WASHINGTON, D.C. (July 22, 2020)—The Centers for Medicare & Medicaid Services (CMS) recently announced in the Coronavirus Disease 2019 (COVID-19) Provider Burden Relief Frequently Asked Questions (FAQs) that the suspension of Medicare fee for server (FFS) audits due to the COVID-19 public health emergency will be lifted beginning Aug. 3, 2020 (see page 1). Due to state reopenings and the importance of program integrity, CMS will be restarting reviews from Medicare Administrative Contractors (DME MACs), Recovery Audit Contractor (RAC), and Supplemental Medical Review Contractor (SMRC) that were previously suspended in March 2020.
In a recent conversation with CMS, the American Association for Homecare (AAHomecare), and advocacy and policy group for the home medical equipment and durable medical equipment (HME/DME) industry, shared industry concerns with this announcement. With many offices still closed and COVID-19 cases increasing, suppliers will have difficulty responding to audit requests. While the public health emergency is still in place, the priority for suppliers is on providing care to patients and suppliers should not be incumbered by large volumes of audits. CMS understood these concerns and to ease the burden on suppliers, CMS clarified that audit activity will not fully resume on August 3. To accommodate suppliers, audits will begin with DME MAC post-pay reviews which will allow for more flexibility than pre-pay reviews and will not hold up payments to suppliers. CMS shared that Targeted Probe and Educate (TPE) audits are not included in this roll out of audits and at this stage, there is no timeline for TPEs to be restarted. DME MACs may allow extensions and the cancelling of an audit based on a supplier’s ability to complete the audit. Currently, there is also no timeline set to restart RAC or SMRC audits.
CMS also shared that audits would start on a delayed timeframe and suppliers should not expect audit requests on August 3. CMS indicated that DME MACs will not be auditing claims started during the crisis at this point. The DME MACs will be pulling claims from sometime prior to March 1, 2020. CMS is tracking state and county-level COVID-19 case data and sharing this information with the MACs to be taken into consideration.