Programs & controls · 14 high-risk Medicaid service categories

High-risk is a control label. It is not a verdict.

Minnesota has placed 14 Medicaid service categories under heightened program-integrity scrutiny. Some have dedicated criminal cases. Some appear only inside mixed-service allegations. Others have no dedicated fraud prosecution located in the current public record. This page keeps those categories separate.

Updated Aug. 29, 2026DHS / DOJ / Minnesota AGCase status separated from program risk

01 · The service map

Fourteen programs. Different evidence.

A service can be high-risk because of weak controls, unusual billing, rapid growth, known fraud patterns or other vulnerabilities. That designation should never be read as a claim that every provider or recipient is fraudulent.

Adult Companion Services

Mixed case

Companion care appears in mixed HCBS allegations, including Guardian Home Health and a 2026 state takedown. No service-only loss figure is isolated.

Adult Day Services

No dedicated case located

No dedicated Minnesota Medicaid-billing prosecution was located in the current research pass.

Adult Rehabilitative Mental Health Services (ARMHS)

Dedicated cases

Current state charges include the Reva Health matter and a separate mixed-service case. Charged amounts remain allegations unless adjudicated.

Assertive Community Treatment (ACT)

No dedicated case located

DHS is reviewing payment policy and rate methodology with a program-integrity lens; no ACT-specific fraud prosecution was located.

Community First Services and Supports (CFSS)

No dedicated case located

CFSS is still replacing PCA. Older PCA cases should not be relabeled as CFSS fraud.

Early Intensive Developmental and Behavioral Intervention (EIDBI)

Multiple cases

Federal autism-service prosecutions include Smart Therapy and Star Autism matters. Published billed, paid and provider-specific figures overlap and cannot be added into one clean loss total.

Housing Stabilization Services (HSS)

Program ended

Multiple federal case waves followed rapid growth and weak controls. HSS ended October 31, 2025; several defendants have since pleaded guilty.

Individualized Home Supports (IHS)

Dedicated + mixed

Healey Homes is a dedicated federal case; Guardian Home Health includes IHS inside a broader HCBS allegation.

Integrated Community Supports (ICS)

Dedicated case

The Ultimate Home Health federal case alleges high-hour ICS billing for services not provided. Program spending is not itself a fraud total.

Intensive Residential Treatment Services (IRTS)

No dedicated case located

No IRTS-specific fraud prosecution was located. DHS is reviewing IRTS payment policy and rate methodology.

Night Supervision Services

Mixed case

Overnight billing appears in the Guardian Home Health complaint, but no standalone Night Supervision scheme total is stated.

Nonemergency Medical Transportation (NEMT)

Dedicated case

The Driving Miss Daisy case alleges more than $1.4 million in false NEMT billing. DHS also began new NEMT claims-compliance reviews in August 2026.

Recovery Peer Support

No dedicated case located

No service-specific criminal fraud prosecution was located. Current law contains billing restrictions and monetary-recovery tools.

Recuperative Care

No dedicated case located

A newer Medicaid service with enhanced screening and universal prior authorization beginning August 1, 2026; no dedicated fraud prosecution was located.

“No dedicated case located” does not mean “no fraud exists.” It means the current public research corpus does not contain a service-specific prosecution that clears the sourcing bar.

Primary overview: Minnesota DHS Program Integrity

02 · What changed

The control response is now statewide.

Prosecution is only one layer. Minnesota and CMS are also changing enrollment, revalidation, payment review and service authorization. Those actions can prevent losses, but they can also slow legitimate care.

Revalidation

3,070 providers revalidated

DHS reported 3,070 high-risk providers revalidated as of August 12, with 1,627 appealing disenrollment, 128 choosing termination instead of revalidation, and 660 terminated after their appeal windows closed.

DHS snapshot →

Enrollment

Moratoria remain in force

Twelve high-risk service categories are under a CMS-approved new-provider enrollment moratorium through January 27, 2027. EIDBI has a separate moratorium; HSS is closed.

DHS Program Integrity →

Pre-payment

Claims can be stopped before money leaves

Enhanced fee-for-service pre-payment review is now part of the corrective-action framework. A flagged claim is not the same as a proven fraudulent claim.

CMS-approved integrity plan →

NEMT

New claims reviews began Aug. 24

DHS announced provider-claim compliance reviews for nonemergency medical transportation. Selection for review is not an accusation.

DHS Program Integrity →

EIDBI

Controls are affecting authorization speed

DHS reported longer-than-required EIDBI authorization timelines in August because review volume increased. Stronger control can create a legitimate access problem if review capacity does not keep pace.

DHS Program Integrity →

Recuperative care

Prior authorization became universal

All recuperative-care services require prior authorization beginning August 1, 2026. A denial or request for more documentation should not be counted as fraud.

DHS Program Integrity →

Control success needs two measures

A fraud-control program is not successful merely because it blocks more claims. The public should eventually be able to see both integrity outcomes—recoveries, verified improper billing, prosecutions—and access outcomes such as authorization delays, provider exits and service availability.

03 · Scale without inflation

Large programs produce large numbers. Context still matters.

DHS says Minnesota Medicaid paid about $20.9 billion to roughly 40,000 provider organizations in 2024 and served about 1.2 million people in an average month. Those figures describe program scale, not a fraud denominator.

2024

$20.9B paid to providers

Statewide Medicaid program spending. It should not be multiplied by a suspicion rate or used as a proxy for stolen money.

Providers

~40,000 organizations

The statewide provider universe is much larger than the providers subject to criminal cases or sanctions.

People

~1.2M monthly recipients

Program-integrity reforms affect a public benefit used by a large share of Minnesotans; access consequences therefore belong in the accountability story.