were consistent with information provided

by insurers’ telephone customer service representatives.

WHAT WE FOUND

Most private insurers reported data to the Plan Finder. However, gaps exist in CMS’s oversight of 

private insurers’ compliance with Plan Finder reporting requirements. CMS did not conduct targeted 

followup with insurers that did not report detailed pricing and benefit information. CMS also has not

been able to identify the entire population of insurers required to report basic company and product 

information. In addition, CMS has not asked insurers to certify to the completeness of submitted data

in accordance with Federal regulation. CMS implemented numerous strategies to monitor data 

accuracy. However, the data displayed on the Plan Finder for the sample of products and plans 

contained some inconsistencies that may confuse consumers. The products and plans displayed were 

not always available for sale or were not always recognized by insurers’ representatives. When 

products and plans were available and were recognized, 81 percent of their data displayed on the Plan 

Finder matched the information provided by insurers’ representatives. 

WHAT WE RECOMMEND

Our findings indicate that additional efforts are needed to oversee private insurers’ compliance with 

reporting requirements for the HealthCare.gov Plan Finder and to ensure that the data displayed on the 

Plan Finder are accurate. Therefore, we recommend that CMS: (1) establish and implement 

procedures to identify and pursue private insurers that do not submit required data to the Plan Finder,

(2) ensure that each private insurer’s Chief Executive Officer or Chief Financial Officer certifies to the 

completeness of data submitted to the Plan Finder, (3) design and implement additional strategies to 

ensure Plan Finder data accuracy, and (4) validate that products and plans submitted to the Plan Finder 

are available for sale. CMS generally concurred with our recommendations and is taking steps to 

address them. 
TABLE OF CONTENTS

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

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

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

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

Gaps exist in CMS’s oversight of private insurers’ reporting of 

required data to the HealthCare.gov Plan Finder.............................8

Although CMS implemented numerous measures to oversee 

data accuracy, the data displayed on the Plan Finder contained 

some inconsistencies......................................................................10

Not all of the products and plans displayed on the Plan Finder 

were available for sale or were recognized by insurers’ 

representatives................................................................................14

Eighty-one percent of product and plan data displayed on the

Plan Finder matched information provided by insurers’ 

representatives................................................................................14

Conclusion and Recommendations............................................................17

Agency Comments and Office of Inspector General Response.....20

Appendixes ................................................................................................21

A: Plan Finder Data Fields Included in Office of Inspector 

General Review of Information Provided by Insurers’ 

Representatives..............................................................................21

B: Agency Comments...................................................................22

Acknowledgments......................................................................................25
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 1

OBJECTIVES

1. To determine the extent to which the Centers for Medicare & Medicaid 

Services (CMS) oversees private health insurers’ compliance with 

reporting requirements for the HealthCare.gov Plan Finder.

2. To determine whether selected data displayed on the HealthCare.gov 

Plan Finder are consistent with other consumer information provided 

by private insurers.

BACKGROUND

The health care reforms enacted in 2010 seek to increase informed 

consumer choice by improving Americans’ access to information about 

available health insurance options.1 Section 1103 of the Affordable Care 

Act (ACA) requires the Secretary of Health and Human Services to 

establish a health insurance Web site portal that presents health insurance 

information in a standardized format and enables comparison of coverage 

options.

2, 3

 Information on coverage options must include private health 

insurance information, as well as government-administered health 

insurance information, such as Medicaid, the Children’s Health Insurance 

Program, State high risk pools, and the Pre-Existing Condition Insurance 

Plan. Data collection and maintenance of the Web site portal, the 

HealthCare.gov Plan Finder, is managed by the Center for Consumer 

Information and Insurance Oversight (CCIIO) within CMS.

4

The Plan Finder is the first comprehensive, centralized, online portal that 

assists American consumers in comparing insurance coverage options. In 

addition, the Plan Finder has the potential to increase the sale of private 

health plans to uninsured individuals and promote market competition to 

improve health coverage choices for all Americans.5 Realizing the benefits 

of expanded consumer information is contingent upon the completeness 

1 75 Fed. Reg. 24471 (May 5, 2010).

2 The Patient Protection and Affordable Care Act (P.L. 111-148) and the Health Care and 

Education Reconciliation Act (P.L. 111-152) are collectively referred to as the Affordable Care 

Act.

3 As specified in 45 CFR § 159.110, health insurance coverage is defined according to 

section 2791(b)(1) of the Public Health Service Act as “benefits consisting of medical care 

(provided directly, through insurance or reimbursement, or otherwise and including items and 

services paid for as medical care) under any hospital or medical service policy or certificate, 

hospital or medical service plan contract, or health maintenance organization contract offered 

by a health insurance issuer.”

4 HealthCare.gov is a Federal Web site that contains information about public and private 

health insurance options across the Nation, connects consumers to quality rankings for health 

care providers, and explains the provisions and key features of the ACA.

5 75 Fed. Reg. 24481 (May 5, 2010).
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 2

and accuracy of the private sector health insurance data populating the Plan 

Finder. Section 1311 of the ACA requires the Secretary to continue to 

operate, maintain, and update the Plan Finder.

Although the Plan Finder is not a transactional Web site from which 

consumers can purchase private insurance, its formats and tools for 

displaying insurance information can inform State and Federal decisions in 

the development of Affordable Insurance Exchanges.

6, 7

 The Exchanges

will serve as competitive marketplaces for consumers to compare and 

purchase health insurance.8 According to HHS, open enrollment in the 

Exchanges will begin on October 1, 2013. The Congressional Budget 

Office (CBO) estimates that by 2016, 24 million Americans will receive

health coverage through the Exchanges.9

The HealthCare.gov Plan Finder

Today, consumers seeking information about private health insurance

options are using the Plan Finder as an education tool to find and compare 

health plans. The Plan Finder was publicly launched on July 1, 2010, and 

had approximately 2 million visitors from July 2010 to July 2011. As of 

March 2013, it housed information on more than 8,000 private health 

insurance products offered within the small group market and the 

individual market. The individual market sells health insurance to 

individuals and families seeking coverage, and the small group market sells 

health insurance to small businesses seeking coverage for their 

employees.10

Private insurers were first required to submit data to the Plan Finder in May 

2010.

