Unified Program Integrity Contractor (UPIC) audits represent one of the most aggressive mechanisms in the federal Medicare fraud enforcement arsenal. These specialized contractors operate under authority from the Centers for Medicare and Medicaid Services (CMS) to investigate suspected Medicare fraud, waste, and abuse.
Lowther | Walker’s UPIC audit lawyers hold decades of experience helping healthcare providers navigate audits and protect their practices.
Request your free consultation now to review your UPIC audit response options.
Unlike routine Medicare administrative reviews, UPIC audits are inherently investigative and frequently serve as precursors to formal federal healthcare fraud investigations. When a UPIC audit targets your healthcare practice or business, you face potential recoupment demands and referrals to the Department of Justice (DOJ), Office of Inspector General (OIG), or other federal law enforcement agencies.
Our federal defense attorneys leverage their experience as former federal prosecutors to provide strategic and aggressive defense against UPIC audits.
With our deep understanding of federal healthcare enforcement mechanisms, our attorneys can help protect healthcare providers from the immediate financial threats and potential criminal exposure these audits represent.
Penalties for failing UPIC audits are significant. Auditors can refer healthcare providers for criminal prosecution, with ZPIC/UPIC audit penalties including:
UPIC contractors can recommend Medicare payment suspensions that freeze your reimbursements indefinitely during investigations
Contractors will use statistical sampling methodologies to transform findings from a small sample into massive monetary demands
After an audit, your practice may face 100% pre-payment review processes that limit cash flow
Criminal referrals are the most damaging consequence of a ZPIC audit. Zone Program Integrity Contractors refer cases to OIG and the FBI for a formal federal investigation.
Federal penalties include exclusion from federal healthcare programs, including Medicare, after an audit finds suspicious payment activity and billing concerns.
By proactively contacting Lowther | Walker at any of the above stages, you can avoid consequences ranging from exclusion from your insurance network to criminal prosecution for healthcare fraud. We’ll work tirelessly to defend your practice and your future within the industry.
Our team has decades of healthcare compliance experience and has demonstrated our industry expertise while successfully defending a client in the highest-value healthcare fraud case the DOJ has ever prosecuted.
Providers face referral to state licensing boards when ZPIC audits result in unfavorable outcomes that trigger further investigations.
When UPIC auditors target your practice, their sole focus is on identifying improper payments and potential fraud. The auditors have significant resources at their disposal. They can interview patients and search for indications of suspicious conduct and previous complaints.
Mr. Lowther and Mr. Walker have built their reputations in healthcare defense by analyzing how federal healthcare fraud investigations develop and forming elegant defense strategies to mitigate investigation progress. They know how ZPIC/UPIC audit findings transition into criminal healthcare fraud cases and prepare clients by pre-empting prosecutors.
We engage directly with ZPIC/UPIC auditors from the earliest stages to establish control over
the audit process.
We aggressively challenge improper sampling methodologies and extrapolation calculations that artificially inflate overpayment demands.
Our team reviews all documentation before submission to identify vulnerabilities while ensuring compliance with audit requests.
We identify systemic weaknesses and implement robust compliance protocols to protect against future enforcement actions.
Lowther Walker delivers unmatched UPIC audit defense through a combination of federal prosecution experience and healthcare regulatory expertise. Our advantage includes:
Our prosecutorial background gives us unique insights into:
Lowther | Walker has built a reputation as one of the nation’s foremost healthcare fraud defense teams.
Our background work in helping clients navigate healthcare audits includes the following:
We’ve developed specialized intervention strategies to:
Our track record demonstrates consistent success in the following:
Standard billing practices may trigger aggressive ZPIC/UPIC enforcement actions. Healthcare providers should be particularly vigilant about:
Any Medicare-participating provider or supplier can be audited, including physicians, home health agencies, DME suppliers, hospices, and skilled nursing facilities.
Yes. Providers are required by federal law to comply with UPIC audit requests within a specific timeframe, usually 10–30 days.
Yes. ZPICs have authority to conduct unannounced site visits and interviews with staff as part of their investigations.
The timeline varies, but audits can take several months from the date of the initial request to the auditor’s final determination, especially if legal proceedings are involved.
Yes. ZPIC findings can be appealed through the Medicare appeals process, which includes multiple levels of review.
Preserve all requested records, avoid altering documentation, notify legal counsel immediately, and prepare a coordinated response strategy.
When your practice faces a ZPIC/UPIC audit, immediate intervention by experienced federal defense counsel is essential. Lowther | Walker provides strategic defense during high-stakes ZPIC audits and investigations, protecting your practice’s financial viability and professional reputation.
Our federal defense attorneys are available for immediate consultation regarding:
Call Lowther | Walker via 1-404-806-7997 and book a free, no-obligation consultation with an experienced audit attorney.
