Rachel Hold-Weiss Comments on the Intensity of ZPIC Scrutiny

Arent Fox Health Care partner Rachel Hold-Weiss was quoted by Modern Healthcare for a story on efforts by zone program integrity contractors (ZPICs) to expose provider fraud.

Modern Healthcare reported that ZPICs are contracted by the Centers for Medicare and Medicaid Service and work in seven zones around the country. The article reports that both the Senate Finance Committee and the Government Accountability Office are reacting to complaints that the ZPICs have been overzealous in fighting fraud.

Ms. Hold-Weiss said that you can’t refuse the investigators entry. However, “Whoever walks in the front door and says we have a piece of paper to get this information, you want to make sure you have someone who is trained in how to deal with them. “You want to make sure that other than water or a cup of coffee, nothing is offered to them. You don’t want to do anything that could be misconstrued as a bribe.”

Ms. Hold-Weiss further commented that government contractors occasionally overlook important information when investigating medical records. The publication added that “the key to mounting a solid defense in such an audit is to make sure that each page of a medical record submitted for review is stamped in an overall page-numbering system, known as Bates numbering, so that omissions or mysteriously ‘lost’ documents will stand out as gaps in the sequence of pages.”

“In every case that I have handled, there has been at least one record where there was a technical denial that there was no basis for, because we have been able to show that the document was there,” said Ms. Hold-Weiss.

To read the full article at the Modern Healthcare website, click here (subscription required).

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