From compliance monitoring to program integrity: Oversight designed for modern government

Bolster compliance monitoring to best protect taxpayer funds from fraud, waste, and abuse, strengthen program execution, and support successful outcomes.

Government programs are facing heightened scrutiny over how effectively they operate and safeguard public resources. Agencies are increasingly expected not only to deliver high‑quality services, but also to demonstrate, clearly and defensibly, that their day‑to‑day operations consistently prevent, detect, and respond to integrity risks, like fraud, waste, and abuse. 

As a firm with decades of experience designing and implementing compliance monitoring programs, we believe the fundamental purpose of compliance monitoring has always been program integrity: protecting taxpayer funds from fraud, waste, and abuse, strengthening program execution, and supporting successful outcomes for program participants.

We define program integrity simply: The program works the way it is supposed to, at scale, under scrutiny. Eligibility decisions and benefit amounts follow policy; improper activity is prevented or caught early; and risks are addressed quickly, without interrupting services for people who qualify.

Why ‘program integrity’ is suddenly everywhere 

Government leaders are operating in a new normal. Oversight scrutiny is higher, expectations for speed and transparency are rising, and risk environments are changing faster than traditional models can keep up. As a result, leaders are elevating program integrity from a compliance concern to a leadership priority.  

This shift is amplified nationally by an intensified focus on eliminating fraud, waste, and abuse. That emphasis changes the standard of proof. It is no longer enough to say controls exist; agencies must be able to show, clearly and defensibly, that controls are working, and that they are being adapted as risks evolve.  

Failures surface most visibly in large benefit programs, where delivery depends on many partners and disconnected systems. This fragmentation can create blind spots, like inconsistent execution, limited traceability, and delayed detection – all of which make oversight harder precisely when scale and urgency are highest. Childcare is one example that receives a lot of attention, but the same dynamics appear across many state‑administered programs. 

Against that backdrop, agency leaders are moving beyond traditional compliance frameworks toward approaches that reflect real operational conditions. The result is stronger program integrity, where agencies can manage risk, meet obligations, and deliver services in a way that earns public confidence. 

Integrity, applied 

Program integrity is achieved when rules are built into everyday work. This includes how staff are trained, how systems operate, how data is used, and how programs are monitored over time. Relevant practices should be able to stand up to oversight and adapt as risks and conditions change. 

To make program integrity practical, we use a simple operating model, the Integrity Loop, that turns the idea of integrity into a repeatable, day‑to‑day practice. It is intentionally designed to strengthen oversight without adding unnecessary administrative burden. 

The Integrity Loop

1) Commit 

Integrity starts with clear ownership: defined roles, expectations, and leadership commitment to prevention, detection, and response. 

2) Assess 

Programs need an honest risk profile that identifies where errors or abuse are most likely and uses data to verify that eligibility and payment decisions are correct. 

3) Design & Implement 

Integrity must be built into workflows: policies translated into operating procedures, staff trained to execute consistently, and monitoring embedded in routine operations. 

4) Execute 

Make integrity a daily practice. Proactively review transactions and decisions, monitor subrecipients, and validate data. 

5) Evaluate & Adapt 

The strongest integrity programs don’t consider the job done after controls have been implemented: They continuously measure whether the controls work and adapt as risks evolve.

The Future of Program Integrity

The Integrity Loop in Practice 

The Integrity Loop provides the structure, but integrity is sustained through execution. In practice, agencies achieve program integrity by repeatedly doing three things well: using data to see risk, monitoring compliance to correct course, and responding decisively when higher risk issues emerge. 

Our approach aligns to these three stages of the Integrity Loop. 

1. See risk early: Data and technology 

Strong program integrity starts with visibility. Programs cannot manage risk if they cannot see what is happening across eligibility decisions, payments, and service delivery. 

Detection must be embedded into day‑to‑day operations. Analytics and alerts should feed directly into workflows, giving staff timely signals to review and act, rather than producing reports that sit on bookshelves. The result is earlier detection, fewer manual errors, and issues addressed before funds are lost. 

How CohnReznick can help: By translating policy into data rules, integrating fragmented systems, and applying analytics, we enable programs to validate decisions, surface anomalies, and identify patterns that may indicate fraud, waste, or abuse. These insights are designed to be explainable and defensible, so they stand up to oversight scrutiny. 

2. Correct course: Compliance monitoring 

Data alone is not enough. Program integrity is reinforced when agencies consistently apply rules across people, processes, and partners. 

Compliance monitoring is the operational backbone of the Integrity Loop. When designed well, it provides early visibility into issues affecting eligibility, payment accuracy, documentation quality, and audit readiness, before those issues become findings or turn into a loss of funding. 

How CohnReznick can help: Our monitoring approach is risk-based and right-sized. Review intensity is aligned to program complexity, delivery models, and risk profiles, allowing agencies to focus oversight where it matters most. Findings  feed directly into policy clarification, procedure updates, training, and technical assistance, reducing repeat issues and improving consistency across stakeholders. 

3. Respond decisively: Construction Integrity Monitoring 

Some risks require a higher level of independence and investigative rigor. When credible allegations, tips, or high-risk patterns emerge, agencies need a response that is timely, defensible, and proportionate. 

How CohnReznick can help: Construction Integrity Monitoring provides independent, real-time oversight to prevent, detect, and respond to serious integrity risks on large capital projects. Our team, drawing on investigative, audit, and technical expertise, identify issues early, preserve facts, and support appropriate corrective or enforcement action, in a way that protects public funds and public trust. 

What strong program integrity delivers 

When built across people, processes, and data, program integrity enables decision-ready insight, stronger operational execution, faster issue resolution, greater accountability to the public, and improved program outcomes. 

For decades, CohnReznick has supported government agencies in maintaining the integrity of their programs. We believe the most effective approaches to program integrity preserve what matters most: mission focus, accountability to the public, and maximizing benefits to program participants. As compliance monitors, our role is to complement an agency’s program integrity efforts by expanding capacity, anticipating and identifying risks early, and delivering actionable, data-driven oversight that protects public funds and public trust. 

Whether your agency is modernizing compliance monitoring, confronting new risk pressures, or preparing for heightened oversight, we welcome a conversation about how to strengthen your program integrity efforts without adding unnecessary red tape.

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This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.