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Kansas State Medicaid Fraud Control Unit: 2012 Onsite Review


OIG oversees all Medicaid Fraud Control Units (MFCU or Unit) with respect to Federal grant compliance. As part of this oversight, OIG reviews all Units. These reviews assess Unit performance in accordance with the 12 MFCU performance standards and monitor Unit compliance with Federal grant requirements. This is a review of the Kansas Unit.


We analyzed data from seven sources: (1) a review of policies, procedures, and documentation of the Unit's operations, staffing, and caseload; (2) a review of financial documentation; (3) structured interviews with key stakeholders; (4) a survey of Unit staff; (5) structured interviews with the Unit's management; (6) an onsite review of case files; and (7) an onsite review of Unit operations.


For fiscal years (FY) 2009 through 2011, the Unit reported combined civil and criminal recoveries of nearly $66 million and 44 convictions. The Unit increased referrals through education and outreach efforts. We found no evidence of significant noncompliance with applicable laws, regulations, or policy transmittals. However, we found opportunities for improvement and instances in which the Unit did not fully meet the performance standards. Specifically, for FYs 2009 and 2010, the Unit had several internal control weaknesses and inadequate policies and procedures related to certain expenditures. For FYs 2009 through 2011, the Unit did not report the identities of all convicted providers to OIG within 30 days of sentencing for the purpose of program exclusion. The Unit also did not establish annual training plans for its professional disciplines. Finally, case files had inconsistent documentation of supervisory approval for key stages of investigations, yet cases proceeded timely.


Based on these findings, the Kansas Unit should: (1) develop policies and procedures to address internal control weaknesses; (2) develop a protocol to ensure identities of convicted providers are reported to OIG; (3) establish annual training plans for professional disciplines; and (4) ensure that all case files contain opening and closing investigative memoranda, documented supervisory approval, and documented periodic supervisory reviews. The Unit concurred with all four of our recommendations.