Maintain Controlled Filing System and Documentation

4.2.2.6.1 - Maintain Controlled Filing System and Documentation (Rev. 11032; Issued: 09-30-21; Effective: 10-12-21; Implementation: 11-10-21) The UPIC shall maintain files on providers/suppliers who have been the subject of complaints, prepayment edits, UPIC investigations, OIG/OI and/or DOJ investigations, U.S. Attorney prosecution, and any other civil, criminal, or administrative action for violations of the Medicare or Medicaid programs. The files shall contain documented warnings and educational contacts, the results of previous investigations, and copies of complaints resulting in investigations. The UPIC shall set up a system for assigning and controlling numbers at the initiation of investigations, and shall ensure that: • All incoming correspondence or other documentation associated with an investigation contains the same file number and is placed in a folder containing the original investigation material. • Investigation files are adequately documented to provide an accurate and complete picture of the investigative effort. • All contacts are clearly and appropriately documented. • Each file contains the initial prioritization assigned and all updates. It is important to establish and maintain histories and documentation on all fraud, waste, and abuse investigations and cases. The UPIC shall conduct periodic reviews of data over the past several months to identify any patterns of potential fraud, waste, or abusive billings for particular providers. The UPIC shall ensure that all evidentiary documents are kept free of annotations, underlining, bracketing, or other emphasizing pencil, pen, or similar marks. The UPIC shall establish an internal monitoring and investigation review system to ensure the adequacy and timeliness of fraud, waste, and abuse activities. The UPIC shall maintain their workload in the Unified Case Management (UCM) system, unless otherwise directed by CMS.