United States General Accounting Office
GAO Report to the Committees on Armed
Services, U.S. Senate and House of
Representatives
July 1999
DEFENSE HEALTH
CARE
Improvements Needed
to Reduce Vulnerability
to Fraud and Abuse
GAO/HEHS-99-142
United States
GAO General Accounting Office
Washington, D.C. 20548
Health, Education, and
Human Services Division
B-282038
July 30, 1999
The Honorable John W. Warner
Chairman
The Honorable Carl Levin
Ranking Minority Member
Committee on Armed Services
United States Senate
The Honorable Floyd D. Spence
Chairman
The Honorable Ike Skelton
Ranking Minority Member
Committee on Armed Services
House of Representatives
In fiscal year 1998, the Department of Defense (DOD) spent about $2.5
billion through contracts to provide health care in civilian settings to about
1.5 million beneficiaries, including dependents of active duty personnel,
military retirees, and their dependents. As with other health care systems,
fraud and abuse threaten DOD with significant financial loss and may
adversely affect the quality of care delivered if beneficiaries are exposed
to unnecessary care or not treated at all.
The military health care system is administered by the military services in
partnership with civilian contractors (see app. I). TRICARE, DOD’s
managed health care program, was established to improve beneficiaries’
access to health care while maintaining quality and controlling costs in a
time of military downsizing and budgetary concerns. DOD, including its
Office of Inspector General, and its civilian contractors work together to
prevent and detect TRICARE fraud and abuse.
Senate Report 105-189, accompanying the National Defense Authorization
Act for fiscal year 1999, expressed congressional concerns regarding the
impact of fraud on military health care and directed that we evaluate DOD
efforts to combat it. In response, we (1) analyzed DOD estimates of the
extent of health care fraud and abuse, (2) evaluated DOD efforts to reduce
health care fraud and abuse in civilian settings, and (3) identified
initiatives and incentives that could improve DOD’s antifraud efforts. We
conducted our work between August 1998 and June 1999 in accordance
with generally accepted government auditing standards (see app. II for
details on our scope and methodology).
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It is impossible to precisely quantify the amount lost to health care fraud
Results in Brief and abuse given the nature of such activities, but there is general
consensus in DOD and the health care industry that fraud and abuse could
account for 10 to 20 percent of all health care costs. Given TRICARE
managed care contract expenditures of $5.7 billion between 1996 and
1998, DOD could have lost over $1 billion to fraud and abuse during this
period. In addition to the financial loss, health care fraud and abuse can
also adversely affect the quality of care provided and may cause serious
harm to patients’ health. For instance, when a provider fabricates test
results instead of actually conducting the tests for which it bills DOD,
patients can receive incorrect diagnoses and inadequate medical
treatment.
DOD and its contractors have had limited success in identifying TRICARE
fraud and abuse. For example, contractors have identified a negligible
number of potential fraud cases: of the approximately 50 million claims
that contractors processed between 1996 and 1998, they referred only
about 100 potential fraud cases to DOD for further investigation. This low
level of fraud identification has occurred, in part, because DOD contracts
do not require contractors to aggressively identify and prevent fraud and
abuse. During this same period, DOD recovered about $14 million in
fraudulent payments out of the $5.7 billion spent.
To its credit, DOD recognizes the need to reduce its vulnerability to fraud
and abuse and has identified a number of revisions it could make to its
antifraud policies and requirements. However, it has been slow to
implement these policy revisions, which collectively would require
contractors to put into place a more aggressive fraud and abuse
identification program. Once these revisions are implemented, existing
contracts can be modified to include specific results-oriented goals and
performance measures, thus putting DOD in a better position to evaluate
contractors’ progress in identifying and reducing fraud and abuse. Given
the magnitude of potential financial loss and harm to patients’ health, it is
important that DOD place a high priority on, and establish a concerted
strategy for, reining in health care fraud. DOD’s strategic plan for the
military health system, prepared in response to the Government
Performance and Results Act of 1993, provides an appropriate vehicle for
articulating DOD’s strategy and establishing how the agency will identify
and prevent TRICARE fraud and abuse. This report makes
recommendations to the Secretary of Defense for reducing TRICARE’s
vulnerability to fraud and abuse.
