The US Department of Health and Human Services, Office of Inspector General, released its 2013 work plan, which provides brief descriptions of activities to initiate or continue in fiscal year 2013, including forthcoming activities related to suppliers of durable medical equipment, prosthetics, orthotics, and supplies.
The work plan describes the primary objectives and provides for each review its internal identification code, the year the Office of Inspector General (OIG) expects one or more reports to be issued as a result of the review, and indicates whether the work was in progress at the start of the fiscal year or will be a new initiative during the year.
The following is a summary of the issues that will directly impact O&P.
Quality Standards — Accreditation of Medical Equipment Suppliers. The accreditation of medical equipment suppliers is a new quality standard that will examine accreditation organizations’ requirements and processes for granting accreditation to ensure that medical equipment suppliers meet each of Medicare’s quality standards. Medical equipment suppliers must become accredited by an accreditation organization approved by the Centers for Medicare & Medicaid (CMS) and must comply with quality standards to maintain their billing privileges. Validation surveys allow CMS to oversee accreditation organizations and determine whether an accreditation organization’s accreditation procedures adequately ensure that suppliers are complying with Medicare’s quality standards. This is a new initiative and its expected issue date is fiscal year 2014.
Program Integrity — Reliability of Service Code Modifiers on Medical Equipment Claims. This will determine the appropriateness of Part B payments that Medicare made on the basis of specific service code modifiers that suppliers entered on claims. Suppliers must provide, on request, the documentation to support the claims for payment that service code modifiers require. Payments to service providers are precluded unless the provider maintains and furnishes upon request the information necessary to determine the amounts due. This is a work in progress and its expected issue date is fiscal year 2013.
Program Integrity — Use of Surety Bonds to Recover Medical Equipment Supplier Overpayments. CMS’s use of surety bonds to recover overpayments made to medical equipment suppliers will be reviewed. OIG will determine the extent to which CMS maintains complete and accurate surety bond information for medical equipment suppliers, as well as determine the number of medical equipment suppliers with overpayment debt, the extent to which these suppliers had surety bond coverage and the amount of overpayment debt that could have been recovered through surety bonds since October 2009. Certain medical equipment suppliers must provide and maintain a surety bond of no less than $50,000. By requiring medical equipment surety bonds, CMS aims to limit fraud risk to Medicare by ensuring only legitimate suppliers are enrolled and to recoup overpayments resulting from fraudulent or abusive billing practices. This is a work in progress and its expected issue date is fiscal year 2013.
Lower Limb Prostheses — Supplier Compliance with Payment Requirements. To determine whether the requirements of CMS’s Benefits Policy Manual were met, the OIG will review Medicare Part B payments for claims submitted by medical equipment suppliers for lower limb prosthetics. Payments to service providers are precluded unless the provider has and furnishes upon request the information necessary to determine the amounts due. The expected issue date is fiscal year 2013.
Back Orthoses — Reasonableness of Medicare Payments Compared to Supplier Acquisition Costs. OIG will compare Medicare reimbursement amounts for the back orthosis procedure code L0631 with supplier acquisition costs to evaluate the reasonableness of Medicare’s spending. Back orthoses are supplied by Medicare medical equipment suppliers who purchase them from wholesalers or directly from orthotics manufacturers. This is a work in progress and its expected issue date is fiscal year 2013.
Competitive Bidding — Mandatory Review: OIG will perform a mandatory review of the process CMS used to conduct competitive bidding and to make subsequent pricing determinations for certain medical equipment items and services in selected competitive bidding areas under rounds one and two of the competitive bidding program. Federal law requires OIG to conduct post-award audits to assess this process. This is a work in progress and a new start and its expected issue date is fiscal year 2013.
