ZPIC Medicare Audits: Lessons Learned From CMS Scrutiny

Navigating the Complex Audit and Appeals Processes

Recording of a 90-minute CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, August 11, 2011

Recorded event now available

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Course Materials

This CLE course will provide guidance to healthcare counsel on preparing for CMS's Zone Program Integrity Contractor (ZPIC) audits. The panel will examine lessons learned during the first year of ZPIC audits, outline steps to minimize the risk of such audits, and offer strategies for appealing unfavorable audit results.


After one year, the Centers for Medicare & Medicaid Services' new enforcement tool, Zone Program Integrity Contractor audits (ZPICs) have proven to pose a greater risk than RACs. ZPICs target the medical necessity of a claim and coding errors.

Providers can learn a lot from the audits conducted so far. ZPICs are time consuming and expensive. ZPIC auditors may arrive unannounced and can demand medical records and interviews with both providers and beneficiaries. Further, ZPIC auditors can conduct both pre-payment and post-payment reviews.

Healthcare providers should treat ZPICs seriously. Even small coding errors can be extrapolated into significant overpayments. Providers and their counsel must understand how to prepare for the audits and how to navigate the appeals process, if necessary, to challenge the results.

Listen as our authoritative panel of healthcare attorneys examines how ZPIC audits are being conducted and the lessons learned after the first year of the audits. The panel will offer strategies on how to prepare for ZPICs and how to appeal unfavorable ZPIC results.



  1. ZPICs audits
    1. Role of ZPICs
    2. Contractor authority
    3. Role of extrapolation
    4. Fraud and abuse consideration
  2. Preparing for ZPICs
    1. Compliance program
    2. Risk assessments
    3. Training
  3. Response to findings and appealing ZPICs
    1. ZPIC audit process
    2. Appeal process
    3. Potential defense issues


The panel will review these and other key questions:

  • What are the key steps healthcare providers can take to minimize the risk of a ZPIC audit?
  • What can healthcare providers do now to prepare for a potential ZPIC audit?
  • What are the best practices for healthcare providers to challenge an unfavorable audit outcome?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Sara Kay Wheeler
Sara Kay Wheeler

King & Spalding

She has extensive experience in the creation and implementation of corporate compliance programs and investigations,...  |  Read More

Steve Lokensgard
Steve Lokensgard

Special Counsel
Faegre & Benson

He has extensive experience with identifying and managing regulatory and financial risk. He assists healthcare clients...  |  Read More

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