Program Integrity

Protecting the Program Without Becoming the Harm

Practical habits for any DHS staff member whose work touches program integrity communication, review, or the people affected by it.

45–52 minutes · 4 lessons · Voluntary learning

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Course outline

Running a program integrity moment through the toolkit
Apply the Equity Analysis Toolkit's five stages to a realistic program integrity communication decision.
12 minutes
Where bias risk hides, and the safeguard against it
Learn to look for bias risk in review patterns rather than intentions, and practice the concrete safeguard available to any staff member.
11 minutes
Drafting the notice: a worked example
Draft an actual program integrity notice using the four elements from lesson one, and see how the same information lands differently depending on how it is written.
12 minutes
Your commitment: a check you will actually run
Commit to running the four-element check on one real communication and the pattern-safeguard question on one real process, with a specific date and colleague attached.
12 minutes

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What you’ll be able to do

Explore and practice

Apply the Equity Analysis Toolkit's stages to a program integrity communication decision.
Identify where bias risk can enter program integrity review through patterns rather than intentions, and name a concrete safeguard.
Draft a program integrity notice or explanation that is accurate, non-alarming, and non-dismissive.

What you can take into your work

A worked scenario applying the toolkit's stages to a real-shaped situation.
One knowledge check on where bias risk hides in review patterns.

Take one program integrity communication your team sends or could send, and check it against the four elements this course describes: what's happening, what stays the same, what's still open, and who to contact.

Read the introduction

The first two courses in this series established two things: fraud enforcement has real costs beyond the fraud itself, and public conversation about fraud can slide into generalizing about a community. This course is about what to actually do with that understanding — concrete habits for communication, for noticing bias risk in how scrutiny gets applied, and for using the Equity Analysis Toolkit when a program integrity decision affects real people.

Program integrity, done well

A one-page reminder for anyone communicating about or reviewing program integrity work

Protecting the program and respecting the person are the same job, done right.

Keep the toolkit's stages and the bias-pattern safeguard ready for the next review, notice, or program integrity question.

The toolkit's five stages apply to how a program integrity action is communicated, not just to policy decisions.
A good notice says what's happening, what stays the same, what's still open, and who to contact.
Bias risk hides in patterns, not intentions — disaggregate who gets flagged and ask why.
Raising a pattern you've noticed is everyone's responsibility, not only the responsibility of staff with direct data access.
Omitting 'what stays the same' from a notice is a common gap that drives unnecessary fear even in an accurate notice.
Protecting the program and respecting the person are the same goal when a review is scoped, communicated well, and checked for bias.

Run your next program integrity communication through the toolkit's first two stages before it goes out.

Before a notice goes out, ask

Have we named the actual action accurately, without inflating or minimizing it?
Who does this affect differently, and have we accounted for it?
Is there a real way for someone to ask a question and get an answer from a person?
After this goes out, how will we know if it worked?

Read your own draft as the reader would

Have we said clearly what is not changing right now?
Have we given an honest, specific timeframe for what's still open?
Is the contact a named person, not just a general office?

What this course does not replace

The official equity analysis toolkit process for an actual policy or budget decision.
Program integrity's own investigative procedures and legal standards.
Legal review of any specific provider action or communication.

Participation and course completion in this program do not count toward DHS-required training credits unless management, a director, or DHS leadership expressly approves an exception.

Sources and further reading

KFF, What to Know About Recent Federal Actions Involving State Medicaid Program Integrity
Nonpartisan explainer on federal program integrity actions, including data-driven review approaches states are adopting.
Centers for Medicare & Medicaid Services, Program Integrity
Federal guidance on Medicaid program integrity strategy, including risk-based provider screening.

All research and sources across the program

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Course outline