A Program Integrity Briefing

Every claim has a chart.
We read both.

EtoAI Integrity is the AI that cross-references every billed code against the clinical documentation that's supposed to support it — surfacing the 70–80% of fraud that claims-only screens never see, with citations a courtroom can verify.

HIPAA · Signed BAAVertex AICitation-groundedCourt-defensible
Case file · redacted exemplar
CF-04412 / NJ-MED
Claim ID2026-XX-098712
Provider NPI1▒▒▒▒▒▒▒▒1
Date of ServiceMay 14, 2026
PayerState Medicaid · NJ
Billed
CPT 99215
Established patient · Level 5 visit
$209
Documentation actually supports
CPT 99213
Level 3 visit · low-complexity MDM
$93
Variance verdictConfidence 0%
−$116Per-claim recovery,
billed level too high
Citation chain
CMS IOM Pub. 100-04Ch. 12 § 30.6.1 — E/M code selection
AMA CPT 2026§ 99215 — high-complexity MDM, or 40–54 min total time
Document hashsha256:7a2c…f019 · 4 pp · time-stamped
RBAC-signed · immutable revision logGenerated in 6.4s · Vertex AI
The problem

Investigators see the bill.
They rarely see the chart.

MFCUs, HHS-OIG, and qui tam counsel run on claims-only signals — billing patterns, frequency outliers, peer-group deviation. The unstructured chart notes that determine whether a code is actually supported sit unreviewable at scale. The variance hides there.

$80B+

Lost to fraud, waste, and abuse across Medicare and Medicaid every year.

GAO-23-105426
$5–10B

What state MFCUs and federal partners actually recover annually.

HHS-OIG FY24
70–80%

Of fraud spend that claims-only screens never surface — hidden in the chart.

OIG Workplan 2025
The insight

The fraud isn't in the claim. It's in the gap between the claim and the documentation that's supposed to support it. Read the chart, and 70–80% of the loss becomes visible — with citations.

What it does

Five capabilities.
One engine that thinks in citations.

Built on Vertex AI under signed BAA. The investigator surface is plain English. The outputs cite the regulation.

01

Variance Engine

Reads every chart note line-by-line, cross-references it against the billed code, and flags the gap. The investigator gets a recovery estimate and the documentation excerpt that proves it.

≥90%
concordance with certified coders
02

Provider Risk Score

A daily 0–100 score per provider that fuses claims signal, documentation quality, and network patterns. Surfaces problem providers before a claims-only screen would trigger.

Daily
refresh, not monthly
03

Program Integrity Copilot

Ask in plain English: "Show me providers who billed therapy while the patient was inpatient." Get cross-referenced results in seconds — every row cited to source.

<2s
median query response
04

Audit Packet Generator

One click drafts the Notice of Intent to Audit, builds the evidence bundle, attaches regulatory citations, and computes the recovery estimate. Days of work collapse to seconds.

~8s
end-to-end packet drafting
05

Citation Grounding

Every assertion traces to claim ID, document SHA-256 hash, and a specific CMS Internet-Only Manual citation. Court-defensible by design — no black-box outputs.

100%
assertions traceable to source
Who it's for

Built for the people who
actually recover the money.

Federal

HHS-OIG

Federal Office of Inspector General

Workplan-aligned variance detection across Medicare A/B/C/D. Findings ship as DOJ-referable evidence packets with citation chains intact.

State

State Medicaid Fraud Control Units

50-state MFCU network

Closes the staff capacity gap — surfaces 10× more leads per investigator-hour. Behavioral health, PCA fraud, DME patterns, eligibility integrity.

Plaintiff

Qui Tam Counsel

False Claims Act relator firms

A force-multiplier for relator counsel preparing FCA filings under seal. Citation-defensible evidence with chain-of-custody hashes attached.

Commercial

Commercial Payors

Special Investigations Units

Enterprise SIU deployment for national and regional plans. Pre-payment variance signals on high-risk providers. Network-quality benchmarking.

Why it holds up

Court-defensible
by design.

Every assertion traces to the underlying claim, the document hash that supports it, and the specific regulatory citation that governs it. Three examples — exactly what shows up in an investigator's packet.

01

Documentation supports CPT 99213, not the billed CPT 99215.

ClaimID 2026-XX-098712 · DOS May 14, 2026
DocumentChart note · 4 pages · sha256:7a2c…f019
StandardCMS IOM Pub. 100-04, Ch. 12 § 30.6.1 — E/M code selection
AuthorityAMA CPT 2026 § 99215 — 3 of 3 components OR ≥40 minutes
02

Provider billed 142% of peer-group median for CPT 90837 over 90 days.

BenchmarkPeer group: same specialty, geography, panel size (n=412)
MethodRobust z-score, MAD-scaled, period-normalized
StandardCMS IOM Pub. 100-08, Ch. 3 § 3.7.1 — statistical sampling
OutputZ = 3.42, p < 0.001, 95% CI excludes peer median
03

Service date overlaps with documented inpatient admission.

Claim ACPT 90837 outpatient psychotherapy · DOS Apr 22, 2026
Claim BCPT 99221 inpatient admission · DOS Apr 22, 2026
StandardCMS IOM Pub. 100-04, Ch. 12 § 30.4.4 — concurrent services
ResultMutual-exclusion violation; one claim must be denied
The method

Inside a finding,
from raw data to a signed packet.

A finding is only as defensible as the chain behind it. Here's exactly how one moves from a claims feed to an investigator's desk — every step, every citation, every signature accounted for.

01

Receive

Claims and clinical documentation arrive under signed BAA. Encrypted in transit and at rest. Private network — no public ingress, no shared infrastructure.

MNDA + BAA executed in 24 hours
02

Read

The AI parses every chart note line-by-line — not just the structured fields, but the unstructured prose that determines whether a billed code is supported.

Outputs benchmarked vs. AHIMA-certified coders
03

Cross-reference

Every billed code is matched against the documentation that’s supposed to support it. Variance is scored, peer-group benchmarked, and ranked by recovery potential.

Daily refresh per provider in the panel
04

Cite

Each assertion is tied to (a) the source claim ID, (b) a SHA-256 document hash, and (c) the specific CMS Internet-Only Manual citation that governs it. Court-defensible by design.

100% of assertions traceable to source
05

Deliver

A drafted Notice of Intent to Audit lands on the investigator’s desk with the evidence bundle, citation chain, and recovery estimate attached. They review, sign, and send.

Days of manual work, collapsed to seconds

Send us a redacted extract.
We'll find what's hiding.

Standard MNDA. 50MB sample. 48-hour analysis. A 30-minute walkthrough where every finding cites the regulation. No deck, no upsell.

integrity@etoai.net