Over the past year and a half, I have seen a significant increase in the volume of Unified Program Integrity Contractor (UPIC) investigations taking place in private physician practices.  UPICs work on behalf of CMS to perform program integrity functions like detecting fraud, waste, and abuse (FWA) through sophisticated data mining and analysis.  UPICs also conduct probe investigations on suspected FWA (among other areas) cases and work collaboratively with law enforcement agencies to make referrals that require further investigation.  UPICs operate as an extension of the government and have special authority to suspend an organization's Medicare/Medicaid program payments immediately.  UPIC investigations are not your typical run-of-the-mill audits.  It is likely that the organization/provider undergoing investigation has been identified as an outlier and/or...

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