For many organizations, the question is not whether 2 CFR 200 matters. It is whether their current systems, documentation, and day-to-day practices actually match what the Uniform Guidance requires. That question feels more urgent now because of the current government-wide revisions that took effect on October 1, 2024. That is where a good 2 CFR…
Audit
Key Takeaways from NGMA AGT 2026: What Today’s Grants Landscape Means for Federal Agencies and Recipients
Key Takeaways from NGMA AGT 2026: What Today’s Grants Landscape Means for Federal Agencies and Recipients Kevin Gregory, Project Lead for a federal post-award monitoring contract at IntegrityM and Certified Grants Management Specialist (CGMS), recently attended the National Grants Management Association (NGMA) Annual Grants Training (AGT) 2026, one of the largest and most influential gatherings…
Subrecipient Monitoring That Survives Single Audit– Part 1 of 2
Effective subrecipient monitoring is essential for any pass-through entity that administers federal funds. To “survive” a Single Audit (the comprehensive annual audit for entities expending significant federal funds), organizations must go beyond minimal oversight. They need a structured approach that satisfies Uniform Guidance requirements and stands up to auditor scrutiny. This post outlines three pillars of audit-proof…
Subrecipient Monitoring That Survives Single Audit– Part 2 of 2
In continuation of our Subrecipient Monitoring series we continue to explore the remaining Pillars. Pillar 2 – Verification: Trust But Verify Subrecipient Compliance Once subawards are made (and risk-tiering is in place), the mantra is “trust but verify.” Verification in subrecipient monitoring means continually checking that subrecipients remain in compliance and on track to meet…
Strengthening Medicare Program Integrity: The Power of Deterrence in Combating Fraud, Waste, and Abuse
In the ongoing effort to protect the Medicare program, deterrence stands out as a powerful and cost-effective strategy. While detection and enforcement remain critical, deterrence shifts the focus from reacting to fraud after it occurs to preventing it before it starts. By increasing the perceived risk of getting caught and reducing opportunities for abuse, deterrence…
Navigating the No Surprises Act: A New Era of Transparency in Healthcare
The No Surprises Act, implemented by the Centers for Medicare & Medicaid Services (CMS), marks a major milestone in protecting patients from unexpected medical bills. This landmark legislation, effective January 1, 2022, addresses long-standing issues related to surprise billing and healthcare price transparency, problems that have affected millions of patients for years. Surprise billing occurs…
From Policy Gaps to Compliance Confidence: Strengthening Grant Management Under 2 CFR 200
Part 2: Practical Steps to Strengthen Your Compliance Framework What Effective Policies and Procedures Look Like Not all written policies are created equal. To satisfy Uniform Guidance requirements and withstand audits, policies and procedures must be: Strong policies not only meet compliance requirements but also create consistency across the organization. They help staff make decisions…
Suspect Payments in Medicare Advantage: Why Transparency Matters
Understanding the context of “Suspect Payments” In Medicare Advantage, payment practices work best when they are clear, consistent, and aligned with beneficiary needs. Strengthening oversight not only reduces compliance risk but also reinforces trust in an organization’s commitment to doing what’s right. Medicare Advantage payment structures can be complex, and certain arrangements may warrant closer…
From Policy Gaps to Compliance Confidence: Strengthening Grant Management Under 2 CFR 200
Part 1: Why Written Policies and Procedures Matter The Most Common Federal Grant Audit Finding and How to Avoid It Federal grants play a vital role in advancing public service, driving innovation, and supporting communities across the United States. Agencies and organizations that receive federal funding bear a critical responsibility: managing taxpayer dollars with integrity,…
Highlighting Public Tools That Advance Medicaid Transparency and Oversight
Let’s talk about…the power of public data tools. Public data dashboards are vital tools for strengthening accountability in healthcare programs. In Medicare and Medicaid, they equip beneficiaries, agencies, and policymakers with insight into how services are delivered and how that information can inform policy development and updates. By making complex data accessible and actionable, these…
Advancing Healthcare Claims Technology
IntegrityM partners with AI and machine learning developers to embed clinical, regulatory, and compliance expertise into the design and deployment of healthcare automation tools. As a trusted healthcare partner, we guide the use of AI/ML technologies in medical coding, claims analysis, and utilization review, transforming complex healthcare data into outcomes that are accurate, compliant, and defensible….
Medicare’s $60 Billion Challenge
Medicare loses an estimated $60 billion annually to fraud, waste, and abuse (FWA), a serious drain on critical health resources that directly affects the care and well-being of millions of beneficiaries. These losses not only compromise the integrity of the program but also erode public trust in one of our nation’s most essential public health…
What Is Statistical Extrapolation and Why Does It Matter?
