It's a rather low bar that allows that a UPIC must must overcome to institute a payment suspension and then the payment suspensions can last for many many months. So in 2019 there were about 400 payment suspensions issued across the country by these duplicates and those payments suspensions can be devastating in our view. And my guess is this might shift if they, you know, do the same analysis you know, into the future. And I was just surprised the number of times I know you have it at your fingertips, Bryan, and this is 2019 data. So, you know, we're sort of a drop in the bucket but I think it is a real enforcement remedy. And I mean, this is still in this report talks about all that UPIC activity, right? This is just hospice.

And I think that's kind of the the tension that exists is it's just not as direct as the contingent arrangement that a lot of our our customers clients think exists.Ī thing that jumped out at me in this report was, I think the death knell that people are most fearful of is payment suspension and just surprised by the number of payment suspensions that were instituted. And the one hand but on the other hand, they do say, but we do expect the return on our investment with these providers. So yeah, this will be in the episode notes report, but you can see how they I think they they make an effort to say that we they're not compensated in a way that influences how they conduct these audits. So if you go through this report, which will you kind of attach to? What do we call them? The comments, the liner notes. But the report is clear that rather than looking at or each audit, is there a continuum fee or they judged based upon that audit? And do they get a cut of that, which is not the case? CMS does look for a return on their investment with each of these UPICs and so it's more of a broader based analysis. And that's really not a direct relation ship that exists for UPICs. They're looking to get a cut and they're there for their inflating denial rates and the value of those denials. And like you said the suspicion of a lot of our clients is these are all contingent auditors. We I agree the intervention of COVID kind of changed a lot about this and I suspect that a lot of what they observed back in 2019 it'd be a completely new set of observations now but on the point you just referenced we there are some subtle indications in this report about that compensation component. But what jumped out at you in this report. So this is it feels like truly a lifetime ago this is pre-COVID. So and I think one caveat, Bryan, with this report is this is looking at 2019 data. However, you know, it's part of performance metrics. So I think we always have to answer that question as, yeah, they're not paid on a contingency basis. And, you know what? What is it that you you pigs are actually doing? In terms of how robust is your program integrity activities? What money are you collecting? What kinds of enforcement are you taking? And things like that. They get a percent of recovery, but most contractors don't you know, get that. And so they're thinking about the RACS, who there was sort of like a contingency. Aren't aren't these contractors incentivized to deny claims? Right.

And it may be a place to start, Bryan, because I feel like we get this question all the time. This is a very stirring title Bryan about and what we're going to be talking about here which is you know a fancy way of saying the OIG came out with a very recent report about UPIC activity and how is it effective and what kinds of things are they doing. The UPIC report card, the OIG's evaluation of the UPICs provides insight into the future of hospice audit. Hello and welcome to Hospice Insights, The Law and Beyond where we connect you to what matters in the ever changing world of hospice and palliative care. This transcript was auto-generated using Adobe Premiere Pro.

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