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The mission of the military health care system is to maintain the health of
Background active duty service personnel and provide health care during military
operations. The system also offers health care to non-active duty
beneficiaries, including dependents of active duty personnel and military
retirees and their dependents, through various military-operated hospitals
and clinics worldwide; the system is supplemented through contracts with
civilian health care providers. TRICARE, the name given to the program
providing this care, is a triple-option benefit program designed to give
beneficiaries a choice among a health maintenance organization, a
preferred provider organization, and a fee-for-service benefit. Five
managed care support contractors create networks of civilian health care
providers. These providers submit claims, either individually or as part of
a group practice, to contractors for payment of medical care they have
provided to DOD beneficiaries. Fraud occurs when health care providers
knowingly submit claims containing false information. Common types of
provider fraud and abuse include billing for services not rendered,
misrepresentation of services, and conducting unwarranted medical
procedures.
Multiple players support DOD’s health care fraud identification and
prevention efforts. DOD’s TRICARE Management Activity’s (TMA) Program
Integrity Branch serves as the centralized administrative hub for TRICARE
fraud and abuse activity worldwide. Its primary responsibilities include
(1) developing policies and procedures for the prevention, detection,
investigation, and control of TRICARE fraud and abuse; (2) educating
beneficiaries, health care providers, and others about various health care
fraud and abuse issues; (3) initiating administrative remedies, such as
sanctioning fraudulent providers; and (4) coordinating with other DOD and
external investigative agencies, such as the Federal Bureau of
Investigation, to assist in investigations of health care fraud and abuse. TMA
staff are also responsible for overseeing and ensuring that the five
contractors comply with contractual antifraud requirements.
Each DOD TRICARE contractor is responsible for establishing a program
for identifying and reporting potential health care fraud and abuse to DOD.
To help with this effort, the contractors have subcontracted with one of
two companies to process TRICARE claims. In conjunction with their
claims processing duties, the subcontractors provide various prepayment
controls and perform postpayment reviews that are designed, among other
things, to identify erroneous billings, duplicate claims, and unusual or
excessive patterns of care.
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DOD’s health care fraud identification and prevention efforts are further
supported by investigators from the Defense Criminal Investigative Service
(DCIS), the investigative unit of DOD’s Office of Inspector General. While
DCIS is involved in some efforts to identify fraudulent activity through
undercover operations, the vast majority of cases it investigates are
referred from other sources, such as TMA and whistleblowers.
While the exact extent of health care fraud and abuse can never be
DOD Could Be Losing precisely quantified, the general consensus, based on the experience of
Hundreds of Millions public and private sector organizations such as DOD, the Health Care
of Dollars to Fraud Financing Administration (HCFA), the U.S. Chamber of Commerce, the
Health Insurance Association of America, and the National Health Care
and Abuse Anti-Fraud Association, is that fraud and abuse could account for 10 to 20
percent of all health care costs. Applying this percentage to TRICARE
contract expenditures of about $5.7 billion between 1996 and 1998, DOD
could have lost between $570 million and $1.14 billion to fraud and abuse
over the last 3 years. As health care costs increase over time, fraud and
abuse can be expected to increase proportionally.
Health care fraud and abuse also affect the quality of care provided and
may cause serious harm to patients’ health. For example, illegal practices
such as “sink testing,” which involves throwing out patients’ blood and
urine specimens and fabricating test results, rather than actually
performing the necessary tests, can result in improper diagnoses and
either no medical treatment or unnecessary treatment. Another health care
fraud scheme that may affect patients’ health involves individuals who
provide unauthorized care by falsely representing themselves as licensed
medical providers.
DOD and its contractors have had limited success in identifying TRICARE
DOD Has Had Limited fraud and abuse. To date, contractors have referred relatively few cases to
Success in Identifying TMA for further investigation and development, in part, because DOD’s
Fraud and Abuse contracts do not require contractors to establish a focused, aggressive
antifraud program. Furthermore, DOD has recovered only a relatively small
portion of its estimated losses to fraud and abuse.
DOD Contractors Have DOD depends on its contractors to help it combat fraud and abuse. Up to
Referred Few Fraud Cases this point, however, contractors have identified and referred relatively few
to TMA potential fraud cases to TMA. Table 1 shows that, of approximately
Page 4 GAO/HEHS-99-142 Defense Health Care Fraud
B-282038
50 million claims processed between 1996 and 1998, contractors referred
only about 100 potential fraud cases to TMA for further investigation, 92 of
which were referred by the contractor with the most TRICARE
experience. Although DOD has not established a specific number of cases
its contractors should refer, DOD officials acknowledge that its contractors
could be more aggressive in their efforts to identify potentially fraudulent
activity. According to DOD officials, this lack of aggressiveness is due, in
part, to the fact that DOD contracts do not specify to what extent
contractors should be identifying and referring potential fraud cases.
