Rivas Goldstein, LLP Call : 212-541-2451 | 800-758-3278

ZPIC audits on the rise: Tips for pharmaceutical companies

Zone program integrity contract (ZPIC) audits are on the rise. These audits can result in evidence given to the Department of Health and Human Services (HHS) Office of Inspector General (OIG) and potentially result in criminal charges.

ZPICs were created by the Centers for Medicare and Medicaid Services (CMS) to find instances of health care fraud and hold alleged offenders accountable for violations. Some reports claim ZPIC investigations are more aggressive and invasive compared to other types CMS inspections.

As a result, proactive measures may be wise.

How can pharmaceutical companies prepare for a ZPIC audit? It can help to know the general process. ZPIC audits can include unannounced site visits, repeated requests for documentation, interviews with staff and management and a review of billing. Those that find themselves the subject of a ZPIC investigation can take steps to protect their interests. These steps include:

  • Get organized. It is important to have documentation often requested by auditors ready. This often includes documentation needed to support payment requests from insurance providers, Medicare as well as private insurance companies.
  • Review compliance. Ideally, the company should already have a compliance program in place to review billing and coding practices. Review the program and update as needed. If the company does not yet have one, put one in place.

It is often wise for pharmaceutical companies to conduct regular internal audits to help better ensure the facility is in compliance with applicable regulations. These audits can result in the discoveries that require a resolution. Making required changes prior to an audit may come at an expense, but it is likely much less costly than a negative audit by the ZPIC that could lead to further investigation from the OIG.

No Comments

Leave a comment
Comment Information
Email Us For A Response

Schedule A Consultation With An Attorney

Bold labels are required.

Contact Information
disclaimer.

The use of the Internet or this form for communication with the firm or any individual member of the firm does not establish an attorney-client relationship. Confidential or time-sensitive information should not be sent through this form.

close

Privacy Policy

Austin Office
3345 Bee Cave Rd, Suite 104
Austin, TX 78746

Toll Free: 800-761-5190
Phone: 512-481-8000
Fax: 512-481-0022
Map & Directions

New York Office By Appointment Only
405 Lexington Ave 26th Floor
New York, NY 10174

Toll Free: 800-758-3278
Phone: 512-481-2916
Phone: 212-541-2451
New York Law Office Map

McAllen Office By Appointment Only
1100 East Jasmine Ave
Suite 105
McAllen, TX 78501

Phone: 512-481-8000
Map & Directions

Review Us