It Always Starts Small: Lessons from the Front Lines of Healthcare Audits

4/28/2025 Justin Brochetti , CEO

In healthcare, most of the time, trouble doesn't announce itself with sirens and red flags. It starts quietly.  A free dinner here.  A paid talk there.  An event that feels more like networking than education. Below is a practical breakdown of what this means and what to do next.

When you’ve been through enough audit investigations… and I've been through more than a few… you learn something important: small lapses, left unchecked, become large liabilities .

That’s why I’m telling this story today.

The Office of Inspector General (OIG) recently issued a Special Fraud Alert warning about pharmaceutical and medical device company speaker programs. Programs that once had good educational intentions have, in many cases, turned into lavish gatherings where compliance risks outpace clinical benefits. The OIG is concerned, and based on the history of these alerts, real enforcement isn't far behind.

I’m not sharing this to be dramatic. I’m sharing it because I’ve seen firsthand what happens when organizations ignore these early warning signs.  Audits come.  Investigations expand.  Small oversights are reframed as systemic misconduct. And it’s not just the fines or the repayments that hurt … it’s the disruption to everything you’ve worked hard to build.

When speaker programs start being about perks over purpose, they expose something deeper: a gap between operational intent and operational reality. And in healthcare, that gap can cost you everything.

After witnessing firsthand how small, unchecked risks spiral into full-blown investigations, I knew healthcare organizations needed a different kind of solution. Not just faster billing. Not just automation for convenience. But automation designed to stand up when everything is on the line.

At Intelligence Factory, we don't just automate billing and claims workflows. We build systems with audit defense in their DNA .

That’s why we created FairPath .

FairPath isn't just about moving claims faster. It’s about building a billing process that holds up when regulators come calling. Every eligibility verification, every claims submission, every workflow step is designed to be clean, compliant, and resilient … because when scrutiny hits, you need more than speed. You need strength.

Speaker programs are just one more reminder that regulators aren't just watching what you bill … they’re watching how you operate. The safest organizations won’t be the ones who “meant well.” They’ll be the ones who can show, with confidence and clarity, that their systems were built to do it right from the start.

And when the pressure is on — when the subpoenas come, when the investigators start pulling files … you won’t be relying on good intentions. You’ll be relying on the systems you built when you still had the choice.

If you're serious about making sure your billing and compliance operations are ready for whatever comes next, let's have that conversation now. Not after a warning letter. Not after an audit notice. Now … while you still have every advantage on your side.

Related resources: The OIG's 2026 RPM Audit is Scheduled: Are You Ready?, OIG RPM Audit Red Flags: What Auditors Look for in Billing Data (and How to Prevent It).

Standard Operating Procedures

FairPath is built on operational work, not theory. We publish the playbooks and checklists we use to keep programs compliant and profitable. Use them whether you run FairPath or not.

Browse the Expert Library →

RPM Manual

The practical 2026 guide to device rules, day thresholds, management time, and audit defensibility for Remote Patient Monitoring.

Read the RPM Guide →

RTM Guide

How to run Remote Therapeutic Monitoring for MSK, respiratory, and CBT workflows with the correct 9897x and 9898x rules.

Read the RTM Guide →

CCM Guide

Calendar-month operations for CCM: consent, initiating visit, care plan requirements, time counting, and concurrency rules.

Read the CCM Guide →

APCM Playbook

The operator blueprint for Advanced Primary Care Management: eligibility, G0556–G0558 tiers, and monthly execution.

Read the APCM Playbook →