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U.S. Department of Health and Human Services · Office of Inspector General

HHS-OIG
Strategic Plan

Oversight of Managed Care for Medicare and Medicaid

The federal Inspector General's plan for policing managed care plans. Rebuilt here for reading, with the hard parts made plain and every quotation pinned to its page.

This is the document the federal government uses to decide where managed care can go wrong. It names network adequacy as a contract condition, calls out barriers to care that raise plan revenue as a known risk, and treats bad provider data as something that blinds the regulator. Nothing on this page changes the document's words. Where NoSuchProvider adds a reading, it is set in a different voice and labeled.

  • 10 pages
  • 4 life cycle stages
  • 3 goals, 6 objectives
  • 10 figures
  • Public domain

Revised March 2025

Start the breakdown Original PDF

Page 3 · By the Numbers

The document in ten figures

The plan opens with a statistics box. It is rebuilt here exactly as the document presents it, followed by the six other figures that appear later in the text. Every figure is national. None of them describes California or any dental plan.

By the Numbers

50% of Medicare enrollees received care through Medicare Advantage in 2022.

81%

of current Medicaid enrollees receive at least one component of care through managed care.

$403B

in Government spending on Medicare Advantage in 2022 (50% of all Medicare funds).

$254B

Federal match for Medicaid managed care in 2021.

Source: HHS-OIG Strategic Plan, p. 3, "By the Numbers"

$650B+
Federal spending on Medicare and Medicaid managed care in 2022
Goal 2 · p. 7
13%
Medicare Advantage prior authorization denials for services that met Medicare coverage rules
Goal 1 · p. 6
1 in 8
Prior authorization requests denied by certain Medicaid managed care organizations
Goal 1 · p. 6
$377M
Potential overpayments identified in risk-adjustment audits, as of August 2023
Goal 2 · p. 7
$1B/yr
Approximate questionable Medicaid payments for people enrolled in two States or two plans at once
Goal 3 · p. 8
$170M+
Medicaid payments made after the death of enrollees
Goal 3 · p. 8

NoSuchProvider · orientation

What this document is, and what it is not

Read this first. It protects the document, and it protects you from over-reading it.

What it is

  • A strategic plan published by the Office of Inspector General of the U.S. Department of Health and Human Services, the federal watchdog over Medicare and Medicaid.
  • A statement of how that watchdog sees risk in managed care, organized around a four-stage life cycle: contracting, enrollment, payment, and services to people.
  • The federal frame in which network adequacy, provider data accuracy, prior authorization, and payment integrity all sit together.
  • A work of the U.S. Government, not subject to domestic copyright. It is reproduced here with page citations and mirrored in full.

What it is not

  • Not a regulation. It creates no enforceable rights or obligations for anyone.
  • Not about any particular plan, county, or specialty. It never mentions dental managed care.
  • Not a description of California, Sacramento County, or any dental plan. Its figures are national.
  • Not evidence about any plan's conduct. It describes risks that exist across the industry.

Page 2

Mission, vision, values

OurMission

To provide objective oversight to promote the economy, efficiency, effectiveness, and integrity of Department of Health and Human Services (HHS) programs, as well as the health and welfare of the people they serve.

OurVision

To drive positive change in HHS programs and in the lives of the people served by these programs.

OurValues

To be impactful, innovative, and people-focused.

Source: HHS-OIG Strategic Plan, p. 2, quoted in full

Page 3

Introduction

Why the plan exists, and the tension at the heart of it: the Inspector General has to police managed care plans and partner with them at the same time.

What the document says

p. 3

Due to the growth of managed care in terms of enrollees and expenditures and the significant differences between fee-for-service and managed care programs, OIG has developed a coordinated plan for managed care oversight.

Effective implementation of this strategy will require OIG to conduct rigorous oversight of managed care plans while also closely coordinating with the same plans to fight fraud, waste, and abuse. OIG must hold Medicare Advantage organizations (MAOs) and managed care organizations (MCOs) accountable. Focused oversight and enforcement targeting plan conduct can hold MAOs and MCOs accountable that game Federal health programs and encourage improved compliance across the industry.

At the same time, OIG must work closely with plans to address health fraud schemes that are increasingly shifting to managed care. OIG recognizes that partnering with plans is key to combating fraud that harms managed care plans, their enrollees, and the Medicare and Medicaid programs.

