Archives: June 2022

Healthcare Investors of the South Conference

I recently spoke at the HITS ((Healthcare Investors of the South) Conference in May, 2022, on Regulatory and Legislative Considerations For Healthcare Investors.


Chris Meekins |Managing Director, Washington Healthcare Policy, Raymond James
Jon Rawlson |President and Founder, Amory Hill Advocates
Jennifer Weaver |Healthcare Industry Partner, Holland & Knight (formerly Waller)

Key Takeaways from the panel include:
• Congress is on a constant quest for more data, more cost reports, and more transparency, and it’s working on the assumption that things are not what they should be when that’s not the reality of the situation.
• The problem for Private Equity is similar to the problem facing PBMs because they’re viewed as a black box. Private Equity doesn’t have an effective lobby like Pharma or any of the other entities in D.C., so Private Equity is easy to point a finger at. If Private Equity is not at the table, it can end up on the table. Private Equity needs to open its checkbooks and invest in lobbyists to advocate on their behalf and actively engage.
• The onus is on Private Equity to be able to prove its compliance program is second to none, clinical programs are executed well and above board and are available for audit at any time. Private Equity must arm itself with sound arguments that it’s delivering the best quality care, regardless of whether it’s for profit or not for profit.

“Private equity healthcare investors are under increased scrutiny from the government and whistleblowers, who gravitate towards the perceived ‘deep pockets.’ The government is particularly focused on individual liability for Private Equity executives who serve on the boards of their healthcare portfolio companies.”
-Jennifer Weaver |Healthcare Industry Holland & Knight (formerly Waller)

About the HITS Conference:

Leaders in private equity, financing, M&A, and development gathered to share insights and observations at the inaugural “Healthcare Investors of the South” conference, hosted by Gallagher, LBMC, Raymond James, and Waller. This day-long intersection of thought leaders produced an essential road map to navigate headwinds and tailwinds as the healthcare industry emerges from a pandemic and faces an uncertain economy.


Who is at risk for a UPIC Audit?

While every provider of the Medicare program is a candidate for an audit, typically, the UPIC audit selection is based on consumer complaints or data analysis. A consumer complaint comes from the company’s employees or the beneficiaries.

Meanwhile, data analysis will search for a large number or mix of cases. Those cases will involve patients who’ve received hospice care, stayed in acute care facilities or had extended home visits.

Learn more about how Armory Hill Advocates helped a pain management client that had a UPIC audit.  

What is a UPIC (formerly ZPIC) Audit?

The Centers for Medicare and Medicaid Services (CMS) created the UPIC (formerly ZPIC) audit to identify and stop fraud and abuse in Medicare and Medicaid.

The main goal of a UPIC is to help CMS:

  • Find fraud, abuse, and waste
  • Perform regional Medicare and Medicaid data analysis
  • Complaint resolution
  • Investigate suspected fraudulent activities

The UPIC uses the above and additional techniques to identify Medicare and Medicaid program weaknesses and vulnerabilities.

Learn more about how Armory Hill Advocates has helped clients that have had a UPIC audit.  

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