If the ALJ upholds the QIC’s decision on reconsideration, the fourth stage of appeal for ZPIC audits is to request a review by the Medicare Appeals Council. The Medicare Appeals Council is comprised of ALJs who have specific experience in matters involving allegations of overpayment and Medicare fraud. However, rather than reviewing the facts of the case, the members of the Medicare Appeals Council review the OMHA ALJ’s ruling for errors of law and abuses of discretion, similar to the role of a federal court of appeals.