NFZ inspection in a physiotherapy practice - what it checks

Ewa runs a physiotherapy practice with a contract with the National Health Fund (NFZ). She bills outpatient physiotherapy sessions, keeps a waiting list, and sends monthly reports. One day she receives a letter: the NFZ is notifying her of an inspection of contract performance. Her first thought is, "Did I do something wrong?" Her second: "Will my records defend every billed visit?"

An NFZ inspection is something different from a KIF site visit or a Sanitary Inspectorate (Sanepid) check. The NFZ primarily verifies whether public funds were spent in accordance with the contract. In this article we show exactly what the NFZ checks in a physiotherapy practice and how to prepare so the inspection doesn't end with a refund of funds.

Who is subject to an NFZ inspection

An NFZ inspection applies only to service providers who have a contract with the NFZ to provide physiotherapy services. If you run a fully commercial practice without a contract, the NFZ does not inspect you (you're instead inspected by the National Chamber of Physiotherapists (KIF), the Sanitary Inspectorate, the National Labour Inspectorate, and under GDPR).

The inspection is based on the Act of 27 August 2004 on healthcare services financed from public funds and the contract itself. It verifies whether performance complies with the contract's terms and with the relevant regulations.

Types of inspection

• Planned -- announced in advance, arising from the NFZ's inspection plan.
• Ad hoc -- triggered by a signal, a patient complaint, or irregularities in reports.
• Records inspection -- often carried out remotely, based on submitted data.

What exactly the NFZ checks

1. Medical records versus billing

This is the core of the inspection. The NFZ cross-checks billed services against the records. For every billed visit there must be an entry confirming that the service actually took place and matched its scope. It checks:

• Whether every billed visit has a corresponding entry in the records.
• Whether the description of the procedure matches the billed code/procedure.
• Whether the dates and number of visits match.
• Whether services that were never provided were billed.

2. Referrals

Physiotherapy under the NFZ requires a referral. The NFZ checks:

• Whether every treatment cycle has a valid referral (e-referral).
• Whether the referral was issued by an authorised doctor and falls within its validity period.
• Whether the scope of services matches the referral.

3. Waiting list

The NFZ verifies how the waiting list is maintained:

• Compliance with the rules for keeping the list and reporting on it.
• Correctness of classification (urgent vs. stable cases).
• Timeliness and accuracy of reporting to the NFZ.

4. Staff and qualifications

• Whether services are provided by people with an active physiotherapy licence number (PWZFz).
• Whether staff meet the requirements set out in the contract (qualifications, working hours declared in the offer).
• Whether the actual work schedule matches what was declared.

5. Conditions of service delivery

• Equipment matching the requirements for the given scope.
• Availability and working hours matching the contract.

Inspection area	Key document	Most common problem
Billing	Records vs. report	Visit billed without an entry
Referrals	E-referral	Missing / invalid referral
Waiting list	Waiting list	Incorrect classification / reporting
Staff	PWZFz, schedule	Discrepancy with the offer
Conditions	Equipment inventory	Equipment shortfalls

Consequences of irregularities

Unlike a KIF visit, where recommendations dominate, an NFZ inspection has a financial dimension:

• Refund of funds paid without justification -- for services billed without matching records.
• Contractual penalties -- for breaches of the contract's terms.
• Termination of the contract -- in cases of serious or repeated irregularities.

That's why the discrepancy "billed but undocumented" is in practice the most dangerous finding of an inspection.

How an inspection unfolds in practice

A planned inspection usually begins with a notification specifying the period and scope covered. NFZ inspectors have the right to:

• Access medical and billing records for the period covered.
• Request explanations and documents confirming that services were provided.
• Verify that the actual state of affairs matches the offer and the contract (staff, equipment, schedule).

An inspection ends with a post-inspection report setting out the findings. You have the right to raise objections within a specified deadline -- which is why it's worth noting explanations as you go and keeping your records organised, rather than reconstructing facts months later. Well-argued objections can genuinely reduce the scope of sanctions imposed.

How to prepare

1. Reconcile billing with records -- every billed visit must have a corresponding entry.
2. Check referrals -- complete, valid, matching the scope.
3. Tidy up the waiting list -- reports matching the actual state of affairs.
4. Verify staff PWZFz and check the schedule matches the offer.
5. Prepare system access -- electronic records ready for inspection.
6. Appoint a contact person for the inspectors.

[SP] Example -- Solo practice: Before the inspection, Ewa goes through the billing reports from recent months and finds a matching record entry for every visit. She finds three billed visits with only a terse description, "treatment." She fills in the description with specific procedures and parameters, because a terse entry risks the billing being challenged.

[GR] Example -- Group practice: In a practice where several physiotherapists deliver the contract, the coordinator checks whether the team's work schedule matches what was declared in the offer to the NFZ, and whether everyone providing services has an active PWZFz. A discrepancy between the offer and the actual roster is a typical reason for a contractual penalty.

Frequently asked questions

Can the NFZ inspect a practice without a contract?

No. An NFZ inspection applies only to service providers bound by a contract with the NFZ. A fully commercial practice is not subject to NFZ inspection, but it is subject to the KIF, the Sanitary Inspectorate, the National Labour Inspectorate, and GDPR.

What is the most common reason for a refund of funds?

Billing a service that isn't fully backed by medical records -- for example, a visit that was billed but has no entry, or one with a description too vague to confirm the procedure performed. That's why matching billing to records is the priority.

Is an NFZ inspection always announced in advance?

Planned inspections are announced, but the NFZ can also carry out ad hoc inspections, for example in response to a patient complaint or irregularities in reports. That's why it's worth keeping records and billing in order continuously, not just before an inspection.

How does an NFZ inspection differ from a KIF visit?

The KIF checks professional and ethical standards and the quality of records, and its sanctions are mainly disciplinary in nature. The NFZ verifies whether public funds were spent correctly in line with the contract, and its findings have a financial dimension: refund of funds, contractual penalties, and even termination of the contract.

CTA: Want every billed visit to be backed by proper records? The STANDARD package includes medical record templates and procedures that make it easier to defend your billing during an NFZ inspection. See FizjoReady packages →

Related articles:
- Medical records in physiotherapy -- which documents are mandatory?
- KIF inspection at your practice -- what to expect and how to prepare
- How to correctly keep a patient record in physiotherapy?