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Law Enforcement Referrals by UPICs

March 26th, 2019 by

UPIC investigatorBy: Matt Fischer

CMS contractors such as Unified Program Integrity Contractors (UPICs) are tasked with ensuring that Medicare pays the right amount for covered services by legitimate providers.  Specifically, a UPIC’s main goal is to identify cases of suspected fraud, waste and abuse, and additionally, to take immediate administrative action to protect federal program funds.  Within its administrative action toolkit, apart from the common pre- or post-payment reviews and payment suspensions, UPICs have the ability to refer cases of potential fraud to law enforcement agencies. read more

DEA Audit & Administrative Proceedings: Steps to Know

November 21st, 2017 by

pharmacy audit deaBy: Matt Fischer

The Drug Enforcement Administration (DEA) is responsible for the monitoring of all manufacturing and distribution of controlled substances in the country.  Pharmacies, medical providers (i.e., who either administer, prescribe or dispense), and distributors and manufacturers of controlled substances are required to register with the DEA.  The DEA’s Diversion Control Division is tasked with reviewing applications of potential registrants and monitoring existing registrants through audits and investigations.  However, the question on many registrants’ minds is what happens if violations or deficiencies are discovered?  The answer is it depends.  The consequences will vary based on the level of noncompliance.  Thus, it is essential to be familiar with the laws that apply and most importantly, have a full understanding of the administrative process in order to act quickly to minimize potential adverse action if noncompliance is found. read more