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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Physicians: Added Revenue for Assessments like Depression, ADD, BiPolar


Several months ago I met a representative from AssessMD.  I have observed and asked many questions.  AssessMD is a computer software that collects answers to questionnaires for assessments many physicians are doing manually now and not being reimbursed because the assessment is not scored.  AssessMD has assessments to score depression, bipolar, ADD, Anxiety, OCD, ODD,  and others with more test coming.  The patient completes the assessment in a few minutes on the physician’s computer or tablet, and produces scored results for the physician in real time.  The physician can then bill for this assessment in addition to the Evaluation and Management Code (E&M) with the documentation provided by this computerized assessment.

Medicare is now requiring annually assessment for depression among the elderly patients.

This is reimbursed by most insurance companies except certain Medicaid.  The reimburse on average is about $60, which would go direct to the physician’s bottom-line because right now if it is handwritten assessment it is not reimbursed.

The physician has a 45 day trial period to test it in his practice.   If you are not reimbursed by the insurance company, there is no charge of the test to the provider.  As a note, AssessMd is not in a position to be a referral stream only a vendor.

This was initially marketed to limited physician practice types, but they have discovered that it is beneficial to many practice areas pain management, obstetrics/gynecology, elder care, and adolescents to name a few.

At the very least it is worth the time to investigate and discuss with your legal counsel to add revenue to the practice.  If you do not have healthcare counsel, click for a list of affordable healthcare attorneys to ensure this is the right model for your practice.

Contact LouAnn McNaughton  at  “214*538*1123”  or   “LouAnn@assessMD.com”

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.

Happy Holidays!


Warm Holiday Wishes to You

Happy Holidays!  May you be blessed with the riches of life.  As we wind down the year, the holidays are a time to spend with friends and family sharing joy, laughter, and love.  The holidays are also a time of reflection and gratitude.  I want to thank each of you for making this a successful happy year, it has been a true gift in my life.  So many of you are friends, business advisers, business partners, clients, and maybe all of these, but you are truly appreciated.  Some of you make me reflect more often than I might like but I’ll keep you anyway..LOL.  I wish each of you a happy and safe holiday that is a road to a successful new year for you, your family and business.   I look forward to you being a part of my life in 2011 too.

Remember to pray for our soldiers and their families during the holidays, and if you see them during travels thank them.

PECOS: Uncover the mystery! Extended 1/3/2011


**NEWS FLASH** Found at least one gov’t contract with an extension notice of Jan 3, 2011 posted!

What is PECOS? Basically, this is an online 855 application process which is also linked to NPPES (NPI database).  The official name  is Medicare Provider Enrollment Chain and Ownership System.

Where did the info in PECOS come from? They uploaded (in some fashion) from the fiscal intermediary that processes your 855 paper enroll applications.

Why do I need to bother if they have the information from 855? The information in many circumstances is inaccurate and it can stop your cash flow reimbursement.  My guess is, as with any software or data conversion, exceptions to eliminate terminated data were not built in sufficiently.  So, with that said, it is very possible information is incorrect which can result in revoked provider number. For example I recently worked on a provider’s PECOS records that showed locations that have been closed for several months. If the Medicare contractors visit locations or call a phone number that is no longer valid including an invalid area code, they can suspend or revoke the provider number.

You must register in PECOS.  This means you must obtain a username and password in PECOS to review and validate all your information.  Before you begin view and print (save to complete) the 855 they show. You may need copies of your previously submitted 855’s. If you did not keep a copy, do so for all applications in the future.  You can save the information and go back to finish if need be.   Do not click “begin submission” until you are 100% certain you are finished.  Any changes will require a “submission” then you must print out the certification documents for signature to submit hard copy to the address that prints on confirmations.

Do not let incorrect information or failure to register in PECOS stop your PESOS (Cash Flow).  Register deadline for PECOS by UPDATED**7/6/2010 or 1/1/2011 (depending on what article you read) will stop your Medicare payments also.   ADDED**This is the latest note I found on CMS’ website “July 6: Please read the news release found at the following location http://www.cms.gov/apps/media/press/release.asp?Counter=3774 , the January 2011 deadline was superseded by a statutorily established deadline in the Affordable care act. As soon as a firm enforcement date of the regulations has been determined we will announce it.”