11 Since that time, CMS has collected updated information from 

private insurers multiple times throughout each year. From July to 

September 2010, the Plan Finder displayed an initial set of basic 

information on private health insurance companies and their products. For 

6 Ibid.

7 Each State will have an Exchange that is operated by the State, by the State in 

partnership with the Federal Government, or by the Federal Government.

8 ACA § 1321(c) and 77 Fed. Reg. 18310 (March 27, 2012).

9 CBO, Estimate of the Effects of the Affordable Care Act on Health Insurance Coverage, 

February 2013. Accessed at http://www.cbo.gov on March 21, 2013. 10 45 CFR § 159.110 adopts the definitions of the terms “individual market” and “small 

group market” found in ACA section 1304(a)(2) and ACA section 1304(a)(3), 

respectively. The term “individual market” is defined as the market for health insurance 

coverage offered to individuals other than in connection with a group health plan. The 

term “small group market” is defined as the market under which individuals obtain health 

insurance coverage (directly or through an arrangement) on behalf of themselves (and 

their dependents) through a group health plan maintained by a small employer.

11 45 CFR § 159.120(a). The regulation text includes the term “health insurance issuers.” 

In this report, we use the term “insurers,” rather than “issuers.” 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 3

purposes of the Plan Finder, products are defined as packages of benefits 

that a private insurer offers that have been reported to State regulators in an 

insurance filing.

12,13 Each health insurance product may have multiple plan 

options. Plans may differ in their premiums, cost-sharing options, types of 

services covered, coverage limitations, and exclusions. The Plan Finder 

began displaying detailed pricing and benefit information for the individual 

market in October 2010 and for the small group market in November 2011. 

For Plan Finder data collection, storage, and maintenance, CMS contracts 

with an information technology and business process services firm. 

According to CMS, the estimated cost of development, operation, and 

management of the data systems that support the Plan Finder and other 

HealthCare.gov functions was $17.2 million for fiscal year 2012.

14 

Federal Requirements for Reporting Private Insurance Data 

Data Submission Requirements. To populate the Plan Finder, all private 

insurers must submit data that provide consumers with information on 

health insurance coverage options.15 The data submission requirements 

apply to health insurance sold in both the individual and small group 

markets in each of the 50 States and the District of Columbia. Private 

insurers must submit:

• Basic health insurance company and product information, including 

enrollment data, geographic availability, and Web site links to provider 

networks. Insurers submit these data electronically to CMS using the

Health Insurance Oversight System.

• Detailed pricing and benefit information on premiums, cost-sharing, 

types of services covered, coverage limitations, and exclusions for each

health insurance plan. Insurers submit these data electronically to CMS 

using the Rate and Benefits Information System.

Insurers must report basic health insurance information prior to reporting 

detailed pricing and benefit information about their products and plans. 

For the individual market, the Plan Finder displays detailed pricing and 

benefit information by health insurance plan. According to CMS, small 

group market insurers do not generally sell or track pricing and benefit 

12 45 CFR § 159.110. 13 States are primarily responsible for oversight of the private health insurance industry. 

State regulators ensure that products comply with State law and do not contain major gaps 

in coverage that might be misunderstood by consumers. CMS does not have the authority 

to actively solicit State involvement to ensure that products submitted to Plan Finder have 

been reported to State regulators.

14 These data systems are used to support other CMS efforts related to ACA

implementation in addition to the HealthCare.gov Plan Finder. The Plan Finder is one of 

several components of the HealthCare.gov Web site.

15 45 CFR § 159.120.
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 4

information by plan. Therefore, in an effort to reduce insurers’ data 

collection burden, CMS collects and displays detailed pricing and benefit 

information for the small group market by health insurance product. For a 

product with multiple plan options, the Plan Finder displays the range of 

deductible, out-of-pocket limit, copayment, and co-insurance options 

offered for the plans associated with that small group product.

In addition to current data submission requirements, future releases of the 

Plan Finder will include performance rating indicators for products and 

plans, such as the percentage of policies rescinded, the percentage of 

claims denied, and the number and disposition of appeals.16 Private 

insurers are not yet required to submit performance rating indicators. 

Data Validation Requirements. Insurers must verify the data submitted to 

the Plan Finder and make corrections to any errors that are found.17 In 

addition, regulations require that each insurer’s Chief Executive Officer 

(CEO) or Chief Financial Officer (CFO) electronically certify to the 

completeness and accuracy of all data submitted.

18 

Related Studies

In 2009, an OIG study identified inaccurate drug prices displayed on the 

Web-based Medicare Part D plan comparison tool that Medicare 

beneficiaries use to find, compare, and select Part D prescription drug 

plans.19 In response, CMS modified information that appears to consumers 

regarding the accuracy of the Part D drug cost estimates provided on the 

Web-based tool.

METHODOLOGY

Scope

We examined CMS’s oversight of private health insurers’ compliance with 

Plan Finder reporting requirements and determined whether selected data 

displayed on the Plan Finder were consistent with other consumer 

information provided by private insurers. We limited our review to health 

insurance data reported by private insurers to the Plan Finder—specifically,

small group market data that were on display from November 15, 2011, to 

March 1, 2012, and individual market data that were on display from 

January 19, 2012, to April 12, 2012. CMS identifies an “insurer” as a 

private health insurance company operating within a State. For purposes of 

16 45 CFR § 159.120(f). 17 45 CFR § 159.120(e). 18 45 CFR § 159.120(g).

19 OIG, Accuracy of Part D Plans’ Drug Prices on the Medicare Prescription Drug Plan 

Finder, OEI-03-07-00600, July 2009. 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 5

our review, if a single company operates in 5 States in both the small group 

and individual markets, we considered it as 10 insurers.

