UPIC Inquiries: Proceed with Caution

In 2016 the Centers for Medicare & Medicaid Services (CMS) began consolidating fraud and abuse oversight work into a new set of contractors called Unified Program Integrity Contractors (UPICs). CMS completed the launch of its new UPIC program with very little public fanfare, and not long thereafter temporarily halted UPIC auditing work during the early part of the COVID-19 pandemic. UPICs are broadly authorized to investigate potential fraud and to report findings to government enforcers. Indeed, a report issued last fall by the Department of Health and Human Services-Office of Inspector General (HHS-OIG) underscores that UPICs have substantially more sophisticated data and tools at their disposal than their predecessors, and healthcare providers receiving a UPIC inquiry should undertake a strategic response, recognizing that a broader government investigation could be on the horizon.