Moreover, some contractor program integrity staff told us that they were
unclear about the types of potential fraud cases to refer to TMA and that
they were not adequately trained to identify fraud and abuse. In addition,
DOD officials told us that, because two of the five contractors were
relatively new to the TRICARE program, they had not yet compiled
sufficient data to identify fraudulent behavior.
Table 1: Claims Processed and
Potentially Fraudulent Cases Referred Referrals of
by TRICARE Contractors, 1996-98 potential fraud
Contractor Claims processed casesa
Foundation Health Federal Services, Inc. 25,700,000 92
Humana Military Healthcare Services, Inc. 14,500,000 4
TriWest Healthcare Alliance, Inc. 6,100,000 3
Anthem Alliance for Health, Inc. 2,700,000 2
Sierra Military Health Services 1,000,000 0
Total 50,000,000 101
a
Potential fraud cases may involve multiple claims.
Source: TMA.
In addition to their modest efforts specifically associated with identifying
and referring potential fraud cases, contractors use claims editing
software and other approaches to ensure that accurate payments are made
to authorized providers and eligible beneficiaries. Such software and
prepayment screens could also serve to deter fraudulent and abusive
behavior. While TRICARE contractors prevented various types of
erroneous payments totaling about $73 million in 1998 through the use of
claims editing software and other prepayment screens and edits, neither
TMA nor contractors could quantify what portion of this amount might be
associated with fraud and abuse. TMA officials acknowledged that while
some of this amount could have been related to fraud and abuse, they
believe the vast majority represented payments generated by clerical and
Page 5 GAO/HEHS-99-142 Defense Health Care Fraud
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other types of errors. They told us, however, that prepayment screens and
edits are likely to deter fraudulent and abusive behavior on the part of
some health care providers.
DOD Has Recovered a DOD and its contractors’ antifraud efforts have resulted in the recovery of a
Small Amount of Its tiny fraction of DOD’s estimated losses from fraud and abuse. For example,
Estimated Losses to Fraud as table 2 shows, between 1996 and 1998, DOD recovered only about
$14 million in fraudulent payments. This amount is negligible when
and Abuse compared with estimated losses of between $570 million and $1.14 billion
during the same period. Even though the exact extent of TRICARE fraud
and abuse is unknown, the small amount of recoveries indicates that DOD
efforts have considerable room for improvement and that DOD’s
vulnerability to fraud and abuse is still high.
Table 2: Results of TMA Antifraud
Efforts, 1996-98 DOD estimates of fraud Fraudulent payments
Year and abuse (in millions) recovereda (in millions)
1996 $130-260 $1.2
1997 190-380 7.1
1998 250-500 6.1
Total $570-1,140 $14.4
a
These figures may be related to cases identified in previous years.
In addition to recovering fraudulent payments, between 1996 and 1998 DOD
participated with other organizations in investigations of TRICARE and
other government health care programs, such as Medicare and Medicaid,
which resulted in penalties, fines, and other assessments totaling
approximately $804 million, 199 criminal charges, and 150 civil
settlements. TMA officials told us, however, that they could not identify the
portion of these penalties, fines, and other assessments associated with
the TRICARE program or its funds.
While DOD recognizes that it needs to reduce its vulnerability to fraud and
Opportunities Exist to abuse, it has been slow to implement revised policies and requirements
Improve TRICARE’s directing its contractors to put into place a much more aggressive fraud
Antifraud Efforts and abuse identification program. Once these revisions are implemented,
DOD’s efforts could also be strengthened by establishing results-oriented
goals and performance measures in its managed care contracts and by
overseeing contractors to assess their performance against these goals and
Page 6 GAO/HEHS-99-142 Defense Health Care Fraud
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measures. In addition, given the potential magnitude of fraud and abuse
within TRICARE, DOD top management could better focus and otherwise
improve DOD’s antifraud efforts by committing itself to, and developing a
concerted strategy for, addressing the problem in its military health
system strategic plan. Such plans are mandated by the Government
Performance and Results Act of 1993 (also known as the Results Act).1
These steps should improve DOD’s antifraud activities and help reduce the
adverse impact fraud and abuse currently have on TRICARE and its
beneficiaries.