Managed care oversight and enforcement is among the most complex work that OIG performs. This strategic plan will help OIG navigate that complexity, address key risk areas, and improve partnerships.

Short version

Managed care now covers most people in Medicare and Medicaid, and it works very differently from fee-for-service. So the Inspector General wrote a dedicated plan for watching it.

The plan sets three goals: access to care, financial oversight, and accurate data.

It also admits a tension. OIG has to hold plans accountable, including plans that game federal programs, while partnering with those same plans to catch fraud, because plans are the first to see it. The life cycle tool below is how OIG decides which posture fits where.

OIG calls this among the most complex work it does.

Pages 4 to 5 · The central tool

The Managed Care Life Cycle

OIG's own framework. Four stages wrap around a core labeled "OIG Oversight," naming the three parties it watches: plans, CMS and the States, and providers and vendors. Each stage raises different risks. Select a stage to read what the document says about it.

What the document says

p. 4

For purposes of oversight, the life cycle of a managed care plan is fourfold: plan establishment and contracting, enrollment, payment, and provision of services. Each stage of this life cycle raises different risks and vulnerabilities. Effective oversight and enforcement will address each stage of this life cycle and the associated risks.

Plan Establishment and Contracting

Scope. Activities that occur when a plan is first established or when its contract is renewed.

What the document says

p. 4

CMS enters into contracts with and makes monthly payments to MAOs to provide coverage to people enrolled in the program. In Medicaid, States operate and fund the program in partnership with the Federal Government. States contract with MCOs to make services available to people enrolled in Medicaid.

Both Medicare and Medicaid have operational requirements for plans, such as financial solvency and providing an adequate network. If plans provide inaccurate information related to these requirements, or if plans do not adhere to the contract, there is risk that the plan should not be operating or is not providing adequate care for enrollees.

Focus areas named in the document

  • Review of contracts with the State or CMS
  • Plan benefit design
  • Establishment of plan service area
  • Accuracy and integrity of plan bids

Short version

This is the moment a plan gets its contract, or renews it. In Medicare, CMS contracts with plans and pays them monthly. In Medicaid, States run the program with federal money and contract with plans to deliver it.

Both programs make plans meet operating conditions. The document names two: staying financially solvent and providing an adequate network.

Then the hard line. If a plan gives inaccurate information about those conditions, or does not follow its contract, OIG says the plan may not belong in the program at all, or may not be giving enrollees adequate care.

Enrollment

Scope. Processes related to enrolling people in plans.

What the document says

p. 4

To attract enrollees, some MAOs engage in aggressive marketing programs through direct contact with enrollees and media campaigns. In some cases, tactics are used that violate marketing guidelines, such as providing incorrect information, which may put people at risk.

Enrollment is also the point at which eligibility and other information (e.g., demographics) is transmitted to the Government; incorrect information will result in incorrect payment.

Focus areas named in the document

  • Marketing
  • Agent or broker activities
  • Eligibility determinations
  • Accuracy and use of enrollment data

Short version

Getting people signed up. Some Medicare Advantage plans market aggressively, through direct contact and media campaigns, and some of those tactics break the marketing rules, including giving people wrong information.

Enrollment is also where a person's eligibility and demographic data enter the system. Wrong data at the door means wrong payments later.

Payment

Scope. Payments made by CMS and the States to plans, as well as plan payments to providers.

What the document says

p. 5

The Federal Government's financial risk is primarily associated with capitation payments to plans, including those based on risk adjustment. Risk adjustment provides higher payments to plans for individuals who are sicker, with the goal of accurately paying plans to provide services to their enrollees and prevent cherry-picking. However, there is a risk that plans will misreport the health status of their enrollees to make them appear sicker to receive a higher payment.

Plan payments to providers could also be improper and at risk for fraud, waste, and abuse. Although costs associated with improper payments from plans to providers may not pose direct financial risk to the Government, these costs could be passed along to Medicare and Medicaid in future years if not identified and corrected.

OIG will also continue to investigate the overlap in providers engaging in fraud in fee-for-service Medicare and Medicaid that are also providing services in managed care networks.

Focus areas named in the document

  • Risk adjustment
  • Payment accuracy
  • Medical loss ratio
  • Value-based care and other alternative payment mechanisms
  • Providers committing fraud in fee-for-service who also serve in managed care networks

Short version

Money flows two ways: from CMS and the States to plans, and from plans to providers.

