Who Audits the Auditors?


Two thousand years ago the Roman poet Juvenal asked, “Who watches the watchmen?” (Satires, VI, line 346).

Since the advent of Medicare in 1965, hospitals have bemoaned the cost and burden of Medicare audits.  The complaints increased when CMS hired private contractors for the audits.  They became deafening in 2009 with the advent of the Recovery Audit Contractor (RAC) program, the program that gives private contractors a percentage of whatever they recover (a bounty in the view of hospitals).

And the audits are not only burdensome, they’re duplicative, what with MACs (for Medicare administrative contractors), ZPICs (for zone program integrity contractors), CERTs (for comprehensive error rate testing contractors) and UPICs (for unified program integrity contractors), as well as the hated RACs.

So the hospitals naturally ask who keeps watch over this mess.  Who makes sure all these audits don’t duplicate one another?  In other words, who audits the auditors?

Last week the Government Accountability Office (GAO) provided an answer:  no one does.  Or at least, no one does a good job at it.  The GAO report concludes that “CMS does not have reliable data to estimate the total cost of duplicative claims reviews by all four types of contractors.”

So now we know.

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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