1. The Core Distinction
The existing 1 bps FWEA Retroactive Payment Audit asks: "Do these payment patterns show fraud?" The Identity Integrity Audit asks a different question entirely: was the payee's identity valid on the exact date this payment was made?
These are completely different questions requiring different data sources, different logic, and different output formats. A provider can have a clean payment instruction, a correct bank account, a valid NPI, and pass all 111 FWEA checks - and still be dead, have a revoked license, be operating from a vacant lot, or have been on the OIG exclusion list for two years. The Identity Integrity Audit closes that gap.
A provider who died in November 2022 is not "currently deceased" from a payment database perspective if their NPI is still active and their bank account is still open. JIL's temporal reconstruction anchors every identity check to the payment date - reconstructing the world as it was when money moved.
2. Temporal Identity Profile (TIP)
For each payee in the audit dataset, JIL builds a Temporal Identity Profile - a structured event timeline mapping key identity state changes against the payment date series. The TIP is the evidentiary artifact that supports investigative referral.
EVENT: Program enrollment confirmed Date: Provider enrolled in Medicare Payments during this period: ELIGIBLE EVENT: Status change (suspension, address change, enrollment suspension) Date: License suspended by state board Payments between suspension and resolution: REVIEW EVENT: Disqualifying event (death, OIG exclusion, license revocation, SOS dissolution) Date: Person confirmed deceased (DMF date) Payments after this date: FRAUDULENT OVERPAYMENT Total: Sum of all post-event payments Referral package: Generated automatically EVENT: Continued payments after disqualifying event Count: N payments totaling $X Range: First payment date through last payment date Individual timestamps: Yes - each payment individually listed
3. Temporal Data Availability
| Data Source | Historical Depth | Event Timestamp | Precision |
|---|---|---|---|
| SSA Death Master File | 1936 to present | Confirmed date of death | Day-level |
| State Vital Records | 1950+ (typical) | Date of death | Day-level |
| OIG LEIE | Full archive | Exclusion effective date | Day-level |
| CMS NPPES | Deactivation date recorded | Yes (not always revocation date) | Month-level in some cases |
| State Medical Boards | 10+ years (most) | Action, suspension, revocation date | Day-level for most states |
| State SOS | Full corporate history | Dissolution, revocation, reinstatement | Day-level for most states |
| SAM.gov / DUNS | Full archive | Debarment effective date | Day-level |
| IRS EIN | Assignment date available | Partial | Year-level in some cases |
| USPS NCOA | Up to 48 months | Move-effective date | Month-level |
Temporal gap handling. Where an exact event date is not available (e.g. a state board records only the month), JIL uses a conservative first-of-month assumption. Findings flagged as post-event represent the minimum possible set. Every finding output includes a
temporal_confidence field: "day", "month", "year", or "estimated".4. The 28-Check Dimension Matrix
| # | Check | Subject | Temporal Anchor | FWEA | Hard Stop |
|---|---|---|---|---|---|
| 01 | Death record - SSA DMF | Person | Death date vs. payment dates | F | YES |
| 02 | State vital records death | Person | State death registration vs. payment dates | F | YES |
| 03 | OIG LEIE exclusion date | Person/Entity | Exclusion effective date vs. payment dates | F, A | YES |
| 04 | SAM.gov debarment date | Entity | Debarment date vs. payment dates | F, A | YES |
| 05 | SOS dissolution date | Entity | Dissolution date vs. payment dates | F, A | YES |
| 06 | SOS good standing at payment date | Entity | Good standing status on each payment date | F, W | REVIEW |
| 07 | Business license expiration | Entity | Expiration date vs. payment dates | F, A | YES |
| 08 | Business license revocation | Entity | Revocation date vs. payment dates | F, A | YES |
| 09 | DUNS/UEI entity existence | Entity | Registration vs. first payment date | F | REVIEW |
