ARLINGTON, Va.—AAHomecare’s Regulatory Council has its hands full this year. With ZPIC, RAC, CERT and medical review audits in play, oversight has never been so intense.
“It is the worst I have ever seen,” said Kim Brummett, Regulatory Council chair. “We have auditing bodies tripping over each other.”
The council met March 31 to focus specifically on audit activity and has identified inconsistencies in documentation requested by various Medicare audit contractors, Brummett said. Council members are currently developing recommendations on exactly what documentation should be requested by auditors for several product categories, including oxygen, CPAP, diabetic supplies, enteral nutrition, nebulizers and power mobility devices.
The goal is to ensure that all audit contractors request consistent documentation that is appropriate and specified under each Medicare coverage policy, said Brummett, vice president, contracting and reimbursement, for Advanced Home Care, High Point, N.C.
With no relief yet, Brummett said, the association is continuing education efforts with members of Congress, staff at CMS and the Office of Inspector General about the problems stemming from “unclear, inappropriate and overly complex” regulatory requirements.
“Instead of just fixing what we have, they just keep piling it on,” said Brummett, a 24-year veteran of the HME billing world. She noted proliferating medical reviews from the DME MACs and audits from CMS’ Program Safeguard Contractors/Zone Program Integrity Contractors, CERT (Comprehensive Error Rate Testing), RACs (Recovery Audit Contractors) and others. Where the ZPICs are concerned, she said, these contractors have the authority to look across a wide spectrum of services, and in many cases they are looking for indictments.
In some cases, providers may be subjected to pre-pay audits that can equal a near-death sentence, Brummett said.
“If an error rate is over a certain percentage, the carriers are going to do 100 percent pre-pay audit,” she said. “When providers get into 100 percent pre-pay audits, they can’t survive. Even the ZPICs are doing some 100 percent pre-pay audits, and in the next six months we will start to see people who are just closing their doors.” Brummett added that was already happening in some areas, including her own backyard in Charlotte, N.C.
Meanwhile, Brummett said the association council is also monitoring implementation of new anti-fraud provisions enacted under health care reform. These include additional provider screening measures such as application fees, licensure checks, site visits, fingerprinting and criminal background checks, as well as mandatory face-to-face exam requirements for DME.
There’s no shortage of additional topics on the watch list, she said, including modifications to the DMEPOS supplier standards, changes to coverage policies based on elimination of the use of least costly alternative, oxygen and CPAP policy and, of course, competitive bidding.