TMA Is in the Process of According to the Chief of TMA’s Program Integrity Branch, DOD’s antifraud
Implementing Revised policies and procedures are vague concerning contractors’
Antifraud Requirements responsibilities. She told us that DOD policies do not direct contractors to
provide their antifraud staff with training in fraud detection and
prevention methods, nor do the policies guide contractors as to the level
of emphasis they should place on such activities. In an effort to improve
the effectiveness of its antifraud efforts, TMA is in the process of
implementing revised program integrity policies and procedures to require
more aggressive fraud identification activities by its contractors. Although
TMA originally intended that its contractors implement these revisions by
October 1, 1998, TMA and the contractors have been negotiating for over 8
months to formally implement these changes. As of June 1, 1999, DOD and
its contractors had not yet agreed to contract terms. If and when
implemented, these changes would include the following requirements of
TRICARE contractors:
• Develop and publish a corporate antifraud strategy. This strategy,
developed and endorsed by corporate management to underscore its
commitment to health care fraud detection and prevention, includes plans
for (1) maintaining a focus on increased health care fraud awareness,
(2) developing processes that identify fraud, (3) aggressively referring
health care fraud cases to TMA, (4) assisting in the prosecution of cases,
and (5) developing deterrents to health care fraud. TMA officials told us
that having a published corporate antifraud strategy would better enable
its contractors to focus their fraud prevention and detection activities, as
well as generate companywide support for these efforts.
• Use new antifraud software. Antifraud software will be used to analyze
health care data associated with the type, frequency, duration, and extent
of services to identify patterns of probable fraudulent or abusive practices
1
The Results Act (P.L. 103-62) requires agencies to clearly define their missions, set goals, measure
performance, and report on their accomplishments.
Page 7 GAO/HEHS-99-142 Defense Health Care Fraud
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by providers and beneficiaries. TMA officials told us that using artificial
intelligence software would allow contractors to be more effective in
identifying fraud and would likely increase the number of fraud cases they
referred to TMA.
• Establish and maintain an antifraud training program. Specifically,
contractors will train their staff to identify abnormal patterns of care, over-
or underutilization of services, and other practices that may indicate
fraudulent or abusive behavior. According to TMA officials, with new
developments in information technology and frequent contractor staff
turnover, structured training would help institutionalize contractors’
antifraud activities. Some contractor and subcontractor staff told us they
were not adequately trained to effectively identify fraud and abuse and
would benefit from a structured, continuously updated antifraud
education program.
In addition, in an effort to increase beneficiary awareness of health care
fraud and abuse, TMA has directed its contractors to include a fraud hot
line telephone number and mailing address on beneficiaries’ “explanation
of benefits” statement. This information provides beneficiaries with a
contact in the event fraudulent activity is suspected or observed. As of
April 1999, all five contractors had included an antifraud contact on their
explanation of benefits statements.
Although TRICARE policy requires that claims be denied when submitted
under a clinic or group practice subidentifier, TMA waived this requirement
in 1996 in an effort to improve claims processing timeliness. However, our
March 1999 testimony raised a concern that TRICARE claims did not
always identify the individual provider rendering care, potentially masking
fraudulent or abusive activity. In response, as of June 1, 1999, TMA directed
all of its contractors to pay only those claims that identify providers
individually, rather than their group or clinic affiliation.2 TMA officials told
us that information on individual providers is also needed to monitor
quality of care.
TMA has not established results-oriented goals or performance measures
for its managed care contracts, although doing so would help it assess
contractors’ performance as well as enable contractors to track their own
progress in combating fraud and abuse.3 Comparing contractor
2
Defense Health Care: Management Attention Needed to Make TRICARE More Effective and
User-Friendly (GAO/T-HEHS-99-81, Mar. 11, 1999).
3
In 1994, DOD’s Office of Inspector General recommended that DOD establish performance measures
related to its health care fraud detection activities.
Page 8 GAO/HEHS-99-142 Defense Health Care Fraud
B-282038
performance with established goals and measures would enable TMA to
identify program deficiencies and help contractors focus their efforts on
needed improvements.
DOD’s Military Health As required by the Results Act, agencies must articulate, in a strategic
System Strategic Plan Does plan, how they will address issues that significantly affect their ability to
Not Address TRICARE manage program operations. Given the potential magnitude of health care
fraud and abuse within TRICARE, it is important for DOD to address this
Fraud and Abuse concern in such a plan. DOD’s current military health system strategic plan,
however, does not specify how the agency will combat TRICARE fraud
and abuse. A more complete plan would provide better direction and
guidance by including an antifraud mission statement, identifying
long-term antifraud objectives and describing how DOD would achieve
them, and explaining key external factors that could affect achievement of
those objectives.
