Healthcare Regulation Update: CMS to Develop New Integrity Contractors Called “Unified Program Integrity Contractors”


The American Health Care Association (“AHCA”) has reported that the Centers for Medicare & Medicaid Services (“CMS”) will be making efforts to streamline its audit structure. Among the changes will be the development of a new integrity contractor called a Unified Program Integrity Contractor (“UPIC”). These new contractors will focus on both Medicare and Medicaid integrity issues. Initial reports suggest that Zone Program Integrity Contractors (“ZPICs”), Program Safeguard Contractors (“PSCs”) and Medicare Administrative Contractors (“MACs”) will be folded into the UPIC structure. However, subsequent guidance from CMS suggests that ZPICs and MACs will still have some responsibilities independent of the UPIC structure.

CMS also plans to phase out Medicaid Integrity Contractors (“MICs”) while leaving Medicare Recovery Auditors (“RAs”) and Medicaid Recovery Audit Contractors (“RACs”) in place. AHCA also reported that CMS would be consolidating all Medicare and Medicaid data into one unified database.

You can read more about AHCA’s announcement here. We are hopeful that the proposed changes will actually streamline the audit process, prevent duplicative audits and limit duplicative records requests, rather than create an additional burden for providers.

Fuerst Ittleman David & Joseph, PL will continue to monitor the CMS audit landscape. For additional information concerning CMS audits, feel free to read our prior articles on this subject, including “The Latest Zpic Target: Medicare Cost Reports” and “ZPICs and Skilled Nursing Facilities: Medicare’s Wild Wild West“.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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