A seemingly innocent conversation between you or your office staff and a Comptrollership and Compliance Unit auditor could get you into serious trouble. 

It is not unusual to hear a physician audit has been expanded resulting in a demand for repayment of a large sum of money based on information acquired during a conversation with the physician or their billing staff. This information has often been obtained during what appeared to be an innocent communication in which the physician or billing staff was attempting to be helpful and cooperative. 

Such communications may result in the inadvertent disclosure of information that is used by the Comptrollership and Compliance Unit to broaden its investigation, initiate an investigation of the physician’s colleagues and demand an even larger repayment amount. 

To avoid these fishing expeditions” and the potential disclosure of unhelpful information, Doctors Manitoba recommends that physicians instruct their billing staff not to communicate directly with Comptrollership and Compliance Unit auditors, outside of providing access to patient records and billing information as specified in the letter from the Comptrollership and Compliance Unit.

All other communication with the Comptrollership and Compliance Unit should go through Doctors Manitoba. Where a physician chooses to self-represent when audited, care must be used when providing information. Only provide the Comptrollership and Compliance Unit with the information that it has specifically requested, nothing more. Even if you believe you have nothing to hide, you would be surprised what a vigorous auditor may latch onto.


Andrew Swan
(204) 9855860

Last updated
December 5, 2023