PERM exposure begins long before a federal sample is drawn.
This executive white paper examines how Medicaid organizations can move PERM eligibility risk from periodic audit response to a continuous operational discipline.
It addresses:
eligibility accuracy versus audit defensibility;
evidence preservation and decision reconstruction;
exception governance;
shadow-PERM testing;
fiscal exposure and executive ownership; and
an action agenda before the next sample.
Five pages | National Medicaid focus | August 2026