Data Collection 

Documentation, Survey, and Interview Data. We obtained current written 

policies and procedures that CMS uses to oversee private insurers’ 

compliance with Plan Finder reporting requirements. CMS completed two 

self-administered surveys and responded to in-person interview questions 

regarding private insurers’ data submissions and CMS’s oversight activities

for the individual and small group markets. 

Source Data Populating the Plan Finder Display. We obtained from CMS

the source data populating the Plan Finder display for the individual and 

small group markets. The source data included detailed health insurance 

pricing and benefit information submitted by 545 small group market

insurers and 310 individual market insurers, for a total of 855 submissions.

CMS indicated that it expected 1,026 insurers to submit detailed health 

insurance information for the Plan Finder update periods in our review. 

Only 897 insurers actually submitted this detailed information. However, 

CMS displayed information on the Plan Finder for 855 of these insurers 

because some insurers’ data submissions did not pass CMS’s validation 

process.

20 

Data Displayed on the Plan Finder. From the Plan Finder, we collected 

information for selected data fields for 94 individual plans and 98 small 

group products. Where possible, this purposive sample included products

and plans offered by two insurers for each State and the District of 

Columbia in both the individual and small group markets.

21, 22 We designed

our sample to include a greater proportion of insurers with higher levels of 

health insurance market share within each State. Of the 192 products and 

20 For the November 2011 update of the small group market data displayed on the Plan 

Finder, CMS provided a source data file on December 12, 2011. For the January 2012 

update of the individual market data displayed on the Plan Finder, CMS provided a source 

data file on February 9, 2012.

21 During the review period, the Plan Finder did not display information for any individual 

market insurers in Rhode Island and displayed information for only one individual market 

insurer in Alabama, Idaho, Minnesota, Montana, New Hampshire, and Vermont, 

respectively. Therefore, 94 individual market plans were included in our sample. 22 We initially selected a sample of 102 small group market products. However, for 

four sampled products, we could not reach a representative during our data collection 

period who was willing and able to answer our questions. Therefore, our sample included 

98 small group market products. 
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 6

plans in our sample, 122 were offered by insurers with more than 5 percent 

of their States’ market shares.

23

Information Provided by Insurers’ Representatives. For each sampled

product and plan, we called the insurer’s customer service telephone 

number and asked to speak with a representative who could answer specific 

questions about products or plans. If transferred by an operator, we 

considered the person to whom we were transferred to be a “customer 

service representative.” We collected information from these 

representatives regarding individual plan and small group product data 

fields displayed on the Plan Finder. Appendix A provides a list of the Plan 

Finder data fields selected for review.

Analysis 

We reviewed and summarized CMS’s policy and procedure documentation,

survey responses, and in-person interview responses regarding private 

insurers’ Plan Finder data submissions and CMS’s oversight activities. 

For each product and plan in our sample, we calculated rates of consistency 

between the data displayed on the Plan Finder and the information

provided by insurers’ representatives by dividing the number of matching

data fields by the total number of data fields included in our review. After 

calculating a consistency rate for each product and plan, we calculated the 

average consistency rate across all products and plans. 

For each data field under review, we calculated the percentage of products 

and plans for which the data values displayed on the Plan Finder matched

the information provided by insurers’ representatives. In some cases,

insurers’ representatives did not know the answer to or did not answer one 

or more of the questions asked about sampled products and plans. We did 

not include missing data values in the denominator when calculating the 

consistency rate for a product or plan or the consistency rate for a data 

field.

In addition, we determined whether there were aberrant or inconsistent data 

values in selected data fields displayed on the Plan Finder for each product 

and plan in our sample using two different analyses:

• We compared the data displayed on the Plan Finder to the data 

submitted by insurers to identify any discrepancies. 

23 In measurement of health insurance market competition, 5 percent is considered a threshold 

signaling that an insurer controls sufficient market share to form provider networks and 

achieve brand awareness for growth in the future. Kaiser Family Foundation, How 

Competitive are State Insurance Markets?, October 2011. Accessed at 

http://www.kff.org/healthreform/upload/8242.pdf on September 5, 2012. 
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 7

• We compared the data displayed on the Plan Finder across products and 

plans to check for extremely high or low values in specific data fields. 

We also reviewed the Plan Finder display for each product and plan in 

our sample to identify logical inconsistencies between the values of 

related data fields. For example, if a plan’s data fields for drug 

coverage indicated that the plan did not cover drugs, but a drug 

formulary list was included on the plan’s display, we would consider 

this to be an inconsistency between values of related data fields. 

Limitations

Although we used randomization where possible to minimize bias in our 

selection of product and plans, our purposive sample of 192 products and 

plans is not representative of all products and plans on the Plan Finder 

display. We also did not validate the information provided by insurers’ 

customer service representatives. Finally, to minimize respondent burden 

for insurers’ telephone representatives, we did not include all data fields for

individual plans and small group products displayed on the Plan Finder in 

our review. 

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.
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 8

FINDINGS

Gaps exist in CMS’s oversight of private insurers’ 

reporting of required data to the HealthCare.gov Plan 

Finder

Thirteen percent of private health insurers that CMS expected to report data 

did not submit pricing and benefit data to the HealthCare.gov Plan Finder

in November 2011 and January 2012. CMS did not conduct targeted

followup with these insurers. In addition, CMS has not required insurers to 

meet the stipulation in the Federal regulation that insurers’ CEOs or CFOs 

certify to the completeness of all submitted data. With respect to oversight 

of insurers’ compliance with reporting basic company and product 

information to the Department of Health and Human Services (HHS), CMS

has not been able to identify the entire population of private insurers 

required to report.24

Thirteen percent of private insurers did not submit pricing and 

benefit data to the Plan Finder 

Of the 1,026 insurers that CMS expected would report specific pricing and 

benefit information for the individual and small group markets, 129, or 

13 percent, did not submit these data. These 1,026 insurers had submitted 

basic health insurance information to the Plan Finder in the past and, 

therefore, were expected to submit detailed pricing and benefit information. 