Extrapolation is a statistical method used to estimate values for an entire population based on a smaller, randomly selected sample. In healthcare audits, this technique allows auditors to review a manageable subset of claims and project the findings to the full universe, saving time and resources while maintaining statistical integrity when applied properly. This approach…
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Four Schemes to be Wary of Amid Soaring COVID-19 Fraud Reports
While combating fraud, waste, and abuse is a federal initiative upheld by each state, administrators achieve this through various means. Some state OIGs report that their work is primarily focused on beneficiary fraud, while some work in both beneficiary and provider fraud. Furthermore, state OIGs do not always see the same types of fraud, waste,…
Contact Tracing 101: 5 Quick Facts on Our Most Effective Tool to #flattenthecurve
What is Contact Tracing? Contact Tracing is not new. It has been used to control infectious disease for decades. Contact Tracing is one of the oldest public health tactics and has been used with smallpox, Ebola, tuberculosis, and AIDS. So what exactly is contact tracing? It is the process of supporting patients with suspected or…
Best Practices for Conducting Healthcare Fraud Investigation Interviews
Healthcare Fraud Investigators provide a valuable resource in the fraud analysis process. They perform in-depth evaluation and analysis of potential fraud cases and requests for information using claims and other sources of data. One method for gathering information during an investigation is performing interviews. Along with analysis of records and other data, conducting fraud investigation…
Using the CIGIE Quality Standards for Inspection and Evaluation
It is important for every industry to have a framework of quality standards by which to measure performance and to establish credibility. Most people have heard of the Yellow Book, or The Generally Accepted Government Auditing Standards, that is used by audit organizations. Evaluation work does not have a well-known equivalent and organizations are often…
Healthcare Secret Shopping: An Effective Tool for Detecting Fraud and Abuse
The Government Accountability Office (GAO) made headlines recently when sharing news that 11 of 12 fictitious applicants obtained coverage for health insurance through the Federal marketplace. GAO targeted the Federal marketplace with secret shopping – constructing fictitious applicants who should not have received health insurance. The secret shopping applicants provided invalid Social Security information or…
Ambulance Billing Fraud and False Claims
Medicare ambulance claims, just like everything involved with Medicare, must meet certain requirements to be considered valid ambulance transport claims. The main factor is the transport must be considered “medically necessary” under Federal Law. To do this, two specific criteria must be met: The use of other transportation methods is contraindicated by the condition of…
Electronic Health Record Challenges: A Look at EHR Fraud, Security Issues, & Adoption Barriers
Since the late 20th to early 21st century, reports such as “To Err is Human” by the Institute of Medicine have been published and have advocated the adoption of electronic health records (EHRs). EHRs offer tools to mitigate human error, be a medium to share personal medical records securely across the country, establish electronic communications…
Medicaid Dental Fraud, Waste and Abuse Reporting
OIG has just released the last in a series of four Medicaid dental fraud reports. The reports identified dentists and orthodontists with questionable billing practices in New York, Louisiana, Indiana, and California. These reports are just one part of OIG’s multi-faceted approach to combat dental fraud. The agency also has ongoing audits of Medicaid dental…
Identifying Fraud is Not Always Easy: Analyzing State Medicaid Fraud Control Unit Reports
The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently released a data chart offering fiscal year (FY) 2014 statistical data for the Medicaid Fraud Control Units. For those of you unfamiliar with Medicaid Fraud Control Units (MFCU), the MFCUs are: single identifiable entities of State government that conduct a Statewide…
Medicaid Managed Care Audits Pay Off…In the Long Run
In May 2014, the Government Accountability Office (GAO) released a report calling for increased oversight of Medicaid managed care spending (the report can be found here). GAO reported that “Most state and federal program integrity officials we interviewed told us that they did not closely examine Medicaid managed care payments, but instead primarily focused their…
Improving Healthcare Error Reporting In Healthcare Audits
The purpose of this paper is to offer a technique to more clearly and fully describe healthcare errors detected in audits, which can lead to improved return on investment (ROI) for healthcare audits. A clear and complete description of all identified errors in a healthcare audit report will help assure that all readers of the…
Evaluations Have Standards Too: An Introduction to Government Evaluation Standards
A few years ago, one of our team members served as the masters of ceremonies at a training program for individuals interested in government evaluation. He periodically mentioned the Blue Book in the transitions between the various presenters. Later, during a break, numerous people asked him about this Blue Book. It was a bit surprising….
