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How to Avoid ZPIC Overpayment Assessments

ZPIC overpayment process

One of the most stressful parts of a ZPIC audit comes when the auditors uncover ways in which your Medicare claims don’t meet coverage requirements. While you can file a redetermination appeal, it’s easier to avoid overpayment assessments altogether. You can do this by making sure that your whole team is fully trained in how to properly document, code, and bill Medicare payments.

Meeting Regulatory Documentation Requirements

It can be hard to convince clinicians and administrative staff alike that appropriate documentation practices are necessary, especially when there’s no threat of a ZPIC audit currently looming. Before an audit ever occurs, you need to show your staff that ZPIC auditors apply a strict interpretation of Medicare’s documentation and coverage requirements.

You can do this by sharing the published reports of ZPIC audits at other organizations. By showing them how ZPIC auditors apply Medicare’s coverage and documentation requirements, you can help them understand the need to adhere closely to these requirements.

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Dr. Nick Oberheiden
Dr. Nick Oberheiden

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Amanda Marshall
Amanda Marshall

Former U.S. Attorney

Lynette S. Byrd
Lynette S. Byrd

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Aaron L. Wiley
Aaron L. Wiley

Former Federal Prosecutor

Subodh Chandra
Subodh Chandra

Former Federal Prosecutor

R. Brandon Johnson
R. Brandon Johnson

Former Federal Prosecutor

Roger Bach
Roger Bach
(Non-Lawyer)

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Dennis A. Wichern
Dennis A. Wichern
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Chris Anderson
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Beverly Gibson
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Joe Lewis
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Pharmacy Compliance

Valerie Rivera
Valerie Rivera
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Private Investigator

Your staff should be able to understand and comply with documentation and coverage requirements for:

  • Local Coverage Determinations (LCDs)
  • National Coverage Determinations (NCDs)
  • Local Medical Review Policies (LMRPs)
  • The Medicare Policy Benefit Manual (MPBM)
  • The Medicare Program Integrity Manual (MPIM)

Other areas that your staff should be familiar with and strictly adhere to include:

  • any statutory provisions covering provided services, and
  • any additional guidance issued by Medicare that applies to your claims.

Make sure you and your staff go over recent enforcement actions and related concerns regularly. Read HHS-OIG’s reports so that you can learn from the mistakes of other providers in your position. Enlist the help of an attorney to help you keep your organization in full compliance, and address any areas of risk in your compliance plan.

As you might guess, ensuring that your staff understands all of these elements – and are compliant when it comes to documentation and coverage requirements – can be complicated. However, it’s important for everyone involved to understand the severity of consequences that can come with not understanding or being in compliance. Failing to comply and making seemingly minor mistakes can cost you your business – and cost everyone who works for you their job.

A Zealous Federal ZPIC Audit Legal Team Can Help

Understanding and following all the elements of a ZPIC audit can be overwhelming and complicated. Combine this with the stress of what might happen to your business, and it can become an unbearable process. Fortunately, it isn’t something you have to navigate or figure out on your own. We can help. At Oberheiden, P.C., our attorneys have the experience and knowledge you need on your side to face and conquer any part of the ZPIC process.

To learn more about a ZPIC audit and what you can expect if documents are requested, you can speak with one of our attorneys at Oberheiden, P.C.. For a free and confidential consultation, call (888) 727-5159 or complete our online contact form today.

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