Without submitting pricing and benefit data, an insurer cannot be displayed 

on the Plan Finder. Therefore, during our review periods, there were 

129 private insurers with potential health insurance offerings that were not

on the Plan Finder. As shown in Table 1, the percentage of insurers that did 

not submit these detailed data was greater among insurers from the 

individual market (21 percent) than that from the small group market 

(7 percent). 

Table 1: Private Insurers’ Compliance With Requirement To Report Specific Pricing 

and Benefit Information to the HealthCare.gov Plan Finder

Health Insurance 

Market

Number of Insurers 

Expected To Report 

Pricing and Benefit Data 

Number of Insurers 

That Did Not Report 

Pricing and Benefit Data 

Percentage of Insurers 

That Did Not Report 

Pricing and Benefit Data 

Individual Market, 

January 2012 Update 395 84 21%

Small Group Market, 

November 2011 Update 631 45 7%

Totals 1,026 129 13%

Source: Office of Inspector General (OIG) survey of CMS/CCIIO staff, 2012.

24 45 CFR §§ 159.100, 159.110, and 159.120. 
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 9

CMS did not conduct targeted followup with private insurers 

that did not submit pricing and benefit information to the Plan 

Finder

CMS did not conduct targeted followup with 128 of the 129 private health 

insurers that did not report pricing and benefit information for their 

products and plans. For the small group market, CMS contacted one 

insurer for failing to submit pricing and benefit information. This insurer 

indicated that the employee responsible for reporting data to the Plan 

Finder had been replaced, which led to confusion among staff about 

data-reporting responsibilities. The insurer indicated that it would report 

its pricing and benefit information in the next Plan Finder data collection 

period. For the individual market, CMS did not conduct targeted followup 

with any insurers that did not submit pricing and benefit information for

the January 2012 display period.

CMS has not required insurers to certify to the completeness of 

the data they submit to the Plan Finder 

Each insurer’s CEO or CFO must certify to the completeness and accuracy 

of all data submitted to HHS for display on the Plan Finder.25 However, 

CMS has not required CEOs or CFOs to certify to the completeness of the 

data submitted since the launch of the Plan Finder in July 2010. For all 

Plan Finder data collection periods from July 2010 through January 2012, 

insurers were required to certify only to the accuracy of the data submitted 

as a condition of displaying the data on the Web site.26 

According to CMS, its decision not to require insurers to certify to data 

completeness stems from the specification that insurers must submit 

information on—at a minimum—all plans that are open for enrollment and 

represent 1 percent or more of the insurer’s total enrollment within a ZIP

Code. According to CMS, most private health insurers do not track 

enrollment at the plan level and therefore feel they are unable to certify

with certainty that they have submitted all of the plans that represent 

1 percent or more of their total enrollment in a given ZIP Code. 

25 45 CFR § 159.120(g). 26 HHS, Revised Language for CEO/CFO Attestation of CMP [Content Management 

Portal] Data, September 22, 2010. Accessed at 

http://cciio.cms.gov/resources/files/notice_revised.pdf on November 18, 2011.
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 10

CMS has not been able to identify the entire population of 

insurers that are required to report basic health insurance 

information to the Plan Finder 

CMS has not been able to identify the entire population of private insurers 

subject to the reporting requirement and therefore cannot oversee insurers’ 

compliance with the requirement to report basic health insurance company 

and product information to HHS. For the November 2011 and January 

2012 Plan Finder updates, CMS did not have a mandatory standard process 

to identify the insurers that may be required to report basic health insurance 

data to the Plan Finder. 

According to CMS, there is no existing reference that it can use to identify 

the total population of insurers required to report to the Plan Finder. In 

addition, ambiguity in the insurance market and across States surrounding 

the definition of a health insurance product makes it difficult for CMS to 

construct such a reference. However, CMS has made prior attempts to 

identify insurers subject to Plan Finder reporting requirements using data 

collected by organizations such as the National Association of Insurance 

Commissioners, America’s Health Insurance Plans, and the Blue Cross and 

Blue Shield Association. 

CMS expects that the introduction of other Federal efforts to collect private 

health insurance information—including data collections for reviews of 

insurance rate increases, medical loss ratios, Health Plan Identifiers, and 

the Affordable Insurance Exchanges—may improve CMS’s ability to 

identify the population of health insurers across the Nation.

27

Although CMS implemented numerous measures to 

oversee data accuracy, the data displayed on the Plan 

Finder contained some inconsistencies

During the data collection periods for the November 2011 and 

January 2012 Plan Finder updates, CMS incorporated data quality checks 

into the data-reporting process for private insurers. CMS held insurers 

accountable for not resolving identified data quality problems by 

suppressing their health insurance product and plan information from 

display on the Plan Finder. Despite these oversight efforts, the data 

displayed on the Plan Finder for our sample of 192 products and plans 

27 A medical loss ratio is the percentage of insurance premiums that an insurer spends on 

health care services and activities to improve health care quality. The ACA generally 

requires that insurers spend 80 percent or 85 percent of insurance premiums on health care 

services and quality improvement. HHS, Health Insurance Basics: Your Insurance 

Company & Costs of Coverage. Accessed at http://companyprofiles.healthcare.gov/ on 

March 21, 2013.
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 11

contained aberrant or inconsistent values that may be confusing or 

misleading to consumers.28 

CMS employed multiple strategies to monitor data accuracy 

and held insurers accountable by suppressing data from the 

Plan Finder display 

To oversee data accuracy during the review period, CMS: 

• conducted training sessions, held weekly user group calls, and made 

staff available to help insurers understand how to submit accurate data; 

• embedded quality checks into the data entry templates that insurers 

used to submit their data; 

• applied to all submitted data templates an automated system validation 

process that conducted quality checks and checked that each insurer

submitted all necessary data; 

• required that insurers review and verify the accuracy of submitted 

information;

29 

• conducted post-submission quality checks of four data fields to 

determine whether the data values appeared as expected; 

• tested the Web site links for the brochures, drug formularies, and 

provider networks submitted by insurers to determine whether the links 

were functional, direct, and accurate; 

• maintained communication channels through the Web site, email, and 

telephone through which consumers, insurers, and State insurance 

regulators could inform CMS of potential data errors on the Plan 

Finder; and

• made the review of insurers’ product information available to States’ 

Departments of Insurance through an online data system. 