This is not going away.  It will take 1-1.5 hours to gather corporate and provider documents.  It will take about 2 hours per provider record to review documents, data, make corrections, make necessary copies of documents, sign and mail.

I have provided a list of numerous documents that you should have available for this as well as site visits.  I recommend maintaining all the important records in a three ring binder to be handy for site inspectors.

If you need help getting this done, we can help with this project.  We will register you, save all log in data for you, save the existing PECOS record, make necessary updates based on the documents provided, save revised document, print all certification forms to PDF.  All documents will be password protected and returned to you by email for $289.00 per provider number.  We can overnight the certification pages and a CD with all documents back to you for an extra $30.00 for all provider records being returned.  Please contact us so that we may sign a confidentiality contract.

PECOS  CHECKLIST

  • Sale purchase agreement, if applicable
    • Asset acquisitions require a new provider number
    • Also note, Home Health Agencies with a provider number less than 36 months old will require a new provider number also
    • Were the state and local agencies informed of the acquisition?
  • State Licensure such as pharmacy license, DME/HME License, typically health care business line specific, if applicable
  • Local- state licenses such as occupancy or business licenses
  • Copy accredit certificate (DME, HHA,
  • IRS 147C letter
  • NPI letter/email
  • Any Adverse Action
  • Director of Nursing/Administrator license
  • Medical MalPractice Insurance Certificate
  • Liability Insurance Certificate must have correct location address on it for minimum $300K
  • HHA: Documentation to demonstrate capitalization requirements
  • Board of Directors, Owners with 5% or more, Manager (w-2), clinical provider Information:
    • Full Name
    • Social Security Number
    • Date of Birth
    • In some states, like FL &CA, finger print cards are required for the mentioned
  • If owned by another company or venture capital company:
    • Need the company(ies) TID#
    • Corporate Business Address
  • If complex ownership, please provide an organizational chart of ownership even if handwritten.

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.

Patient Visits: Changes, Increase Revenue, & Ordered Services


“15 MINUTE THOUGHT”

New Patient Visit Requirements: Increase Your Revenue

MAS is pioneering an informational program that you can listen to over a cup of coffee while you organize your day or on your drive to work. The name of the program is “15 Minute Thought”.  These calls will be free and informative.  Our focus is to give you a new thought once per month to help improve your business during these tough regulatory times.  The call participation should be maintained although CME/CEUs are not attached, it documentation of education efforts.

We will discuss health care reform changes that impact the requirements for patient visits, date last seen, and chart documentation.  We will discuss how to make lemonade out these lemons!  We need to cease the opportunity to increase revenues out of these changes.  Spend 15 minutes and learn about changes that can stop your payments as well as how to increase your revenue.

Program your Phone and Calendar:

The 2nd* and 3rd Wednesday Every Month

July 21, 2010  at 8:30am-8:45am CST

Speaker:          Angela Miller, CHC, Compliance & Billing Expert & Edward Vishnevetsky of Thompson Coe

MAS Conference Call Dial-in#:         218-862-1300

Conference Code:                               622911

MAS Office number:                          972-459-1508

Who should call in?

All health care provider, Health care business owner or manager, Physicians, Home Health, DME, HME, Attorneys, Compliance Officer, and Office Managers

Follow MAS Blog for Schedule & Updates.  You can “follow” MAS on all social media and new blog links are published.  We only publish useful information and breaking news.

Blog:  http://www.angelamillermas.wordpress.com or via website
Linkedin:  http://www.linkedin.com/in/medicalauditingsolutions
Facebook:  http://www.facebook.com/home.php#!/AngelaMiller.MAS

Edward L. Vishnevetsky has extensive experience in the area of health law and commercial litigation. He routinely argues before state and federal courts in areas of health law, employment law, and complex commercial litigation, and also represents hospitals, physicians, durable medical equipment (DME) providers and manufacturers before various state and federal regulatory agencies. Edward advises health care clients on operational matters, liability exposure, privacy issues, federal and state health care regulatory compliance, health care reimbursement disputes, as well as risk management issues. He has represented individuals, physician groups, hospitals, ambulatory surgery centers, sleep laboratories, dialysis clinics, independent diagnostic testing facilities, and DME suppliers.

