Durable Medical Equipment ("DME") Suppliers Subject to RAC Audits
The Recovery Audit Contractor ("RAC") program will be operating in numerous states this year, and will be nationwide by 2010. Durable Medical Equipment ("DME") suppliers nationwide should prepare now for increased scrutiny of their Medicare claims, as the Centers for Medicare and Medicaid Services ("CMS") has announced its intention to focus audit activities upon DME suppliers and Home Health Agencies ("HHAs").
Although the areas that will be subject to review during the RAC program cannot be predicted with certainty, reviewing the categories of claims denied during the RAC demonstration program, and reviewing other CMS guidance, can assist DME companies to determine potential areas of RAC scrutiny.
During the RAC demonstration program, many DME supplies were denied because the items were supplied during a beneficiary's inpatient admissions or Skilled Nursing Facility ("SNF") stay. This will likely remain an area of Medicare scrutiny as the RAC program expands nationwide.
Other CMS areas of focus for DME suppliers include, but are not limited to, the following:
- DME payments for beneficiaries receiving Home Health Agency ("HHA") services;
- Medicare Part B payments for home blood glucose testing supplies;
- Appropriateness of reimbursement for pressure-reducing support surfaces; and
- Appropriateness of reimbursement for power wheelchairs.
DME suppliers must prepare now for increased Medicare scrutiny of these and other types of claims.
Wachler & Associates, P.C., has represented providers, suppliers and other healthcare entities subject to Medicare audits and claim denials for over 20 years. During the RAC demonstration program, our firm successfully represented numerous entities with their appeals of claim denials and overpayment determinations.
Publications
"Audit Impact: Expanded Liability for Overpayments," Andrew B. Wachler, Esq. and Jennifer Colagiovanni, Esq.,The RAC Monitor, July 2011.
"Weathering a Medicare Audit: Overview of the Medicare Appeals Process," Andrew B. Wachler, Esq. and Jennifer Colagiovanni, Esq., MGIS Talking Points Newsletter, Vol.2 No. 3, June 23, 2011.
"Contractor Involvement in the Medicare Appeals Process," Andrew B. Wachler, Esq. and Jennifer Colagiovanni, Esq., The RAC Monitor, June 13, 2011.
"One Year Later The Impact of Health Care Reform on Health Care Provider Audits and Compliance Programs," Andrew B. Wachler, Esq., Jennifer Colagiovanni, Esq., and Christopher J. Laney, Esq., Michigan Bar Journal, June 2011.
"RAC Medical Necessity Denials of Inpatient Services - Fair & Equitable Reimbursement," Andrew B. Wachler, Esq., The RAC Monitor, April 21, 2011.
"The Use of Payment Suspensions in the Audit Landscape," Amy K. Fehn, Esq. and Jennifer Colagiovanni, Esq., The RAC Monitor, March 24, 2011.
"Prepare for Increased RAC Activity in 2011," Andrew B. Wachler, Esq. and Jennifer Colagiovanni, Esq., Wachler & Associates, The RAC Monitor, December 7, 2010.
Speaking Engagements
"RACs, ZPICs, and More - The Latest Improper Payment Initiatives for Governing Audits," MGMA Webinar regarding Recent Proper Payment Initiatives, May 12, 2011.
"Preparing for and Surviving a Third Party Payor Audit," Indiana Medical Society in Merrillville, IN, April 27, 2011.
"The New Landscape of Audits: MICs, MACs, RACs and ZPICs" co-presented with Susan Emanuel, System RAC Coordinator, Catholic Healthcare West, Phoenix, AZ; and Dawn Crump Network Director of Compliance, SSM Health Care St. Louis, Orlando, FL, HCCA's 15th Annual Compliance Institute, April 13, 2011.
"Medicaid RAC Appeals - Similarities and Differences with Medicare RAC Requirements and Processes," 5th Annual Medicare RAC Summit, Washington, D.C., March 9-11, 2011.
"Full Steam Ahead: Latest Developments in Medicare and Medicaid," co-presented with James G. Sheehan, Office of the New York State Medicaid Inspector General, American Bar Association (ABA) Emerging Issues Conference, New Orleans, LA, February 23-25, 2011.
"Medicare and Medicaid Audits: A Year in Review," American Health Lawyers Association (AHLA) Hospital and Health Systems Law Institute, Las Vegas, NV, February 11, 2011.
Please click here for a more complete listing of our attorneys' publications and speaking engagements.
Contact Us
Call us at 877-403-6048 or send us an e-mail to schedule a meeting to discuss your concerns with RACs or to address your other healthcare law-related needs.