During the review period, CMS suppressed submitted private health 

insurance data from the Plan Finder display for the following reasons: 

• One insurer did not pass the automated system validations applied to 

submitted data templates. This insurer’s data did not progress through 

the data submission process and therefore were suppressed from the 

Plan Finder display. 

28 The sample of 192 products and plans was selected from source data files provided by 

CMS. As described on page 5 of the methodology, the files contained detailed pricing and 

benefit information for 855 insurers displayed on the Plan Finder during our review period 

(545 small group market insurers and 310 individual market insurers). 

29 If the insurer identified errors in the submitted data, CMS instructed the insurer to

resubmit and reverify the data. 
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 12

• CMS suppressed 41 insurers’ data from the Plan Finder display because 

the insurers did not verify the accuracy of submitted data. Of these 

insurers, 40 operated in the small group market. 

• CMS did not display at least 1 link for each of 108 insurers that failed 

testing on the Plan Finder Web site, but posted a note stating that 

insufficient link information was provided. 

• CMS received two reports, both initiated by State regulators, about 

potential errors in the small group market data displayed on the Plan 

Finder. One of these reports led to CMS’s suppression of one insurer’s 

data from the Plan Finder display. 

Despite CMS’s efforts to oversee data accuracy, 

inconsistencies appeared in the Plan Finder displays reviewed

The Plan Finder included aberrant and inconsistent information that may 

confuse consumers and undermine the Plan Finder’s utility as a consumer 

education tool. In the sample of products and plans, aberrant or 

inconsistent data values were associated with 3 data fields on the Plan 

Finder displays for the small group market and with 13 data fields on the 

displays for the individual market. One or more of these inconsistencies

were reflected on the Plan Finder displays for 127, or two-thirds, of the 

192 products and plans reviewed. 

• For 89 individual plans, insurers reported to CMS that limitations and 

exceptions may apply to at least 1 of 9 benefits that are displayed for 

each individual market plan on the Plan Finder.30 However, for these 

89 plans, the corresponding Plan Finder displays indicated that 1 or 

more of these 9 benefits were “Included Benefits” with no limitations 

or exceptions.31 This systematic inconsistency between the data that

insurers submitted to CMS and the data actually displayed on the Plan 

Finder can be misleading to consumers. For example, a consumer 

viewing the Plan Finder display for one of these plans may think that 

the plan fully covers home health care services when the data that the 

insurer submitted to CMS indicate that this benefit may be restricted in 

some way. 

• For 36 small group products and 17 individual plans, the names of the 

products and plans that appeared on the Plan Finder display did not 

30 The data fields for the nine benefits were: Dental Checkup for Children, Durable 

Medical Equipment, Eyeglasses for Children, Habilitation, Home Health Care, Hospice, 

Inpatient Rehabilitation, Outpatient Rehabilitation, and Routine Eye Care for Children.

31 Each of these benefits is listed on the Plan Finder display in one of four mutually

exclusive coverage categories: “Included Benefits,” “Excluded Benefits,” “Limited 

Benefits,” or “Benefits Available for Purchase at Additional Cost.”
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 13

match the names on the insurers’ brochures that were linked to the 

display.32 For some small group products, the entire product name on 

the Plan Finder display did not appear in the brochure. If consumers 

cannot identify a product or plan in the insurer’s brochure on the basis

of the name displayed on the Plan Finder, they may be confused as to 

whether the product or plan is actually offered by the insurer. 

• Seven individual plans had a null value (either “$0.00” or “No 

Maximum”) displayed in the data field for In-Network Out-of-Pocket 

Limit, but had specific elements listed as contributing to the 

out-of-pocket limit in the data field for In-Network Out-of-Pocket 

Limit Elements.

33 It is unclear why these elements would be listed for a 

plan without an out-of-pocket limit. 

• For four individual plans, all of their drug coverage data fields (Generic 

Drugs, Preferred Brand Drugs, and Specialty Drugs) on the Plan Finder 

display indicated that drugs were “Not Covered” by the plan. 

However, these plans had drug formulary Web site links posted on their 

displays. It is confusing when a plan that appears to lack drug coverage 

has a link to a list of covered drugs. 

• Three products and plans had extremely low values ($2,250, $2,500, 

$4,000) displayed in their Annual Maximum Benefit data field. An 

Annual Maximum Benefit of $4,000 conveys that the plan pays only 

$4,000 for all in-network health care services provided to an enrollee in 

a year. If this value is inaccurate, it may be misleading to consumers. 

When other products and plans had an Annual Maximum Benefit listed, 

the data values ranged from $25,000 to $7,500,000. 

• Two small group products in our sample had extremely low values 

($1.50, $2, $3, $4, $5) displayed in the data field for Annual 

Out-of-Pocket Maximum Options. A value of $5 conveys the unlikely 

scenario that the consumer will pay a maximum amount of $5 for all 

covered in-network health services during the year. When other small 

group products in our sample had values listed in this data field, the 

values ranged from $200 to $25,000. 

