WASHINGTON, D.C. (October 4, 2018)—In June 2018, the Office of Inspector General for the Department of Health & Human Services reported that most Medicare claims for replacement positive airway pressure device supplies did not comply with Medicare requirements. A sample of 110 claims were reviewed, and 86 did not meet the requirements, totaling $13,414 in overpayments.
Recently, AAHomecare learned that Noridian and CGS have sent letters to the CPAP suppliers associated with these overpayments. In the letter, Noridian and CGS notify suppliers that their claims were flagged due to the OIG report and requests suppliers to conduct a self-audit within 180-days. If suppliers identify overpayments, suppliers then need to contact their MACs within 60-days after the review to either adjust the claim, send a check for the overpayment amount, or negotiate a repayment plan.
AAHomecare recommends suppliers who received a letter from Noridian or CGS to properly self-audit and respond. The self-audit may be conducted by third-party consultants that have expertise in managing this type of work to combat extrapolated overpayments and extrapolations for voluntary refunds or Corporate Integrity Agreements. Suppliers may wish to consult with their counsel on the extrapolation process.
Also in the June 2018 report, the OIG noted that CMS oversight for replacement PAP device supplies was insufficient to ensure compliance and prevent problem payments. The larger Medicare program impact was estimated at that time to be around $631.3 million over a two-year period, according to the OIG.
Previous OIG reviews found that Medicare allows replacement of PAP device supplies more frequently than what is reasonable and necessary. CMS planned to address the problems.