CMS Pub. 100-08, ch. 4, § 4.2.2.6.1

The UPIC shall maintain files on providers/suppliers who have been the subject of

complaints, prepayment edits, UPIC investigations, OIG/OI and/or DOJ investigations,

U.S. Attorney prosecution, and any other civil, criminal, or administrative action for

violations of the Medicare or Medicaid programs. The files shall contain documented

warnings and educational contacts, the results of previous investigations, and copies of

complaints resulting in investigations.

The UPIC shall set up a system for assigning and controlling numbers at the initiation of

investigations, and shall ensure that:

• All incoming correspondence or other documentation associated with an

investigation contains the same file number and is placed in a folder

containing the original investigation material.

• Investigation files are adequately documented to provide an accurate and

complete picture of the investigative effort.

• All contacts are clearly and appropriately documented.

• Each file contains the initial prioritization assigned and all updates.

It is important to establish and maintain histories and documentation on all fraud, waste,

and abuse investigations and cases. The UPIC shall conduct periodic reviews of data

over the past several months to identify any patterns of potential fraud, waste, or abusive

billings for particular providers. The UPIC shall ensure that all evidentiary documents

are kept free of annotations, underlining, bracketing, or other emphasizing pencil, pen,

or similar marks.

The UPIC shall establish an internal monitoring and investigation review system to

ensure the adequacy and timeliness of fraud, waste, and abuse activities. The UPIC shall

maintain their workload in the Unified Case Management (UCM) system, unless

otherwise directed by CMS.