Government Audits and Investigations: Financial Risk Areas and Building a Proactive Response Team

Due to their participation in multiple federal health care programs (such as Section 330 of the Public Health Service Act, Medicaid, and Medicare), health centers are subject to scrutiny from a number of different sources: HRSA’s Division of Financial Integrity, Medicare Administrative Contractors (MACs), CMS’s Unified Program Integrity Contractors (UPIC), State Medicaid Fraud Control Units (MFCUs), and the Office of Inspector General (OIG), just to name a few. Fortunately, there are a number of proactive steps a health center can take to minimize the potential of an audit or investigation taking place or for reducing their scope or duration. This session will address those proactive steps such as establishing an “advance team,” reviewing billing policies and procedures, identifying common risk areas, and conducting self audits. Health centers also need to know how to respond in the event that they receive a notice of an audit or investigation. When a health center has been armed in advance with the knowledge of who should be involved in responding to an audit or investigation, the health center can do a better job of responding in an organized and thoughtful fashion.