A CMS program integrity contractor that focuses on Medicare Part C and D claims and a Medicare Advantage (MA) plan’s special investigative unit (SIU) are simultaneously auditing the same lab, a double whammy that took its attorney by surprise because of the volume of documentation requested both on the claims and on background information of the lab, including enrollment and certifications. He’s worried more provider audits may be in the works for claims submitted to MA plans by the program integrity contractor that had previously investigated only Part D fraud, waste and abuse, the attorney said.

“This is the first dual audit I have seen on MA claims,” said Stephen Bittinger, an attorney with K&L Gates in Charleston, South Carolina. “The really crazy thing is two different auditors are each allowed a bite at the apple.” Although the focus of the audits is different, the MA plan and the CMS program integrity contractor are auditing some of the same claims, he said.

The lab recently received requests for medical records from Qlarant, which is an Investigations Medicare Drug Integrity Contractor (I-MEDIC). Qlarant said in 2018 that it was chosen as the I-MEDIC and that it would “detect, prevent, and proactively deter fraud, waste, and abuse” in Parts C and D.^[1]