Table of Contents
Unified Program Integrity Contractor (UPIC) audits are among the most aggressive mechanisms in the federal Medicare fraud enforcement arsenal. These specialized contractors operate under the authority of the Centers for Medicare and Medicaid Services (CMS) to investigate suspected Medicare fraud, waste, and abuse. Lowther | Walker’s UPIC audit defense attorneys hold decades of experience helping healthcare providers navigate audits and protect their practices.
Request your free audit defense consultation now to review your UPIC audit response options.
No-obligation. Fully confidential.
Call Us Today: (404) 496-4052
Investigation terminated; no prosecution. DOJ notified our client, the CEO of a major hospital network, that he was the target of a multi-million-dollar healthcare fraud investigation related to “Medicare upcoding” that the FBI and HHS-OIG […]
The FBI and the HHS-OIG investigated our client for Health Care Fraud based on the client’s submitting over $7 million in alleged false claims to Medicare. The Government indicted our client on Conspiracy to commit […]
HHS-OIG investigated our client for Healthcare Fraud and Aggravated Identity Theft based on the client’s allegedly participating in a “telemedicine” kickback scheme that defrauded Medicare of approximately $30 million in reimbursements for not-medically-necessary durable medical […]
A private insurance company discovered that our client, a dentist, fraudulently billed it, various other insurance companies, and federal health care benefit programs for approximately $400,000 of services that our client did not provide. We […]
The Department of Justice’s Criminal Division, Fraud Section charged our client and nine other individuals in a $1.4 Billion health care fraud, wire fraud, and money laundering conspiracy (the largest health care fraud case that […]
Investigation terminated; no prosecution. DOJ notified our client, the CEO of a major hospital network, that he was the target of a multi-million-dollar healthcare fraud investigation related to “Medicare upcoding” that the FBI and HHS-OIG […]
The FBI and the HHS-OIG investigated our client for Health Care Fraud based on the client’s submitting over $7 million in alleged false claims to Medicare. The Government indicted our client on Conspiracy to commit […]
HHS-OIG investigated our client for Healthcare Fraud and Aggravated Identity Theft based on the client’s allegedly participating in a “telemedicine” kickback scheme that defrauded Medicare of approximately $30 million in reimbursements for not-medically-necessary durable medical […]
A private insurance company discovered that our client, a dentist, fraudulently billed it, various other insurance companies, and federal health care benefit programs for approximately $400,000 of services that our client did not provide. We […]
The Department of Justice’s Criminal Division, Fraud Section charged our client and nine other individuals in a $1.4 Billion health care fraud, wire fraud, and money laundering conspiracy (the largest health care fraud case that […]
Unlike routine Medicare administrative reviews from MACs, 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 immediate financial damage to their practice and potential criminal exposure.
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.
Joshua Lowther and Murdoch Walker have built their reputations in healthcare defense by analyzing federal healthcare audits and fraud investigations and forming elegant defense strategies to halt the investigation’s progress. They know how UPIC audit findings can lead to criminal healthcare fraud cases and prepare clients through proactive analysis to stay ahead of prosecutors.
We engage directly with ZUPIC auditors from the earliest stages to establish control over the audit process.
We aggressively challenge improper sampling methodologies and extrapolation calculations that can 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 help prevent future enforcement actions.
Lowther Walker delivers unmatched UPIC audit defense through a combination of federal prosecution experience and healthcare regulatory expertise. Our advantages include:
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:
Our Healthcare representation experience includes intervening in UPIC audits for the following industries:
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 (404) 496-4052 and book a free, no-obligation consultation with an experienced audit attorney.
No-obligation. Fully confidential.
Call Us Today: (404) 496-4052
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.