32 We considered a product or plan name on a brochure as matching the name on the Plan 

Finder display if parts of the displayed name appeared anywhere in the brochure. For 

example, if part of the displayed name was “1500/30” and cost-sharing information in the 

brochure included a $1,500 deductible with 30-percent coinsurance, then we considered 

the names to match. 33 The In-Network Out-of-Pocket Limit is the maximum amount a patient pays for 

in-network covered health services in a year. Generally, this includes the deductible, 

coinsurance, and copayments. The elements included in the out-of-pocket limit vary from 

plan to plan. 
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 14

Not all of the products and plans displayed on the 

Plan Finder were available for sale or were recognized 

by insurers’ representatives 

For 26 of 192 products and plans (14 percent), either the insurers’ customer 

service representatives stated that the health insurance products or plans 

were not available for sale (14 products or plans) or the representatives 

could not identify the products on the basis of the name displayed on the 

Plan Finder (12 products). 

Insurers’ representatives stated that 14 small group products or individual 

plans were not available for sale. Of these, 13 were not available at the 

time of the calls or were not offered in the States or counties that we 

referred to during the calls. For one individual plan, the representative 

indicated that the plan was available only to consumers withdrawing from 

group coverage and therefore was not available to all individuals 

purchasing private insurance. Insurers’ representatives could not identify 

an additional 12 small group products on the basis of the product names 

that we provided from the Plan Finder display. For example, one 

representative said, “There are 10 different [products]—none of them say 

‘Consumer Choice’ on them.” Another representative indicated that the 

product name we gave her was for a “portfolio” and there were multiple 

products within the portfolio that each included a set of plan options. She 

said that she could not answer our questions unless we chose a specific 

product from the portfolio. 

We could not compare the data displayed on the Plan Finder to the 

information provided by insurers’ representatives for the 26 products and 

plans that were not available or could not be identified. Therefore, our data 

comparisons were limited to the remaining 166 products and plans that 

were available for sale and recognized by representatives. 

Eighty-one percent of product and plan data displayed 

on the Plan Finder matched information provided by 

insurers’ representatives

On average, products and plans in our sample had 81 percent of the data 

displayed on the Plan Finder match the information provided by insurers’ 

representatives. We compared information displayed on the Plan Finder to 

information provided by insurers’ representatives for 18 data values for 

individual plans and 30 data values for small group products.34 To 

34 In some cases, insurers’ customer service representatives did not know the answer to or did 

not answer one or more of the questions asked about products and plans in our review. 

Specifically, insurers’ representatives did not know the answer to 5 percent of questions and 

did not answer 1 percent of questions.
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 15

illustrate, if 14 of 18 individual plan data values matched the plan 

information provided by insurers’ representatives, we calculated a 

78-percent consistency rate for the plan.35 The rates of matching data 

ranged from a 45-percent consistency rate for one small group product to a 

100-percent consistency rate for seven products and plans. Overall, small 

group products had lower rates of consistency than did individual market 

plans. Table 2 specifies the distribution of consistency rates for the 

products and plans in our sample. 

Table 2: Consistency of HealthCare.gov Plan Finder Display With Information Provided by 

Private Insurers’ Representatives

Health Insurance Market

Number (%) of 

Products and 

Plans With a 

Consistency Rate 

of Less Than 75% 

Number (%) of 

Products and 

Plans With a 

Consistency 

Rate of 75–89%

Number (%) of 

Products and 

Plans With a 

Consistency Rate 

of 90–99% 

Number (%) of 

Products and 

Plans With a 

Consistency Rate 

of 100%

Average 

Consistency

Rate Per 

Product and 

Plan

Individual Market, 

January 2012 Update

(86 plans)

9 (10%) 48 (56%) 23 (27%) 6 (7%) 86%

Small Group Market,

November 2011 Update

(80 products)

38 (48%) 29 (36%) 12 (15%) 1 (1%) 76%

Totals 

(166 products and plans) 47 (28%) 77 (46%) 35 (21%) 7 (4%) 81%

Source: OIG analysis comparing consumer information provided on calls to insurers’ telephone customer service representatives to the data 

displayed on the HealthCare.gov Plan Finder Web site, 2012.

For 47 of 166 products and plans (28 percent), less than three-quarters of 

their displayed data matched the information provided by insurers’ 

customer service representatives. Small group market products accounted 

for 38 of the 47. It is important to note that these small group market data 

reflect CMS’s first collection of detailed pricing and benefit information 

from small group market insurers. In contrast, individual market insurers 

have been reporting detailed plan data to the Plan Finder since September 

2010. 

For certain fields on the Plan Finder display, data values were 

less likely to match information provided by insurers’ 

representatives

Across small group products and individual plans, certain benefit data 

fields displayed on the Plan Finder were less consistent with information

provided by insurers’ representatives. For example, only 39 percent of 

individual plans had data in the Plan Finder’s data field for Home Health

Care that matched the home health care benefit information provided by 

35 We did not include missing data values in the denominator when calculating the consistency 

rate. For example, if the representative did not know the answer to 1 of the 18 questions 

regarding an individual plan and 14 of the remaining 17 data values matched, we calculated an 

82 percent (14/17) consistency rate.
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 16

insurers’ representatives. This low consistency rate may be attributed to 

the systematic inconsistency described earlier, i.e., insurers reported 

information to CMS about limitations and exceptions for home health care 

coverage that was not reflected in the health insurance plan data displayed 

on the Plan Finder. 

For six of the seven benefit data fields that displayed small group products’ 

range of cost-sharing options, less than 75 percent of products had Plan 

Finder data values that matched the information provided by insurers’ 

representatives.36 Insurers were instructed to summarize information about 

their products to enter it into the Plan Finder templates. Lower consistency 

rates for the “range of cost-sharing options” data fields on the Plan Finder 

display may reflect challenges that insurers faced when summarizing 

pricing and benefit information as a set of product options. Alternatively, 

the lower consistency rates for these data fields may reflect challenges that 

insurers’ representatives faced when recalling and presenting the minimum 

and maximum values of a range of product options. 

