# HPI-CT — Scope, Intended Use & Limitations

*Read this before using the toolkit for any decision. Personal-capacity, public-source work. Version-dated 2026-07-16.*

## What this is

HPI-CT is an **educational self-assessment aid** for healthcare fraud, waste, and abuse (FWA) prevention. It helps an organization structure a self-review of its FWA controls against widely used internal-control and compliance frameworks, and see where its own maturity may be strong or thin. It is a **thinking tool and a gap-analysis scaffold** — a structured way to ask better questions and organize evidence.

## What this is NOT

- **Not legal advice.** Nothing here is legal, regulatory, actuarial, or professional advice. Regulatory citations are provided for orientation and must be read in their current, official form (eCFR) and applied with qualified counsel.
- **Not an official standard or government product.** It is not issued, endorsed, reviewed, or approved by CMS, HHS-OIG, COSO, the ACFE, GAO, or any regulator or standard-setter. References to those frameworks are for mapping and education only.
- **Not a certification, audit, or guarantee of compliance.** A high maturity score does **not** establish that an organization is compliant, nor does a low score establish a violation. The tool cannot detect fraud and does not opine on any specific transaction, claim, or party.
- **Not a replacement for an organization's compliance program.** It is meant to **complement** an OIG-based compliance program, the COSO/ACFE Fraud Risk Management Guide, and any GRC tooling — not substitute for them.

## Methodology limitations (read these honestly)

- **Scores reflect expert-judgment design choices, not empirically validated measurement.** The hidden scoring keys, the 0–3 maturity scale, the component weights (CE 20 / RA 20 / CA 25 / I&C 15 / Mon 20), the evidence-reliability ladder, and the provenance rules are reasoned design decisions grounded in the cited frameworks. They have **not** been validated through a pilot, and no inter-rater reliability or predictive-validity study has been conducted. There is, as yet, **no evidence that a given maturity score predicts actual FWA exposure or recovery outcomes.**
- **Self-assessment carries self-report bias.** Answers are self-reported; the evidence-reliability ladder and the provenance discriminator mitigate but do not remove this. The "verification status" and provenance fields record *how* verifiable a basis is; they do not independently verify it.
- **Targets and seeded values are illustrative defaults, not benchmarks.** Replace them with your own risk-based targets.
- **Framework mapping is editorial.** Which COSO/Green Book principle, FRMG principle, or OIG element a given question "best" satisfies is a judgment call open to reasonable disagreement. (Framework **numbering** and the **42 CFR section identities** have been verified against primary sources — see `03_Toolkit/Framework_Citation_Verification_FULL_2026-07-16.md`.)
- **Regulations change.** Citations are current as of the version date above; verify against eCFR before relying on any of them.

## Appropriate use

Use HPI-CT to organize an internal gap analysis, prioritize where to invest control effort, prepare for (not substitute for) an audit or an OIG-based program review, and structure conversations with compliance, internal audit, and leadership. Treat every output as a **prompt for professional judgment**, not a conclusion.

## Authorship, status & data

- **Authorship:** developed in a personal capacity from public sources. Not affiliated with, or representing, any employer, agency, or organization.
- **Status:** working DRAFT under active revision.
- **Data & privacy:** the interactive toolkit stores answers **only in your own browser** (localStorage); there is no account and no backend, and nothing is transmitted. Use Export/Import to keep or move a copy.

## No warranty / limitation of liability

Provided "as is," without warranty of any kind, express or implied. The author is not liable for any decision made or action taken in reliance on this material. You are responsible for validating any output against authoritative sources and qualified professional advice before acting.