The big federal risk is capitation, the fixed payment a plan receives per enrolled person, especially when it is adjusted for how sick people are. Risk adjustment pays plans more for sicker people so plans are not tempted to avoid them. The flip side is that a plan can make its enrollees look sicker on paper and collect more.

Plan-to-provider payments can also be improper. Even when that does not cost the government directly today, OIG says the cost can be passed along to Medicare and Medicaid in later years.

OIG also keeps watching providers who commit fraud in fee-for-service and also work inside managed care networks.

Services to People

Scope. Whether enrollees have adequate access to high-quality services.

What the document says

p. 5

Managed care plans have different incentives based on the capitation payment. Plans may impose barriers that prevent enrollees from accessing services to reduce plan medical costs and increase revenue. Although program safeguards, such as medical loss ratios, are intended to curb these behaviors, the risks and potential impact on enrollees are high, warranting additional oversight.

Additionally, managed care arrangements also have flexibility to provide nontraditional benefits, such as gym memberships. These benefits are often funded through a different financial mechanism than the base payment and actual utilization may not be transparent.

Focus areas named in the document

  • Network adequacy
  • Ineligible or untrustworthy providers
  • Coverage determinations
  • Whether enrollees are receiving care that meets clinical guidelines
  • Fraud schemes that cross multiple plans and/or Federal health care programs

Short version

Do enrollees actually get care? Because a plan is paid a fixed amount per person, it keeps more of that money when it delivers less care. OIG states the risk directly: plans may put up barriers to services in order to cut medical costs and increase revenue.

Safeguards such as the medical loss ratio exist to curb that. OIG says the risk to enrollees is still high enough to need more oversight.

Extras like gym memberships are paid for differently from the base payment, and how much they are really used may not be visible.

Plans may impose barriers that prevent enrollees from accessing services to reduce plan medical costs and increase revenue.

HHS-OIG Strategic Plan, Oversight of Managed Care for Medicare and Medicaid, p. 5 (rev. March 2025)

NoSuchProvider reading

This is the federal Inspector General naming the economic mechanism, not as an allegation against any plan, but as a structural risk built into capitation. It moves access failure out of the category of administrative sloppiness and into the category of a known, named financial incentive.

Pages 6 to 8

Goals and Objectives

What the document says

p. 6

Through its oversight and enforcement, OIG seeks to ensure that managed care provides value as measured by the financial impact to the Federal Government and the quality of care for people in the programs. To address the risks associated with each stage of the managed care plan life cycle, OIG has three strategic goals: (1) promote access to care for people enrolled in managed care, (2) provide comprehensive financial oversight, and (3) promote data accuracy and encourage data-driven decisions.

Promote access to care for people enrolled in managed care

OIG says it is committed to protecting Medicare and Medicaid enrollees, who "should have access to safe, effective, and equitable care" and "should be able to access effective services in a timely and efficient manner." Health care quality touches the services-to-people stage and also payment, enrollment, plan establishment, and contracting. p. 6

Objective A

Ensure that managed care plans provide enrollees with access to health care services, including mental health services.

Access encompasses not only physical proximity but also timeliness of care. Harmful delays in care can result from wait times to get an appointment and lengthy prior authorization processes.

"Access to services is the foundational principle for care; without the ability to access providers, enrollees will not receive the care they need." p. 6

Objective B

Ensure that care provided to people enrolled in managed care is safe and effective.

"At a minimum, the care they receive should not harm them. It should also meet established quality standards." Quality bonus payments create "a nexus between quality of care and payment," and care "should also promote the ability of enrollees to reach the highest level of health." p. 6

Examples of OIG's work in this area

OIG has been working on access to behavioral health and is conducting a cross-program behavioral health study that will examine the ratio of providers to people enrolled, ability of providers to accept new patients and schedule appointments, and network adequacy.

OIG examined prior authorization requests in Medicare Advantage and found that in 13 percent of cases, plans denied services that met Medicare coverage rules. OIG found that certain Medicaid MCOs denied one out of every eight requests for the prior authorization of services, and that States had limited oversight of MCO prior authorization denials.

Quoted in full · p. 6

Short version

Enrollees should get safe, effective, equitable care, on time. Access is the foundation: if you cannot reach a provider, nothing else matters. And access means more than a provider being nearby. It means getting an appointment without harmful delay, including delay caused by prior authorization.