In addition, taking a more strategic approach would help TMA establish
annual performance goals and measures related to its long-term objectives
and determine how it will assess its progress in achieving them. Specific
performance measures could include calculating the cost-effectiveness of
TMA’s antifraud efforts. By benchmarking and periodically assessing its
progress in combating TRICARE fraud and abuse, TMA would be in a better
position to measure its vulnerability to such activity, focus its antifraud
efforts on the most prevalent types of fraud and abuse, and allocate an
appropriate level of resources to combat this problem.
Health care fraud and abuse within TRICARE potentially result in the loss
Conclusions of hundreds of millions of dollars and adversely affect the health of untold
numbers of beneficiaries. Despite TRICARE’s known vulnerability, DOD’s
activities thus far have not been very successful in identifying fraud and
abuse. Furthermore, as health care costs increase over time, fraud and
abuse can be expected to increase proportionally. While DOD recognizes
the importance of its contractors’ role in combating fraud and abuse and
has been negotiating with them to implement new antifraud requirements,
it has been slow in doing so. If effectively implemented, these
requirements would help DOD and its contractors increase the
effectiveness of their antifraud efforts; in our view, immediate attention
should be focused on getting these requirements in place. In addition, by
establishing results-oriented goals and performance measures for its
contractors, TMA would be in a better position to identify program
Page 9 GAO/HEHS-99-142 Defense Health Care Fraud
B-282038
deficiencies and help its contractors more effectively target their efforts to
reduce fraud and abuse. Given the relatively few dollars DOD has recovered
and the magnitude of potential fraudulent activity, DOD would also benefit
from adopting a more strategic approach. We believe DOD’s military health
system strategic plan provides an appropriate mechanism for articulating
this approach and for setting forth the specific goals, objectives, and
strategies for reducing DOD’s vulnerability to TRICARE fraud and abuse.
Ultimately, the success of DOD’s antifraud efforts will depend on the
priority it places on fraud prevention and detection and how effectively it
oversees its contractors’ antifraud activities.
To reduce TRICARE’s vulnerability to fraud and abuse, we recommend
Recommendations that the Secretary of Defense direct the Assistant Secretary of Defense
(Health Affairs) to
• expedite implementation of TMA’s revised antifraud requirements,
including the requirements that contractors develop a corporate antifraud
strategy, utilize new antifraud software, and develop an antifraud training
program;
• modify current contracts to establish specific results-oriented goals and
performance measures for contractors; and
• include in DOD’s military health system strategic plan how DOD will combat
health care fraud and abuse and an assessment of DOD’s performance in
combating such activity.
In commenting on a draft of this report, the Assistant Secretary of Defense
Agency Comments (Health Affairs) stated that the report will provide DOD with invaluable
and Our Evaluation assistance as it begins to do more in the area of reducing fraud and abuse
in its health care program. In response to our recommendations, DOD
agreed to expedite implementation of revised antifraud requirements by
requiring contractors to develop a corporate antifraud strategy, utilize
antifraud software, and develop an antifraud training program. In addition,
DOD agreed to include in the TMA strategic plan how DOD will combat health
care fraud and abuse.
However, DOD is concerned about establishing specific results-oriented
goals and performance measures for its contractors. While DOD agrees that
establishing goals and measures is desirable, it states it is unaware of a
methodology that would enable it to do so. We recognize that finding the
right methodology is challenging, but establishing program-specific goals
Page 10 GAO/HEHS-99-142 Defense Health Care Fraud
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and performance measures for key program activities is a fundamental
responsibility placed on all agencies by the Results Act. In our view,
combating fraud and abuse is a key management activity; therefore, DOD
needs to establish goals and measures to assess contractors’ performance,
identify program deficiencies, and enable contractors to track their own
progress in combating fraud and abuse.
DOD also raised concerns about data presentation in two areas. First, it was
concerned that a comparison between the number of claims processed
and the number of fraud cases identified presupposes a correlation
between the two sets of data. DOD stated that no industry standard based
on such a correlation exists. We do not dispute that there is no industry
standard. However, by virtually any standard, DOD contractor referrals of
101 potential fraud cases out of about 50,000,000 processed claims
represent a minimal level of activity. In this context, it seems clear that
there is room for the contractors to be more aggressive in their efforts to
identify fraudulent activity. Further, DOD concurred with our
recommendation to expedite the implementation of revised antifraud
policies and requirements that place greater demands on contractors to
identify and prevent fraud.
