Deeper Than the Headlines: State Inspectors General

We talk a lot about the OIG. So much so that we use the term “OIG” to generally mean the OIG for the Federal Department of Health and Human Services. It is important to stay on top of the Federal OIG work plan, audits, investigations and other initiatives. However, don’t forget the OIG closer to home your state Inspector General.

Most states will have an Inspector General of the state health department and/or the Medicaid program run by the state. Many also post work plans, audits and investigation reports on their websites. It’s important to stay current on these state issues as well. Let’s look at a couple by way of example.


In December of 2017, the Texas Health and Human Services Commission (HHSC) Inspector General (IO) Audit Division posted their conclusion of an audit they conducted of Gaddy Enterprises, Inc. The objective of the audit was to determine whether fee-for-service claims for Durable Medical Equipment (DME) incontinence supplies paid with Medicaid funds were billed in accordance with state laws, regulations, and program requirements.

The scope of the audit included Medicaid paid claims for the period from September 1, 2015, through August 31, 2016, and a review of relevant activities. They tested (a) Title XIX DME/Medical Supplies Physician Order Forms for 45 clients to determine whether the forms were current and complete and (b) DME Certification and Receipt forms for 50 clients to evaluate the existence and support of paid claims for the audit period.

Fortunately, for this auditee, the test results did not identify any exceptions to Texas Medicaid billing requirements. However, if you provide these types of services it might be a good idea to have a mock audit performed to see if your organization would have favorable results as well.

Knowing what state officials are auditing can be a clue for your compliance program. See more from the Texas IG at


The Florida Health OIG’s website also provides a wealth of information. One of the activities I find useful is to review their annual report. In Appendix C of their most recent report, they list all the complaints they closed. And though the information is somewhat vague, it is still interesting to see the types of complaints coming in, such as the following:

  • “Alleged misuse of position, fraud, & acceptance of bribe”
  • “Concerns related to rehiring dentist who resigned”
  • “Alleged theft and/or diversion of narcotics”
  • “Alleged Medicare fraud”
  • “Alleged misconduct by a physician”
  • “Alleged misuse of grant funds”
  • “Alleged inappropriate care provided by a licensed professional”
  • “Alleged issue related to X-ray Technician”
  • “Alleged patient abuse & Medicaid fraud by a non-Department employee in a non-Department facility (Not a WhistleBlower)”
  • “Concerns related to dental care”
  • “Alleged Medicaid fraud”
  • “Alleged failure to provide medical records”

Each of the closed complaint lists a “disposition” associated with it as well as the type of complaint. The appendix lists the following in its abbreviation legend:

  • WB – Whistleblower
  • IN – Investigation
  • NF – No Further Action
  • RF – Referral to Others
  • WBD – WB Determination
  • MA – Management Advisory
  • INA – Investigative Assist
  • PI – Preliminary Inquiry

Similar to the Federal OIG’s semiannual report, the Florida annual report summarizes key investigations and findings from the year. It can be a wealth of information as you are assessing your organization’s risks and work plan.

For more on the Florida IG see:

In addition to Texas and Florida, other states also have IGs or Medicaid enforcement agencies.Some include:

The lesson here is to make sure you’re familiar with the activity and initiatives of your state inspector general and/or Medicaid inspector general.

Questions or Comments?