Rhode Island Medicaid Providers: Executive Office of Health and Human Services Audit Responses

By Patrick N. Sampson and Leslie D. Parker on July 7, 2026

Healthcare providers enrolled in Rhode Island Medicaid are increasingly encountering audits from the Rhode Island Executive Office of Health & Human Services (“EOHHS”). Those audits frequently include allegations of fraudulent and/or incorrect billing and demands to implement Corrective Action Plans (“CAPs”). A provider’s response in these scenarios can shape the outcome.

Every matter is fact-specific, but providers should consider the following items upon receiving an audit notice and further correspondence from EOHHS:

1. Immediately Review the Notice and Preserve the Deadlines

EOHHS correspondence often imposes short deadlines to respond to audit findings, produce records, and submit any written explanation. Failing to comply with a deadline can result in a number of various remedies, including, for example, overpayment determinations, recoupments payment suspension, sanctions, or termination from the Medicaid program. Upon receipt of an audit notice, providers should immediately calendar all deadlines and begin internally coordinating their response.

2. Preserve Records and Conduct an Internal Assessment

Before responding, providers should identify the specific services, claims, and time periods under review. An internal assessment should include:

• Securing all relevant medical records and billing documentation;
• Preserving electronic health records and billing data;
• Identifying employees involved in documentation and claim submission;
• Reviewing applicable Medicaid coverage and billing requirements; and
• Determining whether similar issues may exist beyond the claims EOHHS has identified.

An organized internal review allows providers to understand the scope of the allegations before making any statements and providing any documentation to the agency. Providers should then provide all of the responsive documents to EOHHS.

3. Evaluate a Corrective Action Plan Closely

Many providers assume that accepting a proposed CAP is simply the cooperative path forward. But a CAP may contain significant consequences, such as factual admissions, required operational changes, and ongoing reporting obligations.

As a result, before executing any CAP, providers should evaluate whether the alleged deficiencies are factually accurate and whether the proposed corrective measures are operationally feasible. Providers should also consider whether the implementation of the proposed CAP provisions would create additional compliance obligations. Based on that review, the Provider should consider and discuss with EOHHS if alternative CAP provisions exist or changes are needed.

4. Develop a Coordinated Legal and Compliance Strategy

EOHHS audits can overlap with other regulatory and legal exposures, including, for example, potential referral of matters to the Rhode Island Office of the Attorney General or managed care organization obligations.

For that reason, providers should coordinate internally before responding to the agency. In addition, providers should consider speaking with legal counsel prior to discussing a CAP and/or engaging in discussions with EOHHS regarding alleged payment issues. A coordinated strategy keeps communications consistent, preserves records, and ensures any necessary corrective measures are implemented without unnecessarily expanding potential liability.

Final Thoughts

Audit notices and discussions with EOHHS should be treated seriously from the outset. Providers who act carefully, promptly, and diligently are generally better positioned to resolve investigations while minimizing operational disruption and preserving their continued participation in the Rhode Island Medicaid program.

We work with Rhode Island Medicaid providers through every stage of this process to protect both the provider’s immediate position and its long-term participation in the program. Please feel free to contact the AP&S healthcare team for further guidance.