Second, DOD raised a concern that the report compares gross estimates of
potential amounts lost to fraud and abuse with only the amounts
recovered in fraud cases. Our report clearly states that DOD was unable to
estimate recoveries for abuse but reported that contractors prevented
erroneous payments totaling about $73 million. Moreover, most of this
$73 million was not attributable to abuse but rather to payments resulting
from clerical and other types of errors.
DOD’s comments are included as appendix III.
Page 11 GAO/HEHS-99-142 Defense Health Care Fraud
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We are sending copies of this report to the Honorable William S. Cohen,
Secretary of Defense, and other interested parties. We will also make
copies available to others upon request.
If you or your staffs have any questions about this report, please contact
me at (202) 512-7101 or Michael T. Blair, Jr., Assistant Director, at
(404) 679-1944. Jeffrey L. Pounds, Steve D. Morris, and Michael Tropauer
also made key contributions to this report.
Stephen P. Backhus
Director, Veterans’ Affairs and
Military Health Care Issues
Page 12 GAO/HEHS-99-142 Defense Health Care Fraud
Page 13 GAO/HEHS-99-142 Defense Health Care Fraud
Contents
Letter 1
Appendix I 16
TRICARE Contractors
and Subcontractors
Responsible for
Antifraud Efforts
Appendix II 17
Scope and
Methodology
Appendix III 18
Comments From the
Department of
Defense
Tables Table 1: Claims Processed and Potentially Fraudulent Cases 5
Referred by TRICARE Contractors, 1996-98
Table 2: Results of TMA Antifraud Efforts, 1996-98 6
Abbreviations
DCIS Defense Criminal Investigative Service
DOD Department of Defense
HCFA Health Care Financing Administration
TMA TRICARE Management Activity
Page 14 GAO/HEHS-99-142 Defense Health Care Fraud
Page 15 GAO/HEHS-99-142 Defense Health Care Fraud
Appendix I
TRICARE Contractors and Subcontractors
Responsible for Antifraud Efforts
TRICARE regions TRICARE contractors Subcontractors
Northwest Foundation Health Federal Wisconsin Physicians
Services, Inc. Service
Southwest Foundation Health Federal Wisconsin Physicians
Services, Inc. Service
Southern California, Golden Foundation Health Federal Palmetto Government
Gate, and Hawaii-Pacific Services, Inc. Benefits Administrators
Southeast and Gulf South Humana Military Healthcare Palmetto Government
Services, Inc. Benefits Administrators
Central TriWest Healthcare Alliance, Palmetto Government
Inc. Benefits Administrators
Northeast Sierra Military Health Palmetto Government
Services Benefits Administrators
Mid-Atlantic and Heartland Anthem Alliance for Health, Palmetto Government
Inc. Benefits Administrators
Page 16 GAO/HEHS-99-142 Defense Health Care Fraud
Appendix II
Scope and Methodology
To evaluate DOD’s antifraud efforts, we met with DOD officials responsible
for planning, managing, and implementing TRICARE’s antifraud program.
We reviewed DOD regulations, policies, and requirements pertaining to its
program integrity functions, as well as strategic plans developed by DOD.
We also reviewed antifraud requirements outlined in contracts with
managed care support contractors hired by DOD to administer the
TRICARE program regionally. In addition, we visited DOD’s five contractors
and their two subcontractors to obtain information on their antifraud
efforts. We also interviewed representatives of public and private sector
organizations involved in health care fraud issues, including the Health
Care Financing Administration; the Federal Bureau of Investigation; and
the National Health Care Anti-Fraud Association, whose mission is to
improve the private and public sectors’ detection, investigation, and
prevention of health care fraud.
Page 17 GAO/HEHS-99-142 Defense Health Care Fraud
Appendix III
Comments From the Department of Defense
Page 18 GAO/HEHS-99-142 Defense Health Care Fraud
Appendix III
Comments From the Department of Defense
Now on p. 10.
Page 19 GAO/HEHS-99-142 Defense Health Care Fraud
Appendix III
Comments From the Department of Defense
Now on pp. 5-6.
(101621) Page 20 GAO/HEHS-99-142 Defense Health Care Fraud
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Address Correction Requested
Defense Health Care: Improvements Needed to Reduce Vulnerability to Fraud and Abuse
Published by the Government Accountability Office on 1999-07-30.
Below is a raw (and likely hideous) rendition of the original report. (PDF)