36 These six data fields were: Available In-Network Deductibles, Available 

Out-of-Network Deductibles, Annual Out-of-Pocket Maximum Options, Range of 

In-Network Copay Options, Range of In-Network Coinsurance Options, and Range of 

Out-of-Network Coinsurance Options. 
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 17

CONCLUSION AND RECOMMENDATIONS

Private insurers offering health insurance in the individual and small group 

markets must submit data to populate the HealthCare.gov Plan Finder. The 

data collection conducted by CMS/CCIIO to populate the Plan Finder 

represents the first national attempt to identify these insurers and the 

products and plans they offer. For American consumers to obtain the 

maximum benefit from the Plan Finder, the private health insurance data 

displayed there must be complete and accurate.

In November 2011 and January 2012, CMS did not ensure that private 

health insurers reported all required data to HHS. However, CMS 

implemented numerous measures to ensure the accuracy of reported data 

and suppressed data from the Plan Finder when quality checks identified 

problems. Despite these efforts, our review of the data displayed on the Plan 

Finder for 192 selected products and plans found that some aberrant and 

inconsistent data values appeared on the Web site. These inconsistencies 

may be confusing or misleading to consumers using the Plan Finder to seek 

information about the private health insurance products and plans available 

to them. 

Our comparison of data displayed on the Plan Finder to data provided by 

insurers’ representatives was designed to identify inconsistencies between 

two sources of health insurance information. This comparison revealed that 

some health insurance products and plans displayed on the Plan Finder were 

not available for sale or were not recognized by insurers’ representatives. 

When products and plans were available and were recognized, an average of 

81 percent of the data displayed on the Plan Finder matched the information 

provided by insurers’ representatives. For a smaller number of products and 

plans in our purposive sample, less than three-quarters of their Plan Finder 

data matched the information provided by insurers’ representatives. Small 

group market products accounted for most of these inconsistencies. The 

data reviewed from the small group market represent CMS’s inaugural

collection of detailed pricing and benefit information for this insurance 

market.

Our findings indicate that additional efforts are needed to oversee private 

health insurers’ compliance with reporting requirements for the Plan Finder 

and to ensure that the data displayed on the Plan Finder are accurate. 
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 18

Therefore, we recommend that CMS: 

Establish and Implement Procedures To Identify and Pursue 

Private Insurers That Do Not Submit Required Data to the Plan 

Finder

CMS should establish and implement a standard process to identify private 

health insurers that are required to report basic health insurance company 

and product data to HHS. After doing so, CMS should systematically 

contact insurers that have not submitted basic health insurance information 

for display on the Plan Finder. CMS has taken initial steps toward this end 

by seeking a contractor to evaluate Plan Finder data with a specific goal of

determining whether the insurers that have reported data to the Plan Finder 

reflect the entirety of insurers subject to the requirements. In addition, CMS

should establish and implement procedures to conduct targeted followup 

with private health insurers that did not submit pricing and benefit 

information during each data collection period. If these steps do not 

improve compliance, CMS should consider seeking additional authority to 

impose penalties on insurers that do not submit required data. 

Ensure That Each Private Insurer’s CEO or CFO Certifies to the 

Completeness of Data Submitted for the Plan Finder 

Since July 2010, insurers have been required to certify to the accuracy of the 

data submitted to the Plan Finder. CMS should implement the requirement 

in 45 CFR § 159.120(g) that insurers’ CEOs or CFOs certify to the 

completeness of the submitted data as a condition of displaying the data on 

the Plan Finder. As part of this, CMS may want to consider revising the 

current specification of completeness—that insurers must submit 

information on—at a minimum—all plans that are open for enrollment and 

represent 1 percent or more of the insurer’s total enrollment within a ZIP

Code. One option is to devise a specification of completeness that aligns 

with how private insurers track enrollment. 

Design and Implement Additional Strategies To Ensure Plan 

Finder Data Accuracy 

CMS incorporates insurer training and data quality checks into the Plan 

Finder data submission process to prevent and correct data errors. However, 

our review indicates that CMS should perform additional data quality 

checks to prevent aberrant or inconsistent values from being displayed on 

the Plan Finder that may be confusing or misleading to consumers. In 

designing additional strategies, CMS should begin by addressing the 

inconsistencies described in this report. For example, CMS should check 

that data submitted by insurers on limitations or exceptions to plan benefits 

are reflected on the Plan Finder. CMS may consider incorporating specific 

instructions in its data entry guidance to private insurers about submitting 

product and plan names for the Plan Finder that appear on brochures and are 
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 19

recognizable to insurers’ customer service representatives. CMS could also 

instruct insurers to submit data on the range of cost-sharing options for 

small group products that are the same as those outlined in materials used 

by their customer service representatives to sell insurance to small 

employers. 

Validate That Products and Plans Submitted to the Plan Finder 

Are Available for Sale 

Our review indicates that not all private health insurance products and plans 

that appeared on the Plan Finder were available for sale. CMS is awarding 

a contract for a Plan Finder data evaluation. One of the goals of this 

contract is to use data from outside sources to produce a report on insurers’ 

accuracy of reporting. At a minimum, CMS should focus the contractor’s 

efforts on using data from outside sources to ensure that products and plans 

that are submitted to the Plan Finder are available for sale.
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 20

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

CMS generally concurred with all of OIG’s recommendations and has 

begun to implement changes to address them. CMS stated that it believes 

that regulations and standards proposed for 2014 will help simplify the 

reporting process for health insurers and increase the reliability of Plan 

Finder information. 

CMS concurred with our first recommendation, that it establish and 

implement procedures to identify and pursue private insurers that do not 

submit required data to the Plan Finder. CMS stated that it had identified 

three lists of Health Insurance Issuers that may need to report additional 

data under the HealthCare.gov regulation and that it would begin sending 

targeted memos and conducting followup with these issuers in January 

2013. In addition, CMS noted that it is compiling lists of issuers required 

to report to the Plan Finder from other sources and will begin to contact 

these issuers in the first quarter of 2013. 

CMS concurred with our second recommendation, that it ensure that each 

private insurer’s CEO or CFO certifies to the completeness of data 

submitted to the Plan Finder. CMS stated that it is working to integrate 

Corporate Officer attestations associated with various ACA reporting 

requirements. CMS noted that it expects to implement the fuller attestation 

requirement in the second quarter of 2013. 

