Healthcare providers who participate in federal Medicare and Medicaid programs may be subject to audits by the Centers for Medicare and Medicaid Services (CMS). These audits are conducted by contractors under CMS's auspices through a program known as the "Unified Program Integrity Contractor program, or "UPIC." If you are a licensed healthcare professional and you receive a letter from a UPIC notifying you that you are being audited, it could have significant repercussions on your practice. UPIC audits often result in disruptions in payments, possible FBI investigations, and more. They can also trigger an investigation into your professional license by your state licensing board. Let's talk about the ramifications of a UPIC investigation and what you should do to protect your career.
What Is a UPIC Audit?
A UPIC audit is an investigation by a private contractor that has been contracted by CMS into whether your organization has complied with CMS program requirements. UPIC audits are not random events: they are triggered when CMS detects a discrepancy or billing mistake in your records. UPIC audits focus on specific areas of potential fraud, waste, and abuse in Medicare/Medicaid claims, such as billing for unnecessary services, upcoding (billing for a more expensive service than was actually provided), or providing kickbacks. While the UPIC audit is ongoing, payment on claims may be suspended, putting your practice in financial jeopardy. If the CMS suspects fraud, it may turn over its findings to the Department of Justice for further review.
How can a UPIC Audit Affect My License?
While the UPIC audit itself can have severe repercussions on your practice, the fallout from the investigation could also impact your medical license. State licensing boards typically discipline healthcare providers over things like overbilling, insurance fraud, and poor record-keeping--the very issues that triggered the UPIC audit. If the licensing board gets notified that you're being audited, it may trigger a second, separate investigation by the board into your professional license. If the board determines that wrongdoing likely occurred, it can take disciplinary action against you, including suspension or revocation of your license--possibly even before the UPIC audit concludes.
What Should You Do if You Receive a UPIC Audit Notice?
If you receive an audit notification from a UPIC contractor, it's important to take immediate action to protect your career. Since UPIC audits can last for months, cooperation is key to making the process go faster. Contact the Lento Law Firm for assistance. Attorney Lento will guide you as you provide the requested documentation, along with any evidence you can provide to demonstrate that you are either in compliance or moving toward compliance. If you can resolve a UPIC audit quickly and in your favor, it will lessen the chances that your medical license will be scrutinized.
If your state licensing board notifies you that they have opened an investigation, whether due to a UPIC audit or for any other reason, you need an experienced licensed defense attorney to represent your interests and improve your chances for a favorable resolution. In New Jersey and New York, attorney Joseph D. Lento and the Lento Law Firm help medical professionals and other professional license holders whose licenses are at risk. Contact us today at 888-535-3686 for an appointment.
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