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Fraud, Waste and Abuse (FWA)
A category of oversight activity, separate from general compliance, that the COA universe must include and classify.
The COA universe covers auditing, monitoring, and investigation activities, including both compliance and FWA activities. Column C (Compliance or FWA?) records whether each activity was Compliance, FWA, or Both. Risk assessments must show how FWA risks were identified.
Source: CPE protocol, COA guidance, p. 12; COA Column C, p. 13; Supplemental Documentation Requests, p. 16.