OIG Enforcement Trends

SDPs · CMPs & Exclusions · Advisory Opinions · Criminal & Civil Actions · CIAs

Source: oig.hhs.gov Period: Records: Updated: · refreshes quarterly

Data compiled from public OIG enforcement listings, the Advisory Opinion browse index, and the Corporate Integrity Agreement browse index. Enforcement category assignments reflect a keyword-based classifier applied to the action title and OIG's one-sentence summary; cases implicating multiple theories (e.g. AKS + unlicensed provider) fall into the highest-precedence category. Provider type classifications are similarly keyword-based.

Advisory Opinion arrangement type and requestor industry classifications are manual (each opinion reviewed individually). The statutes implicated tags reflect what each opinion analyzes directly; note that every OIG advisory opinion implicates AKS by default, so the tag is only analytically useful when combined with other statutes (most notably the Beneficiary Inducement CMP). OIG does not have jurisdiction to opine on the physician self-referral law (Stark); Stark enforcement sits with CMS.

Criminal & Civil Actions are DOJ-led enforcement matters investigated, supported, or referred by HHS-OIG and posted to OIG's enforcement listing. The dashboard filters out non-healthcare actions (SNAP, passport fraud, alien-smuggling, defense-contractor matters, etc.) that appear on the OIG list because of OIG's broader oversight role beyond Medicare/Medicaid. Resolution stage (Indictment / Plea / Conviction / Sentence / Civil Settlement / DPA-NPA) is inferred from the title verbs. Dollar amounts come from the title where stated; many criminal cases have no $ figure in the title and are shown as "—". Same-actor cases at successive stages (e.g. indictment then plea then sentence) are kept as separate enforcement events.

Corporate Integrity Agreements (CIAs) are the post-settlement compliance obligations OIG imposes when it agrees to permissively waive its exclusion authority in exchange for a remediation regime. The lighter Integrity Agreement (IA) form is typically used for individuals and small entities. Each CIA listing on OIG's site identifies a Category (Claims Review, Arrangement Review, Quality of Care, etc.) that signals the type of independent review obligation OIG built into the agreement, and Tags identifying covered service lines or risk areas. The standard CIA term is 5 years; 3-year terms typically apply to IAs and lower-risk matters. Each settlement amount shown is the dollar amount of the underlying FCA settlement to which the CIA is appended; CIAs themselves do not impose monetary penalties beyond stipulated penalties for breach. Sector and underlying conduct theory classifications in this dashboard are derived from the entity name and OIG-provided summary; for cases without a press release on the OIG listing, the theory is shown as "Unspecified."

Each row links to the underlying OIG page (click the ↗ in the Src column). Exclusion-only actions are shown with a $0 amount and excluded from the dollar chart but counted in the frequency chart. Two distinct categories use the word "excluded": Excluded Individual means the settling provider employed or contracted with an excluded person, while Affirmative Exclusion means OIG excluded the named party itself. Affirmative exclusions that state a conduct theory (kickbacks, medically unnecessary services, false claims) are categorized by that theory instead. A dagger (†) on a provider type means it was inferred from the entity’s name because OIG’s notice did not state one; treat those as unverified. Affirmative exclusions whose notice gives no usable signal are left as Other / Unclassified rather than guessed. In each CMP case resolved through settlement agreement, the settling party has contested OIG's allegations and denied any liability; no CMP judgment or finding of liability has been made.

About this dashboard. Maintained by Kaufman & Canoles' Health Care Practice Group. We update this page quarterly as new enforcement actions, advisory opinions, and CIAs are posted to OIG's site. Where appropriate, our updates also include reclassifications based on additional facts surfaced after the initial posting.

Disclaimer. This dashboard is provided for informational and educational purposes only. It is not legal advice and does not create an attorney-client relationship. The classifications, summaries, and analytical groupings reflect the editors' interpretation of public OIG and DOJ source materials and may not capture every nuance of the underlying matter; readers should review the linked OIG and DOJ pages and consult qualified counsel before making any decision based on this content. Past enforcement results do not predict future outcomes in any individual matter. Use of this dashboard is at the reader's own risk.