Even with home health agency’s efforts to comply with Medicare regulations, the looming potential of being identified as an “outlier” by a ZPIC leaves you subject to a full-blown audit. In fact, this may happen for many reasons; a ZPIC audit could use data analysis to detect “outliers” compared to local and national patterns, employee or beneficiary whistle-blowers, or referral from a MAC or other contractors based on the results of a previous audit.

Should your agency receive a ZPIC Audit being prepared is a key step to ensure documentation and billing compliance. Taking a proactive approach is necessary. Learn from our clinical compliance expert, Dee Geray, about the best steps to take to prevent a ZPIC audit:

My Agency is receiving a ZPIC audit, now what?          


  • Report the ZPIC auditor presence to key parties in your organization.
  • Involve legal counsel immediately.
  • Take your time in preparing requested documents and request extension as needed.
  • Use the full allotted time frame to ensure all documents of the record are provided so both technical and clinical eligibility are evident.
  • Include supporting documentation prior to and post review request that support clinical eligibility.
  • Submit additional request documents as soon as possible.
  • Ensure each packet is prepped at the same time.
  • Keep exact copies of any submitted documents.
  • Have a central mail repository so no demand letters are missed.
  • Review all findings when they arrive. The documents can be lengthy.


  • Alter documents that are requested.
  • Use this time to identify problems, instead focus on the task at hand.

About The Contributor

Dee Geray, RN, Clinical Consulting Manager

Dee Geray, RN, is a Clinical Consulting Manager for post acute solutions at McBee. Dee works with home health and hospice providers nationwide to perform Medicare compliance reviews and establish internal audit plans.