The examples: OIG found Medicare Advantage plans denied 13 percent of prior authorization requests for services that met Medicare's own coverage rules, and certain Medicaid plans denied one request in eight while States barely watched.

Provide comprehensive financial oversight

"In 2022, the Federal Government spent more than $650 billion on Medicare and Medicaid managed care programs." The payment mechanisms are "complex and multifaceted, requiring robust surveillance," and oversight is needed "to safeguard taxpayers dollars and to promote a culture of compliance in the managed care industry." p. 7

Objective A

Ensure that payments to Medicare Advantage and Medicaid plans are accurate.

OIG focuses on "risk-adjusted capitated payments as well as the documentation and diagnosis submission patterns behind them," and has "highlighted concerns that Medicare Advantage plans' use of certain tools to increase the risk-adjustment payments they receive presents payment integrity risks."

As managed care has grown in enrollment and complexity, plan compliance functions generally have not kept pace. p. 7

Objective B

Identify and prevent fraud in managed care plans.

"The risk of provider-level fraud against plans has increased as managed care enrollment has grown over the past several years." OIG is expanding engagement with plans and their special investigation units, in coordination with Federal and State law enforcement, "because plans are on the front lines to spot it." p. 7

Examples of current and completed work

OIG has conducted audits of health plans to validate risk-adjusted payments made by CMS. As of August 2023, OIG has identified approximately $377 million in potential overpayments. OIG has also examined the use of chart review and health risk assessments to increase risk scores.

In Medicaid, OIG has undertaken a series of evaluations focused on oversight and integrity of managed care plans' reported medical loss ratios, a critical tool for ensuring that managed care plans are directing appropriate levels of funds toward patient care.

Quoted in full · p. 7

Short version

More than $650 billion a year. Payments are complicated, so they need constant watching. OIG concentrates on risk-adjusted capitation and the diagnosis paperwork behind it, and has flagged tools plans use to raise their risk scores. It says plan compliance programs have not kept up with the growth.

OIG also knows fraud follows the money. It is working with plans' special investigation units to catch provider fraud against plans and refer more of it to law enforcement.

The examples: about $377 million in potential overpayments found in risk-adjustment audits as of August 2023, and a series of Medicaid evaluations on medical loss ratios, which OIG calls a critical tool for making sure plan money reaches patient care.

Promote data accuracy and encourage data-driven decisions

"Data accuracy safeguards program dollars and quality of care. Data should be accurate, timely, and complete. Without accurate data, payments will not be correct and resources may not be appropriately directed." p. 8

Objective A

Ensure that data are accurate.

"When information is not accurate, correct payment is at risk and oversight and monitoring become difficult. It is critical that States, CMS, and plans have accurate data to effectively administer the program and ensure compliance. Data are also a powerful tool to examine health care quality issues." p. 8

Objective B

Encourage timely collection of complete data.

"Incomplete data can result in inaccurate payment and make program analysis difficult. Areas of risk evolve and change and can be best addressed by data that are timely and complete. Furthermore, analysis of robust, near real-time data allows for identification of emerging risks." p. 8

Examples of current and completed work

OIG's audits of Medicaid enrollment data found that States made approximately $1 billion per year in questionable payments for concurrent enrollment in two different States or concurrent enrollment in two different MCOs, and more than $170 million in payments after death of enrollees.

OIG reported that the lack of provider identifiers on Medicare Advantage encounter data prevented their ability to provide robust oversight.

OIG has consistently identified deficiencies in the Transformed Medicaid Statistical Information System (T-MSIS) data, including in its managed care data. OIG will continue to examine data issues, in both Medicare and Medicaid managed care, especially regarding collecting more robust data that will give critical insights into the programs.

Quoted in full · p. 8

Short version

Payments and oversight both run on data. When the data is wrong or missing, payments go wrong and regulators cannot see what is happening.

The examples: roughly $1 billion a year in questionable Medicaid payments for people enrolled in two States or two plans at the same time, and more than $170 million paid after enrollees had died. Missing provider identifiers in Medicare Advantage encounter data prevented robust oversight. The national Medicaid data system, T-MSIS, has had persistent problems, including in its managed care data.

NoSuchProvider · selection

The ten sentences that matter most

Every sentence below is the government's, quoted exactly and pinned to its page. The selection and the short note under each one are ours. Use the button on the cover to light these up where they appear in the document text above.

