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Fraud Risk Spectrum

The government's primary civil tool for addressing health care fraud is the False Claims Act (FCA). Most FCA cases are resolved through settlement agreements in which the government alleges fraudulent conduct and typically the settling parties do not admit liability. Depending on the facts and circumstances presented, OIG will usually pursue one of the following approaches when settling a health care fraud case: (1) exclusion; (2) heightened scrutiny; (3) integrity obligations; (4) take no further action; or (5) in the case of a good faith and cooperative self-disclosure, release 1128(b)(7) exclusion with no integrity obligations. OIG’s Risk Spectrum illustrates these approaches.

A graphic that shows high risk to low risk respectfully: Exclusion; Heightened Scrutiny; CIAs; No Further Action; Self-Disclosure

FY 2023 Q1-Q3

Fraud Risk Spectrum 2023 Q1: 9 exclusions, 2 heightened scrutiny, 17 CIAs, 132 no further action, 4 self-disclosure

Fraud Risk Spectrum 2022 Q1-Q4: 11 exclusions, 1 heightened scrutiny, 37 CIAs, 193 no further action, 6 self-disclosure

Updated Risk Spectrum for 2021 Quarters 1 through 4

Updated Risk Spectrum for 2020 Quarters 1 through 4

Updated 2019 False Claims Act Settlements on the Risk Spectrum