| 10 | EIN/IRS TIN match | Entity | TIN confirmed; mismatch flagged | F, A | REVIEW |
| 11 | NPI active at payment date | Provider | Deactivation date vs. payment dates | F | YES |
| 12 | PECOS enrollment at payment date | Provider | Enrollment active on each payment date | F, W | YES |
| 13 | Professional license at payment date | Person | Revocation/suspension vs. payment dates | F, A | YES |
| 14 | DEA registration at payment date | Person | DEA expiration/revocation vs. payment dates | F, A | YES |
| 15 | Program enrollment at payment date | Person/Entity | Termination date vs. payment dates | F, W | YES |
| 16 | Address classification at payment date | Address | Address type during payment period | F, A | REVIEW |
| 17 | Address occupancy at payment date | Address | Was address occupied? | F | REVIEW |
| 18 | Address type vs. payment type | Address | Classification vs. payment rules | F, A | REVIEW |
| 19 | Address tenure - payee at address | Person/Entity | USPS NCOA tenure vs. payment dates | F | REVIEW |
| 20 | Address change during payment period | Person | Move-effective date vs. payment dates | F, A | REVIEW |
| 21 | High-density multi-registrant address | Address | Entity count vs. property type | F, A | REVIEW |
| 22 | Registered agent address as business | Address/Entity | Match against registered agent firms | F | REVIEW |
| 23 | UBO deceased check | Person (UBO) | UBO death date vs. entity payment dates | F, A | YES |
| 24 | UBO OIG exclusion check | Person (UBO) | UBO exclusion date vs. entity payment dates | F, A | YES |
| 25 | Entity registered before first payment | Entity | Incorporation date vs. first payment | F | REVIEW |
| 26 | Billing volume vs. physical capacity | Entity | Billed volume vs. licensed capacity | W, A | REVIEW |
| 27 | Service area geographic plausibility | Entity/Address | Provider service area vs. patient address | F, W | REVIEW |
| 28 | Citizenship/residency at payment date | Person | DHS SAVE status at benefit payment | F, A | REVIEW |
F = Fraud, W = Waste, A = Abuse
5. Address Classification Types
| Classification | Risk Level | Description | Hard Flag For |
|---|---|---|---|
| Commercial Office | Low | Dedicated commercial office space | N/A |
| Medical Facility | Low | Purpose-built or licensed medical facility | N/A |
| Licensed Care Facility | Low | State-licensed hospice, nursing home, daycare | N/A |
| Residential / Home-Based | Medium | Private residential address | Institutional billing (hospice, DME) |
| Shared / Co-Working | Medium | Multiple businesses at same address | N/A |
| Registered Agent Only | Medium | Address belongs to registered agent firm | All provider billing |
| P.O. Box / Mail Drop | High | Post office box or commercial mail drop | All provider billing |
| Vacant / Unoccupied | Critical | Confirmed vacant during payment period | All billing |
| Address Mismatch | Critical | Instruction address does not match enrolled | All payment types |
| High-Density Multi-Registrant | High | Unusual number of entities at same address | All provider billing |
6. Finding Record Structure
{
"finding_id": "FND-2026-0041872",
"finding_type": "POST_DEATH_PAYMENT",
"severity": "CRITICAL",
"fwea_pillar": "FRAUD",
"check_ids": ["ID-008"],
"payee_type": "individual",
"payee_name": "[PAYEE NAME]",
"payee_npi": "1234567890",
"payee_address": "123 Example St, Houston TX 77002",
"address_classification": "residential",
"event_type": "DEATH_CONFIRMED",
"event_date": "2022-11-14",
"event_source": "SSA_DMF",
"temporal_confidence": "day",
"payments_before_event": {
"count": 847,
"total_usd": "$2,341,880.00",
"verdict": "ELIGIBLE"
},
"payments_after_event": {
"count": 23,
"total_usd": "$127,440.00",
"first_payment": "2022-11-28",
"last_payment": "2023-08-12",
"verdict": "FRAUDULENT_OVERPAYMENT"
},
"evidence": {
"dmf_record_hash": "sha256:a3f2c8...",
"source_document_ref": "SSA-DMF-2022-TX-...",
"verdict_receipt_hashes": ["sha256:..."],
"dilithium_signature": "post-quantum signed",
"reproducible": true
},
"referral_recommended": true,
"referral_agencies": ["HHS_OIG", "CMS_ZPIC", "DOJ_CIVIL"],
"statute_references": [
"42 USC 1320a-7b (False Claims)",
"18 USC 1347 (Health Care Fraud)"
],
"receipt_hash": "sha256:f6a7b8..."
