The UPIC Audit Landscape: Legal Risk, Enforcement Trends, and Provider Impact

Date: 07/10/25
Time: 2:00-3:30 PM ET

* Please Note: registration closes at 11:59 PM ET the day before the live event. No further registrations will be accepted once registration has been closed *

Live closed captions are available.

Overview: UPIC audits are among CMS’ most aggressive tools for enforcing Medicare and Medicaid program integrity—and their prevalence, scope, and severity are growing. Often initiated through covert data analysis and conducted by contractors, these audits can result in multimillion dollar recoupments, payment suspensions, and even law enforcement referrals—all before a provider can respond or appeal. Yet, many providers and their counsel remain unprepared for what these investigations truly entail. Using real case examples, this webinar breaks down the full UPIC audit timeline, from data-driven targeting through the five-step appeals process. Speakers also offer strategies for building cross-functional response teams and spotting policy patterns that could reshape the future of CMS enforcement. Attendees will leave equipped to advise clients at every stage of a UPIC audit—from trigger through final appeal.

Learning Objectives: 

  • Understand the current UPIC audit landscape, enforcement trends, and due process challenges through real-world case examples.
  • Explore what makes UPIC compliance uniquely complex compared to routine audit adjudication.
  • Discover best practices for preparing, responding to, and defending against a UPIC audit.

Speaker Information:

Jon B. Rawlson, Founder & President, Armory Hill Advocates, LLC.

Jennifer Weaver, Partner, Holland & Knight


Continuing Education:

CLE: IMPORTANT CHANGE REGARDING CLE CREDIT: We are now working with ABA CLE for our accreditation needs. To earn credits during a live webinar, attendees must be logged into the webinar for at least 75 minutes (of a 90-minute webinar) or 55 minutes (of a 60-minute webinar). Then, they will receive a personalized CLE affidavit from mcle-ahla@americanbar.org. Watch for this email within 7-10 business days. If you do not receive it, please check your spam or junk folders as these emails often end up there. Please note you will fill out one affidavit for the full event. Once you complete the affidavit, you will be able to download your certificate(s) of attendance, and certificates will be emailed to you from mcle-ahla@americanbar.org.

CPE: AHLA is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Nashville, TN 37219-2417. Website: www.nasba.org. For further information, please visit our Continuing Education Page.

AHLA is seeking CPE credits for live webinars. The maximum number of credits available is 1.80.