Phase 5: Stabilize & govern · Step 5.2
Run program integrity & fraud control
Year 1 onward · UHA Program Integrity; HHS-OIG; DOJDiscuss this step
operationallikelihood: mediumimpact: medium
Fraud concentrated on one payer
Medicare FFS's 7.7% improper payment rate applied to UHP benefits would be about $297.3B.
Early warning signs
- Improper payment rate
- Billing anomalies
Mitigation
- 2.5% admin budget with integrity funding
- Prepayment review in high-risk categories
Implementation risks
| Risk | Mitigation |
|---|---|
| Medicare FFS's improper payment rate was about 7.7% in FY2024. Applied to UHP benefits, that would be about $297.3B a year. | Most improper payments are documentation errors, not fraud; budget enough for review. |