}
7. Finding Type Reference
| Finding Type | Description | Severity | Referral Agency |
|---|---|---|---|
| POST_DEATH_PAYMENT | Payment after confirmed death | CRITICAL | HHS OIG, SSA OIG, CMS ZPIC, DOJ |
| POST_EXCLUSION_PAYMENT | Payment after OIG exclusion effective date | CRITICAL | HHS OIG, DOJ Civil, CMS |
| POST_DEBARMENT_PAYMENT | Payment after SAM.gov debarment | CRITICAL | GSA IG, DOJ, contracting agency IG |
| POST_DISSOLUTION_PAYMENT | Payment to legally dissolved entity | CRITICAL | State AG, HHS OIG, CMS, FBI |
| POST_LICENSE_REVOCATION | Payment after license revocation | CRITICAL | HHS OIG, state licensing board, state AG |
| POST_LICENSE_EXPIRATION | Payment during license lapse | HIGH | State licensing board, CMS |
| POST_NPI_DEACTIVATION | Billing after NPI deactivation | CRITICAL | CMS ZPIC/RAC, HHS OIG |
| POST_PECOS_DISENROLLMENT | Billing after PECOS disenrollment | CRITICAL | CMS, HHS OIG, DOJ |
| VACANT_ADDRESS_BILLING | Billing from address confirmed vacant | CRITICAL | HHS OIG, CMS ZPIC, FBI |
| INELIGIBLE_ADDRESS_TYPE | Address type does not support billed service | HIGH | CMS, HHS OIG, state Medicaid IG |
| ADDRESS_NOT_OCCUPIED_DURING_SERVICE | Payee not at address during service period | HIGH | CMS, state Medicaid, SSA OIG |
| CAPACITY_BILLING_EXCESS | Billed volume exceeds licensed capacity | HIGH | CMS, state childcare licensing, HHS OIG |
| GEOGRAPHIC_IMPOSSIBILITY | Service location outside provider service area | HIGH | CMS ZPIC, state Medicaid IG |
| UBO_DECEASED | Beneficial owner deceased during payment period | HIGH | HHS OIG, FinCEN, FBI |
| ENTITY_NOT_YET_INCORPORATED | Payment predates entity incorporation | CRITICAL | CMS, DOJ, FBI |
| EIN_MISMATCH | EIN does not match legal entity name | HIGH | IRS, CMS, state AG |
| CITIZENSHIP_INELIGIBLE | Citizenship did not meet program requirements | HIGH | DHS, SSA OIG, state Medicaid IG |
8. Pricing
| Tier | Price | Included |
|---|---|---|
| Tier 1 - Core Mortality | 35 bps per record | Death records (SSA DMF + state), OIG exclusion, SAM debarment, PECOS/NPI status, program enrollment. Point-in-time temporal reconstruction. Referral packages for CRITICAL findings. |
| Tier 2 - Entity Integrity | 60 bps per record | Everything in Tier 1 plus SOS dissolution history, business license expiration and revocation, DUNS/UEI entity existence, EIN/TIN match, NPI deactivation history, professional license status history, UBO deceased and exclusion checks. Full TIP per payee. |
| Tier 3 - Full Intelligence | 90 bps per record | Everything in Tier 2 plus full address classification and occupancy history, address tenure and NCOA history, high-density multi-registrant detection, registered agent flag, capacity vs. billing volume, geographic plausibility, citizenship/residency at payment date, bank account age and tenure, marital status and spousal benefit cross-reference. Full referral packages and regulator API access. |
| Bundle (FWEA + Identity) | 1 bps + chosen tier with 10% discount | Both products on the same dataset in one pipeline |
| Revenue-share option | Zero upfront, 15% of recovered funds | Full Tier 3 audit at no upfront cost. JIL retains 15% of confirmed collections from findings. |
9. Related specifications
- BID Extended Identity Checks (ID-008 through ID-016)
- Investigation Engine Input Schema
- Ignore Flag API
- Investigative Referral Pathway Reference
- FWEA Framework
(c) 2026 JIL Sovereign Technologies, Inc. All rights reserved. Patent Pending. Investigation findings are analytical outputs and not legal conclusions. All referrals to law enforcement or regulatory agencies should be reviewed by qualified legal counsel prior to submission. Government database access requires applicable data use agreements and enrollment.