In one health care organization, a provider was reviewed and cleared through routine payment integrity processes. Months later, that same provider became the subject of a fraud investigation, based on patterns that had been present all along. Both reviews were technically correct within their scope. But together, they revealed something more concerning: The system itself was not aligned. Health care organizations invest heavily in payment integrity (PI) and special investigations units (SIU) to detect improper payments, investigate fraud, and protect financial resources. These functions are designed to serve as safeguards within increasingly complex reimbursement systems. Yet despite these investments, many organizations continue to experience recurring provider issues, rising investigative workloads, and persistent financial leakage. The problem is often framed as one of fraud sophistication or insufficient detection. But that framing misses something more fundamental. By the time fraud is detected, the system has already failed.
Payment integrity and SIU operate with a shared mission but different orientations. PI focuses on transactional accuracy, reviewing claims, validating coding, and correcting payments. SIU focuses on provider behavior, identifying patterns, intent, and potential fraud. In theory, these functions should reinforce one another. In practice, they often operate in parallel. This creates a critical risk: The same provider or billing pattern may be reviewed by both functions, yet produce different conclusions. One team may determine that documentation supports billed services, while another later identifies concerning patterns such as cloned records or systematic overbilling. Both conclusions can be technically correct within their respective scopes. But together, they reveal a deeper issue: The organization is operating with competing versions of reality.
This is not simply a communication problem. It is a structural misalignment. Corrective action plans (CAPs) are intended to address identified issues and prevent recurrence. However, in many cases, CAPs are embedded in settlement agreements, minimally defined, and rarely monitored over time. Once funds are recovered, follow-up often gives way to new case demands. Providers may reappear months later, sometimes using different codes, but engaging in similar behavior. In this context, corrective action becomes less about sustained change and more about case closure.
Another driver of misalignment is incentive structure. Payment integrity teams are often measured on payment accuracy and cost containment, while SIU teams are measured on investigations and referrals. Each function may perform well against its own metrics, but those metrics do not always reinforce shared outcomes. Without aligned incentives, collaboration becomes situational rather than systemic. Organizations that demonstrate stronger alignment often establish shared, enterprise-level goals, such as medical cost reduction, that require cross-functional contribution. When multiple teams are accountable to a common outcome, coordination becomes necessary rather than optional. Volume also plays a role. High case loads, often hundreds per year, create pressure to resolve quickly, recover funds, and move forward. Under these conditions, long-term monitoring and follow-through become difficult to sustain. As a result, organizations may repeatedly address symptoms without resolving underlying causes.
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A less visible but equally important factor is internal system design. Improper payments are not always driven by intentional fraud. They often result from incomplete policies, outdated coding frameworks, or configuration gaps that allow claims to pass incorrectly. In these cases, investigative functions are left to correct issues that could have been prevented upstream. This points to a broader reality: Fraud detection is often compensating for design failure. The dominant question in many organizations is how to detect fraud faster. A more effective question may be: What conditions allowed misalignment to persist long enough to become behavior?
Shifting the focus from detection to alignment changes how organizations approach integrity.
- Fraud is visible. Misalignment is not.
- Fraud is investigated. Misalignment is often normalized.
- Fraud is treated as an event. Misalignment is a condition.
- Fraud is not the first failure. Misalignment is.
Until organizations address the structural, behavioral, and incentive-based conditions that allow misalignment to take hold, integrity functions will remain reactive, identifying issues only after they have materialized. The future of program integrity will not be defined by stronger investigations alone, but by better system design, aligned incentives, and sustained accountability.
Tiffiny Black is an organizational governance and change strategist, scholar-practitioner, and author whose work examines how governance, organizational systems, policy, technology, and human behavior shape implementation and sustainable change. She holds a Doctor of Management with a specialization in organizational development and change.
Across more than eighteen years in health care, government, regulatory oversight, compliance, and organizational improvement, she has focused on the gap between institutional intent and what systems and people can sustain in practice. Her work spans organizational readiness, psychological transition, governance and accountability, health care systems, artificial intelligence and data governance, privacy and compliance, and the human consequences of organizational and technological change. She is the developer of Human Systems Readiness™, an emerging framework examining whether organizations and their people are structurally and psychologically prepared to absorb change.
Black is the author of Leader’s Edition: The Psychology of Change, Safety, Resistance, and Real Accountability and The Change They Didn’t See Coming: Why Psychological Transition (and Safety) Matter More Than Strategy, both published by Bold Moves Press. Her doctoral research at Colorado Technical University examined the psychological transitioning that leads to change resistance in law enforcement. Her writing on KevinMD addresses institutional trust and scientific dissent, clinician burnout and health care governance, psychological safety, payment integrity and fraud detection, and the difference between implementation and readiness. She shares updates on LinkedIn.
