ARCLIGHT

Policy White Paper / May 2026 – Updated Edition

Upstream Denials, Downstream Costs

Hidden Systemic Costs and Measurement Failure in Medicare Unified Program Integrity Contractor (UPIC) Determinations

Overview

Research and evidence for a more accountable system.

UPICs are paid to find fraud, waste, and abuse. But who measures whether their determinations are right? This updated Arclight Insights white paper estimates the hidden systemic cost of reversed, plausibly reversible, and unappealed UPIC determinations at $49 million to $250 million annually, while documenting a deeper measurement failure: CMS does not publish contractor-level appeal outcomes. The paper argues that Medicare program integrity should measure accuracy, not just activity.

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