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Early ZPIC Audit Considerations for Health Care Providers

ZPICs are the new kids on the block in the Medicare audit industry, and anyone in the healthcare field should familiarize themselves with the operation of these contractors.

    November 17, 2011 /Mens Interest PR News/ -- Even though most healthcare providers are aware of the broad range of audit tools available to the Centers for Medicare & Medicaid Services (CMS), it is easy for professionals to lose track of the most recent developments. An example of recent changes in CMS's task to detect and prevent Medicare fraud and abuse is the shift of responsibility to new contractors such as Zone Program Integrity Contractors (ZPICs).

Of course, the best resource for ensuring compliance and responding to the early stages of an audit is a law firm specializing in healthcare matters. Even before speaking to an experienced healthcare law attorney, however, anyone in a leadership position within a health care entity can benefit from a basic understanding of ZPICs and what to expect if contacted by one.

ZPIC Overview

Zone Program Integrity Contractors are to fully replace the current Program Safeguard Contractors and Medicare Drug Integrity Contractors. ZPICs will ensure a higher level of uniformity in Medicare benefit integrity activities.

The entire nation is divided into seven ZPIC zones. As of 2011, ZPICs are operating in only four of those zones. However, the ZPICs that are operational have been extremely active.

ZPICs are charged with overseeing the integrity of all Medicare-related claims for providers in their designated zones. In contrast to Recovery Audit Contractors (RACs), ZPICs are not paid based on the Medicare overpayment amounts they recover. However, since the primary goal of a ZPIC is to identify cases of suspected fraud, ZPICs may employ many strategies to detect possible improper payments. These include statistical extrapolation, pre-payment reviews and data analysis. ZPICs are under intense pressure by CMS to identify fraudulent claims and thus ZPIC investigations will likely remain highly aggressive.

Initial Steps in A ZPIC Audit

A ZPIC audit can be initiated in many ways. For instance, a ZPIC audit can arise from proactive data analysis, an official complaint, a referral from other contractors or law enforcement agencies, a mismatch of records, etc. Regardless of the means, the initiation of a ZPIC audit is concerning for a health care institution due to a ZPIC's ability to refer cases for substantial criminal or civil monetary penalties, recoupment of Medicare overpayments, or the establishment of pre-payment review, which can have detrimental consequences on a health care practice.

Once a ZPIC audit begins, one of the first actions often taken is a request for records, also known as an ADR. Failing to follow timeframe requirements, formatting guidelines and persuasive best practices for ADR submissions can be problematic.

Only a qualified healthcare attorney can fully explain the best ways to develop an audit defense strategy, and facilitate an effective challenge to ZPIC audits. There are a few key tips to remember when discussing an ADR with your attorney. Depending on the size of your facility, you may want to ask to reduce the number of claims in the requested sample. Also, including an ADR cover letter highlighting evidence that supports patient eligibility can be persuasive, helping avoid claim denials or a more cumbersome, in-depth review. Submit extra documentation (with an explanation in your cover letter) along with requested records if it will help support your claim. Finally, follow proper documentation procedures: never send original records, and keep a copy of all ADR responses. Providers who have concerns about the legality of their billing practices may want to have a health care attorney handle all communications with the ZPIC to avoid making statements that could later be used against them.

Going through a ZPIC audit can be a trying process. But, with the right legal help, you can respond effectively and prevent a ZPIC from wrongly recapturing funds from your practice.

Article provided by Wachler & Associates PC
Visit us at www.racattorneys.com


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