How Violations Are Initially Identified

9020.1 – How Violations Are Initially Identified (Rev. 24, Issued: 02-12-16, Effective: 03-14-16, Implementation: 03-14-16) Potential violations can only be identified through a QIO physician reviewer’s review of a practitioner’s or other person’s statutory obligations. This review may occur in a number of ways, including: • The QIO’s examination of a practitioner's or other person's services furnished, in the conduct of multiple case reviews by multiple physician reviewers; • An individual case review completed by one physician reviewer; or • A referral from another entity, such as the QIO‘s Physician Reviewer, a subcontractor providing physician peer review services, another QIO, the MAC, licensing and certification agencies, CMS, or OIG. Potential violations of the obligations listed in §9020 above are initially identified and referred to the QIO for a sanction review as described in §9025 below.