Self-Audits to Avoid Civil Monetary Penalties
A Self-Audit Can Help Mitigate 43 C.F.R. 1003 Civil Monetary Penalties
1 – Initial Consultation
Establish baseline on case, timelines, and essential details of the statistical extrapolation.
2 – Selection of Claims
Review of assembled data by qualified expert statistician.
3 – Analysis & Documentation
Attorney briefed on opposition research and given list of questions for cross-examination.
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4 – Methodology
Estimation of cost to health care provider; specify tasks & objectives.
5 – CPA Certification
Brief attorney on initial findings; review strengths and weaknesses of case; pick litigation strategy.
6 – Brief to Attorney
Expert witness for your hearing provides the necessary testimony.
7 – Report (2 versions)
Assemble all information regarding the statistical extrapolation.
8 – Pleading Support
Report of findings. A second report contains detailed annotations and notes for attorney.
"When the provider has performed a Self-Audit, it mitigates the amount of Civil Monetary Penalty."