Managed care oversight and enforcement is among the most complex work that OIG performs.

p. 3 Read in context

Why it lands

The federal watchdog says this is the hardest thing it does. A single member trying to reach a specialist is up against the same complexity, without the staff.

If plans provide inaccurate information related to these requirements, or if plans do not adhere to the contract, there is risk that the plan should not be operating or is not providing adequate care for enrollees.

p. 4 Read in context

Why it lands

"Should not be operating" is the strongest phrase in the document, and it is attached to inaccurate information about contract conditions, one of which is an adequate network.

However, there is a risk that plans will misreport the health status of their enrollees to make them appear sicker to receive a higher payment.

p. 5 Read in context

Why it lands

The government pays plans more for sicker patients. The document says plainly that the paperwork can be tilted to collect more.

Plans may impose barriers that prevent enrollees from accessing services to reduce plan medical costs and increase revenue.

p. 5 Read in context

Why it lands

The load-bearing sentence. Less care delivered, more revenue kept. Stated as a risk of the payment model, by the regulator, in a public plan.

Although program safeguards, such as medical loss ratios, are intended to curb these behaviors, the risks and potential impact on enrollees are high, warranting additional oversight.

p. 5 Read in context

Why it lands

The existing safeguard is acknowledged and then described as insufficient. The word "high" is the government's.

Access encompasses not only physical proximity but also timeliness of care. Harmful delays in care can result from wait times to get an appointment and lengthy prior authorization processes.

p. 6 Read in context

Why it lands

A dot on a map is not access. A provider you cannot get an appointment with does not count, in the federal reading, as a provider you can reach.

OIG examined prior authorization requests in Medicare Advantage and found that in 13 percent of cases, plans denied services that met Medicare coverage rules. OIG found that certain Medicaid MCOs denied one out of every eight requests for the prior authorization of services, and that States had limited oversight of MCO prior authorization denials.

p. 6 Read in context

Why it lands

Denials of care that met the rules, at scale, with the States barely watching. The full passage is quoted in the Goal 1 examples box.

As managed care has grown in enrollment and complexity, plan compliance functions generally have not kept pace.

p. 7 Read in context

Why it lands

The plans' own internal checks are behind the growth of the programs they run, in the regulator's words.

States made approximately $1 billion per year in questionable payments for concurrent enrollment in two different States or concurrent enrollment in two different MCOs, and more than $170 million in payments after death of enrollees.

p. 8 Read in context

Why it lands

Bad enrollment data is not abstract. It is a billion dollars a year, and payments for people who had died.

The lack of provider identifiers on Medicare Advantage encounter data prevented their ability to provide robust oversight.

p. 8 Read in context

Why it lands

Missing provider data did not merely inconvenience the regulator. It stopped the regulator. Bad provider data disables oversight.

NoSuchProvider · analysis

Why this document matters to this investigation

Everything in this section is NoSuchProvider commentary. It is our reading of a public document, offered so a member, a reporter, or a regulator can see the connections we see and check them against the source.

1Stage 1 · Contracting

The contract door

An adequate network is an operational requirement of the contract, listed with financial solvency. Inaccurate information about that requirement creates the risk that the plan "should not be operating."

Both Medicare and Medicaid have operational requirements for plans, such as financial solvency and providing an adequate network. If plans provide inaccurate information related to these requirements, or if plans do not adhere to the contract, there is risk that the plan should not be operating or is not providing adequate care for enrollees.

p. 4

4Stage 4 · Services to People

The services door

Network adequacy is the first-named oversight focus area for the stage where members actually try to get care.

Focus areas may include network adequacy, ineligible or untrustworthy providers, coverage determinations, whether enrollees are receiving care that meets clinical guidelines, and fraud schemes that cross multiple plans and/or Federal health care programs.

p. 5
OIG's measure (p. 6)This site's methodWhere to see it
"the ratio of providers to people enrolled"Count the directory listings, then count the distinct providers behind them. Seventeen listings can be ten offices.The Western Dental listing breakdown
"ability of providers to accept new patients and schedule appointments"Call the office. Ask for the listed specialist by name. Write down the answer and the date.The Ghost Hunt method
"network adequacy"Check each listed specialist against the NPI registry, the State license, and board certification before counting them as a specialist at all.The credential verification chain

NoSuchProvider · cross-reference

Where each part of the document connects to this site

The left column is the document. The middle column is our reading. The right column links to the place on this site where the evidence or the explainer lives. Rows without a live page say so instead of linking.

