OIG Work Plan 2013 – Medical Equipment and Supplies

If you are not aware, every year the OIG ( Office of Inspector General) produces a report on what they plan to audit and review for the upcoming year. The new report does not take past items of interest off the table.

Here are some highlights for medical equipment suppliers:
1. They will review Accreditation Organization and their process for approving providers.
2. Service code modifier KX indicates the patient meets the medical criteria and upon request their is information that supports the medical need of the patient. In audits, they have found that providers have little to no documentation to support medical need. Make sure you read the medical records you obtain from physicians ordering services to ensure they include documentation that supports services you have provided.
3. In audits of lower limb prostheses, they have found in 267 providers audited no history of the patient having a lower limb amputation. I would recommend if you are providing prostheses, you obtain where the amputation was done. Medicare may not have documentation because it was not paid for by Medicare or change of physicians.
4. It appears they will be looking at reimbursement for several items and comparing it to other payor sources to see if they can reduce their reimbursement or frequency for items such as erect aids, back orthoses, parenteral nutrition, and CPAP (frequency).
5. Diabetic supplies will be reviewed for: a) see if medical records corroborate the IDDM as compared to NIDDM (making sure IDDM isn’t submitted just to bill for more supplies), b) multiple supplies, c) make sure supplies are not auto shipped, d) patients requests refill, e) the quantity of supplies left is documented at the time of request for refill, f) compares supplies provided to the competitive bid areas, g) see if “non-mail” order supplies were actually mailed, if they are in competitive bid areas, and h) IF supplies are mailed but KL not applies to indicate so the provider receives a higher rate of reimbursement.

If you have not started your compliance program audit and risk assessment protocol, these are some key areas to look at to reduce your business risk. Ask physicians to provide copies of medical records at the time of the order.

Remember, to look at the OIG Work Plan from 2012.  I outlined hightlights last year that you really need to review if you did not and continue to include those moving forward.

You may find the the OIG Work Plan details at https://oig.hhs.gov/reports-and-publications/workplan/index.asp and see Medicare Part I for Parts A & B.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller is Certified in Healthcare Compliance.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

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Medicare PrePay Audit for Oxygen and CPAPs for all MACs

As I understand it, all Oxygen and CPAPs in all Medicare MAC regions are on prepayment status.  This means you will be getting additional documentation or development request letters to provide documentation to support medical need prior to the claims being paid.  This evidently is being discussed in Mac Council Meetings this month.

How to do improve turnaround time?

You need to obtain all documentation, physician chart notes, date last seen initial and renewal (if applicable), and copies of test results at the time of the order intake and certainly PRIOR TO BILLING.  Waiting until the request is received puts your business in danger of missing the deadline due to the physician failing to see the importance of a timely response to the request for records.

What is your plan?

Have you diversified your business model with higher ratio of commercial payers?  If not and you want to increase to likelihood of sustaining prepayment audit while Medicare penalizes everyone in the industry with this prepayment plan you need to look at diversification.

If you have better ideas for fighting fraud and abuse beside penalizing everyone in the industry with prepayment audits, the Senate Finance Committee is seeking input from the healthcare community.  Speak up!

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.