Texas HCS and TxHmL waiver providers under HHSC program-integrity scrutiny.
The engagement
Authorizations that match the documentation; survey-ready records; recoupment exposure quantified; and a response to retrospective reviews built to the state’s own rule.
Week 1 — intake: authorization-to-documentation reconciliation, monitoring posture, and exposure. Weeks 2–4 — person-centered-plan and service-authorization review. Ongoing — pre-bill reconciliation and retrospective-review response.
Regulatory context
Texas tightened the screws on waiver billing. HHSC issued Revision 24.1 of the HCS and TxHmL billing requirements effective January 2024, and the OIG codified retrospective-review recoupment in 1 TAC §371.1723 (2024); recoupment authority for HCS/TxHmL sits at 26 TAC §263.601.
Nationally, the Medicaid improper-payment rate rose to 6.12% ($37.39 billion) in FY2025, with roughly 77% from insufficient documentation — the exact gap a retrospective review exploits.
From revenue cycle through audit defense — each shaped to your operation.
Each service shaped to the specific pressure observed.
Three reasons HCS and TxHmL providers choose us:
HHSC arena understood at the unit level. Service definitions, unit accuracy, IPC alignment — where reviews actually land.
Billing review defense as case file, not memo. Chart-by-chart, unit-by-unit, indexed and citation-grade.
Operational support across both day-to-day and review. We work alongside the team through both modes.
Is the “$80M recouped from HCS providers” figure real?
We could not verify that specific number in any CMS, HHSC, or Texas OIG source, so we don’t use it. What is documented: Texas OIG recovered $442.3M+ in FY2024 and codified retrospective recoupment in 1 TAC §371.1723.
What triggers a recoupment?
A mismatch among the service authorization, the person-centered plan, and the documentation of services delivered. Retrospective payment review tests exactly that.
Can you help before a review?
Yes — we reconcile authorizations to documentation pre-bill so the record holds when a retrospective review comes.
Are you a law firm?
No — we’re Texas-licensed investigators and expert consultants who read HHSC’s rules the way HHSC does. We work alongside your counsel through retrospective review and appeal, and can testify as experts. Nothing here is legal advice.
Tell us what you are up against. Scoping memo in week one, before any meaningful commitment.