Catherine Boerner (firstname.lastname@example.org) is President at Boerner Consulting, LLC in New Berlin, WI.
Have you seen the OIG’s “Fraud Risk Indicator”? It’s the figure below, which can be found on their website at https://oig.hhs.gov/compliance/corporate-integrity-agreements/risk.asp (https://bit.ly/2ImyIzw) to gain a further understanding and review the “published criteria.”
Basically, OIG assigns people to the following categories , based on their criteria, when gathering information on a False Claims Act (FCA) case. OIG will use its exclusion authority differently for parties in each category.