The Centers for Medicare & Medicaid Services (“CMS”) has launched another targeted and wide-reaching effort to identify and stop Medicare fraud and abuse through its use of Medicare Zone Program Integrity Contractors (ZPIC). While much of the provider focus has been on the Medicare Recovery Audit Program (RAC audits), ZPIC contractors have emerged as perhaps a more significant cause for concern with recent scrutiny on skilled nursing facilities, hospices, physicians, home medical equipment suppliers, physical therapists and the like in an ostensible effort to detect potential fraud and abuse to the Medicare program. In this teleseminar, Reed Smith attorneys Scot Hasselman and Rahul Narula will discuss the background behind this important fraud and abuse auditing initiative, its scope and process, how providers can stay attuned to these vital issues in CMS’ dynamic regulatory environment, and possible tactics for challenging audits when the need arises.

Topics include:

• Defining what ZPICs are and how they relate to (and differ from) other Medicare auditors such as RACs and PSCs
• Identifying what you should expect from a ZPIC audit
• Determining the scope of authority of ZPIC audits, including discussion on pre-pay and post-pay review, and the ZPIC’s performance of statistical sampling and extrapolation
• Preparing for a ZPIC audit, including discussion on compliance programs and maintenance of medical records
• Contesting a ZPIC audit, including strategies and discussion on challenging such audits through the Medicare appeals process
• Understanding the potential for referrals to other agencies such as DOJ or OIG

Presenters:

• Scot T. Hasselman is the Vice Chairman of Reed Smith's Life Sciences Health Industry Group, practicing in the area of health care regulatory law. Scot's practice encompasses a variety of health law matters with a focus on fraud and abuse issues. He has represented and defended health care companies in lawsuits, regulatory, and program integrity matters before the Centers for Medicare & Medicaid Services, the United States Department of Justice, the HHS Office of Inspector General, health care program contractors, and various state agencies. He has also negotiated government settlements and corporate integrity agreements.
• Rahul Narula works with a variety of health care clients, including providers, on a broad range of complex regulatory issues. He has experience handling matters pertaining to Medicare and Medicaid reimbursement, federal and state health law matters, fraud and abuse compliance, and FDA regulatory and enforcement. Rahul has assisted clients with regulatory due diligence, fraud investigations, and audits, and has analyzed complex health care arrangements under the Anti-Kickback, Stark, and False Claims Laws.