CMS concurred with our third recommendation, that it design and 

implement additional strategies to ensure Plan Finder data accuracy. CMS 

stated that it hired a contractor in 2012 to review the quality of Plan Finder

data and provide quarterly reports that will enable CMS to contact issuers 

regarding aberrant data. In addition, CMS noted that it conducts weekly 

calls to address questions from issuers on reporting data accurately. CMS 

stated that it believes that changes to its data collection to reflect the 

Summary of Benefits and Coverage (a standard document that insurers are 

required to provide to consumers) will improve communication and 

presentation of information on the Plan Finder. 

CMS concurred with our fourth recommendation, with caveats, that it

validate that products and plans submitted to the Plan Finder are available 

for sale. CMS stated that its data quality contractor will evaluate whether 

the information reported to the Plan Finder is accurate. In addition, CMS 

noted that it will encourage the display of “marketing names” for health 

insurance plans and products to decrease confusion as consumers 

communicate with sales representatives. 

The full text of CMS's comments is provided in Appendix B.
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 21

APPENDIX A 

Plan Finder Data Fields Included in Office of Inspector General

Review of Information Provided by Insurers’ Representatives

We collected information from insurers’ customer service representatives 

for 18 of the 55 data fields for individual plans and 23 of the 63 data fields 

for small group products displayed on the Plan Finder. We included seven 

small group data fields that each displayed a range of cost-sharing options. 

For these data fields, we collected information on the minimum and 

maximum of the range and considered the minimum and maximum as two 

distinct data values. Therefore, for the 23 selected Plan Finder data fields 

for small group products, we collected 30 data values from representatives. 

Table A-1 outlines the Plan Finder data fields included in our review. 

Table A-1: Plan Finder Data Fields Included in Office of Inspector General 

(OIG) Review of Information Provided by Insurers’ Representatives 

Name of Data Field Reviewed, 

Small Group Market, 

November 2011 Update

Name of Data Field Reviewed, 

Individual Market, 

January 2012 Update

Product Name Plan Name

Available In-Network Deductibles1 Deductible (Individual)

Available Out-of-Network Deductibles1 In-Network Out-of-Pocket Limit (Individual)

Annual Out-of-Pocket Maximum Options1 In-Network Out-of-Pocket Limit Elements

Health Savings Account Eligibility Health Savings Account Eligibility

Annual In-Network Maximum Benefit Annual Maximum Benefit (Individual)

Doctor Choice Doctor Choice

Enrollment of Same-Sex Partners Primary Care Physician Office Visit

Enrollment of Domestic Partners Specialty Physician Office Visit

Range of In-Network Copay Options1 Inpatient Hospital Services

Range of Out-of-Network Copay Options1 Emergency Room Services

Range of In-Network Coinsurance Options1 Generic Drugs

Range of Out-of-Network Coinsurance Options1 Mental Health Coverage (Outpatient)

Specialist Visit Prenatal and Postnatal Care

Emergency Room Home Health Care

Generic Drugs Hearing Aid

Mental [Health,] Inpatient Long Term Care

Prenatal and Postnatal Care Chiropractic

Home Health Care

Hearing Aid

Long Term Care

Acupuncture

Bariatric Surgery

Source: OIG telephone calls to insurers’ customer service representatives based on data displayed on the 

HealthCare.gov Plan Finder Web site, 2012.

1 For this small group product data field, we collected data on the minimum and maximum of the range and 

considered the minimum and maximum as two distinct data values in our analysis. 
APPENDIX 8 

Agency Comments 

("'Jf-	 Centers tor Medicare & Medicaid Services DEPARTMENT OF HEALTH & HUMAN SERVICES 

Administrator 

Washington, DC 20201 

DATE: JAN 1 ~ 2013 

TO: 	 Daniel R. Levinson 


Inspector General 


FROM: 	 Marilyn Tavenner 


Acting Administrator 


SUBJECT: 	 Otlice of Inspector General (OIG) Draft Report: "Oversight of Pri vate Health 

Insurance Submissions to the Healthcare.gov Plan Finder"--(OEI-03-11-00560) 

The Centers for Medicare and Medicaid Services (CMS) would like to thank OIG for the 

opportunity to review and comment on the OIG Draft Report referenced above. 

The evaluation report issued by OIG identifies several areas where CMS can improve the 

accuracy and completeness ofour data collection to support HeahhCare.gov . CMS generally 

concurs with each of the OIG recommendations and has begun implementation of changes that 

we believe will meet the recommendations. CMS believes that the overall assessment overstates 

the problems with the website by underappreciating the degree to which the current insurance 

market operdtes in non-standard ways. Current regulation allows issuers to assign a single name 

to a complex set ofoptions which make it difficult to confirm specifics on the website. CMS 

does reach out to issuers when errors are reported to us, and these are often the result of 

misinformation or misidentification by customer service representatives rather than errors in 

reporting. We believe that regulations and standards currently under review and proposed for 

2014 will help simplify this process, and increase the reliability of information . 

OIG Recommendation 

The 010 recommends CMS establish and implement procedures to identify and pursue private 

insurers who do not submit required data for the Plan Finder. 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 22 
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 23
 

Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 24
Oversight of Private Health Insurance Submissions to the HealthCare.gov Plan Finder (OEI-03-11-00560) 25

ACKNOWLEDGMENTS

This report was prepared under the direction of Robert A. Vito, Regional 

Inspector General for Evaluation and Inspections in the Philadelphia 

regional office, and Linda M. Ragone, Deputy Regional Inspector General. 

Amy Sernyak served as the team leader for this study. Other Office of 

Evaluation and Inspections staff from the Philadelphia regional office who 

conducted this study include Joanna Bisgaier and Conswelia McCourt. 

Central office staff who provided support include Heather Barton, 

Althea Hosein, Meghan Kearns, and Christine Moritz. 
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.