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.

Bankruptcy Attorneys & other Attorneys: What you need to know about Medical Receivables 7/14/2010


“15 MINUTE THOUGHT”

***REMINDER***

What you Need to Know about Medical Receivables

MAS is pioneering an informational program that you can listen to over a cup of coffee while you organize your day or on your drive to work. The name of the program is “15 Minute Thought”.  These calls will be free and informative.  Our focus is to give you a new thought once per month to help improve your business during these tough regulatory times.  The call participation should be maintained although CME/CEUs are not attached, it documentation of education efforts.

We will discuss key points that you need to know when managing a corporate bankruptcy.  Your goal is to collect as much of the receivables as possible to pay off creditors.  One very very critical thing is, insurance payers do not wait for the court system.  Tune in so we can help you improve your collection rates.

Program your Phone and Calendar:

The 2nd* and 3rd Wednesday Every Month                July 14, 2010  at 8:30am-8:45am CST

Speaker:                                                Angela Miller, CHC & Compliance & Billing Expert

MAS Conference Call Dial-in#:     218-862-1300

Conference Code:                               622911

MAS Office number:                          972-459-1508

Who should call in?

All Attorneys and specifically Bankruptcy Attorneys

Follow MAS Blog for Schedule & Updates.  You can “follow” MAS on all social media and new blog links are published.  We only publish useful information and breaking news.

Blog:  http://www.angelamillermas.wordpress.com or via website
Linkedin:  http://www.linkedin.com/in/medicalauditingsolutions
Facebook:  http://www.facebook.com/home.php#!/AngelaMiller.MAS

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.

“15 Minute Thought” Schedule – Free Informational Programs


“15 MINUTE THOUGHT”

MAS is pioneering an informational program that you can listen to over a cup of coffee while you organize your day or on your drive to work. The name of the program is “15 Minute Thought”.  These calls will be free and informative.  Our focus is to give you a new thought once per month to help improve your business during these tough regulatory times.

Program your Phone and Calendar:

The 2nd* and 3rd Wednesday Every Month                 at 8:30am-8:45am CST

* Indicates specific audience

MAS Conference Call Dial-in#:         218-862-1300

Conference Code:                               622911

MAS Office number:                          972-459-1508

MAS Fax:                                               214-461-0295

Who should call in?

Any health care provider, Health care business owner or manager, Attorneys, Compliance Officer, and Office Managers

Schedule & Topics

July 14, 2010               Bankruptcy Attorneys & other Attorneys:  What you need to know about Medical Receivables*

July 21, 2010               Patient Visits: Changes, Increase Revenue, & Ordered Services

August 11, 2010         Physicians: NP & PA Visits: Can the non-physician provider be billed under the physician?*

August 18, 2010         Payer Audits Giving “RAC’d” a Whole New Meaning: Tips to Manage Audits

September 8, 2010      Conflict of Interest: Pay Attention or Write a Big Check

September 15, 2010    Compliance Officer:  Who? What? …Really?

October 13, 2010        Dental Providers:  Reform & Common Audit Errors*

October 20, 2010        Reserve Chute: Not just for jumping out of planes

There will be guest speakers.  We will release the brief description of the call within the next 24 hours.  There are plans to have Edward Vishnevetsky of Thompson Coe, Darrell Armer of Looper Reed & McGraw, David Reimer of Dental Medical Economics as well as others guest such as Advocate, MD present over the next few months as we roll this program out.  You will hear thoughts from some of the best in the health care industry.  The guest schedules are not finalized and they may participate in programs setup on this schedule.  We may increase the number of calls depending on the attendance.

Follow MAS Blog for Schedule & Updates.  You can “follow” MAS on all social media and new blog links are published.  We only publish useful information and breaking news.

Blog:  http://www.angelamillermas.wordpress.com or via website
Linkedin:  http://www.linkedin.com/in/medicalauditingsolutions
Facebook:  http://www.facebook.com/home.php#!/AngelaMiller.MAS

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.  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.