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2. UNANNOUNCED MEDICARE AUDITS – WHAT TO DO IF INVESTIGATORS COME TO YOUR OFFICE Friday, February 25, 2011 2 Alan S. Gassman, Esq. and Lester Perling, Esq. Copyright © 2011 Gassman, Bates & Associates, P.A.

3. Don’t panic or feel rushed. 3 Copyright © 2011 Gassman, Bates & Associates, P.A.

4. Make sure that you confirm the identity of the individuals and make copies of their identification cards and credentials. 4 Copyright © 2011 Gassman, Bates & Associates, P.A.

5. Contact qualified legal counsel and let the investigators wait while you do this. 5 Copyright © 2011 Gassman, Bates & Associates, P.A.

6. Appoint a buffer person in the office to facilitate communication. Even jokes can be misconstrued against you. 6 Copyright © 2011 Gassman, Bates & Associates, P.A.

7. Be polite. Be professional. Stress that your primary concern is for patients and their privacy. 7 Copyright © 2011 Gassman, Bates & Associates, P.A.

8. Say as little as possible. “Anything you say can and will be used against you.” Do not agree to an interview. 8 Copyright © 2011 Gassman, Bates & Associates, P.A.

9. Don’t seek sympathy from the investigators. You will not get it! 9 Copyright © 2011 Gassman, Bates & Associates, P.A.

10. Let employees know that they are not required to speak to the investigators. Do not obstruct the investigators from approaching employees. 10 Copyright © 2011 Gassman, Bates & Associates, P.A.

11. Do not sign anything not reviewed by legal counsel. 11 Copyright © 2011 Gassman, Bates & Associates, P.A.

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