What To Do When Notified Of A ZPIC or Medicare Audit and Site Visit: Checklist

Friday, November 18, 2016
By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law
When a physician, medical group or other healthcare provider receives a notice of an audit and site visit from Medicare, the Medicare Administrative Carrier (MAC) or the Zone Program Integrity Contractor (ZPIC), things happen fast with little opportunity to prepare.  Hopefully this checklist will help you to prepare for the on-site visit that will shortly follow.

Many items on this checklist may seem common sense to the reader;  however, they would not be on here if I did not encounter them as problems in at least two different instances for each one.
If you would like to see a sample letter from CMS Zone, click here.

1. Immediately check your address on the letter to ensure it is the correct and complete physical address of the site visit, including the suite number.

2. Immediately call and make telephone contact with the auditors.

3. Immediately call and advise your health care attorney and have him/her present at the audit and site visit.

4. If the site visit is set for a branch office, make sure the appropriate administrative personnel and at least one of the treaters who see Medicare patients are in that office on the day of the site visit.

5. Conduct a self-inspection of your office immediately; call for an emergency house-keeping visit to clean if necessary.

6. Make sure all patient health records are properly secured and your medical record handling and storage are complaint with HIPAA standards.

7. Make sure all displayed licenses and certificates are current.

8. Have a separate room set aside for the auditors to use with chairs and a flat surface (desk or table) for them to use as their meeting room, conference room and interview room.

9. Make sure your office is "photogenic."

10. Require proper photographic identification and identifying information from each member of the audit team.

11. Be aware of scrutiny of policies and procedures for narcotics or pain medications.

12. Assign one main staff person as communication point with the auditors (and your attorney).

13. Keep a copy of every document or paper you provide to the auditors during the site visit.

14. If the records needed by the auditors are in a different office of the practice, don't kill yourself getting them during the site visit.

15. Don't guess at the answers to the questions asked by the auditors.

16. Expect to be asked for your drug list or formulary.

17. Do not voluntarily advise the auditors of suspicions of wrongdoing or ask if what you are doing is correct.

18. Do ask questions of the auditors.

19. Keep good copies of and document your transmittal of documents to the auditors.

20. If additional time is needed, request it by telephone and confirm it in writing.

Although this checklist just scratches the surface of the audit process, I hope you find it of some help in preparing for any upcoming audit involving a site visit.

Contact Experienced Health Law Attorneys.

The Health Law Firm routinely represents pharmacists, pharmacies, physicians, nurses and other health providers in investigations, regulatory matters, licensing issues, litigation, inspections and audits involving the DEA, Department of Health (DOH) and other law enforcement agencies. Its attorneys include those who are board certified by The Florida Bar in Health Law as well as licensed health professionals who are also attorneys.

To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law is an attorney with The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com  The Health Law Firm, 1101 Douglas Avenue, Altamonte Springs, Florida 32714, Phone: (407) 331-6620.

"The Health Law Firm" is a registered fictitious business name of and a registered service mark of The Health Law Firm, P.A., a Florida professional service corporation, since 1999.
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