Document elementSite relevanceOn this site
Stage 1: an adequate network as a contract requirement p. 4Directory misrepresentation as a contracting-integrity riskThe federal rule behind the dental network test
Stage 1: "the plan should not be operating" p. 4Escalation theory under State licensingThe Knox-Keene Act and the DMHC
Stage 3: capitation and cherry-picking p. 5The economic engine of a network with no real specialistsGhost referral loops
Stage 3: fraud overlap between fee-for-service and managed care p. 5Provider-level exhibits, if any ariseNo exhibit on this site yet
Stage 4: barriers to reduce cost and increase revenue p. 5The load-bearing sentenceThe sentence, on this page
Stage 4: network adequacy as a focus area p. 5The core thesis of the siteHow California measures a dental network
Stage 4: ineligible or untrustworthy providers p. 5A federal category, listed for referenceDeliberately not linked to any exhibit
Goal 1, Objective A: proximity and timeliness p. 6Appointment availability as evidenceSecret-shopper surveys in the State's method
Goal 1: the behavioral health study design p. 6Methodology parityThe credential verification chain
Goal 2: medical loss ratio as an insufficient safeguard pp. 5, 7The financial dimension of an adequacy failureThe California layer, W&I Code 14197
Goal 3: data accuracy and the regulator's sight p. 8Cross-checking the State directory against the plan's ownThe State directory versus the plan directory
OCIG: False Claims Act, exclusions, corporate integrity agreements p. 9The federal enforcement trackEnforcement actions in the press gallery
OI: investigators in all 50 States p. 9Where a complaint can landWhere to report

Page 9

Who does what inside the Office of Inspector General

What the document says

p. 9

OIG's mission, as mandated by P.L. No. 95-452, as amended, is to protect the integrity of HHS programs, as well as the health and welfare of the people 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:

OAS

Office of Audit Services

Audits HHS programs, grantees, and contractors, with its own auditors or by overseeing others' audit work. Audits "are intended to provide independent assessments of HHS programs and operations" and "help reduce waste, abuse, and mismanagement."

OEI

Office of Evaluation and Inspections

Conducts national evaluations "to provide HHS, Congress, and the public with timely, useful, and reliable information on significant issues," and presents "practical recommendations for improving program operations."

OI

Office of Investigations

Conducts "criminal, civil, and administrative investigations of fraud and misconduct," with "investigators working in all 50 States and the District of Columbia," in coordination with the Department of Justice and other law enforcement. Its work "often lead[s] to criminal convictions, administrative sanctions, and/or civil monetary penalties."

OCIG

Office of Counsel to the Inspector General

OIG's lawyers. 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," and "negotiates and monitors corporate integrity agreements." Issues advisory opinions, compliance program guidance, and fraud alerts.

Source: HHS-OIG Strategic Plan, p. 9. Condensed; quoted phrases are verbatim.

OIG Public Hotline (for reporting fraud)
oig.hhs.gov/fraud/report-fraud
Phone
(800) 447-8477
TTY (for hearing impaired)
(800) 377-4950

Reporting channel as published in the document, p. 9

Page 10 · Provenance

Read the original

We reproduce and analyze a public document. Here is the document, mirrored so the exhibit survives link rot, with a checksum so you can confirm the mirror is untouched.

Title
Oversight of Managed Care for Medicare and Medicaid
Series
HHS-OIG Strategic Plan
Issuing body
U.S. Department of Health and Human Services, Office of Inspector General
Edition
Revised March 2025
Length
10 pages
Address of record
330 Independence Avenue, SW, Washington, DC 20201
Publisher
oig.hhs.gov
Statutory basis for OIG
P.L. No. 95-452, as amended
Copyright
Work of the U.S. Government; not subject to domestic copyright (17 U.S.C. § 105)
SHA-256 of the mirrored PDF (identical to the file at oig.hhs.gov, checked September 9, 2026)
243bf202f88eadecd6212d9f3829118e08329b48311cc746cf8488a29137cf94

Open the mirrored PDF

Dating note

The edition on file is marked "Revised March 2025." Its most recent internal data point is "As of August 2023," which suggests an earlier original issuance. This page does not state an original publication date, because we have not independently confirmed one.

The document's own hyperlinks to underlying OIG reports are not reproduced here. Each would need to be verified against oig.hhs.gov before being cited.