Yes, the root problem is CMS effectively audits managed care organizations (MCO, or health insurance companies) far too rarely. And even when they do audit th

Yes, the root problem is CMS effectively audits managed care organizations (MCO, or health insurance companies) far too rarely. And even when they do audit them, they audit far too few and with insufficient depth such that people working inside the MCO have no justification to spend more resources on ensuring the job is done properly. If CMS was constantly auditing random cases, then the MCOs would have to tighten up operations. As it is, any MCO that does will lose out to any MCO that plays it fast and loose, since MCO profit margins are low single digit percentages. Although, I am sure one can kick up the problem to legislators not allocating enough funding to CMS to constantly audit MCOs, just like the IRS does not have enough funding to audit sufficient taxpayers.