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CMS recently completed a series of upgrades to their website that may affect bookmarked links. If you bookmarked a sub-page on the old CMS website, you will be redirected to the new index page for that particular topic. From there, you may access a specific subtopic from a list on the left-hand side of the page and create a new bookmark. For example, if you previously bookmarked the page containing a list of annual Comprehensive Error Rate Testing Contractor (CERT) audit reports, you will now be taken to the main index page for information related to the Comprehensive Error Rate Testing Contractor and will need to click on the “CERT reports” link.
If you are a regular visitor of our site, you may have noticed that we’ve recently had a minor facelift. MiraVista is proud to announce the launch of a new logo that symbolizes our commitment to keeping our clients’ businesses moving forward.
The logo is the brainchild of managing member Derrick Stark, who drafted the initial design. “We aren’t the same company we were nine years ago,” Stark said. “It was time for a change.”
Managing member and DME consultant Andrea Stark agrees. “Like many businesses, our organization has evolved and grown over the years. We needed a logo that better reflects where we are now.”
While we may have a new look, MiraVista will continue to provide suppliers with the same high caliber of educational and billing services they have come to rely on. Be sure to look for our new logo in future marketing materials and educational initiatives!
How to Protect Yourself Against Hiring Employees Excluded From Participating in Federal Healthcare ProgramsWednesday, March 7th, 2012
Did you know that if you hire any employee or contract with an entity that has been excluded from participating in a Federal healthcare program, that it could cost you tens of thousands of dollars in fines?
In addition to imposing civil money penalties (CMPs), the Office of Inspector General (OIG) has the authority to exclude any individuals and entities who have engaged in fraud or abuse from participation in Medicare, Medicaid and other Federal healthcare programs. Per the OIG:
- The practical effect of an exclusion is to preclude employment of an excluded individual in any capacity by a health care provider that receives reimbursement, indirectly or directly, from any Federal health care program.
- No Federal payment may be made for any items or services furnished by the excluded individual or entity, even if the payment is being made to another non-excluded provider or supplier.
- In addition, payment may not be made for items and services prescribed by an excluded physician.
Also per the OIG, if you employ an excluded individual while providing services to patients under a Federal healthcare program, you could face:
- A civil money penalty of up to $10,000 for each item or service furnished by the excluded individual or entity and listed on a claim,
- An assessment of up to three times the amount claimed, and
- A possible exclusion from program participation (i.e. Medicare).
For liability to be imposed, current statute requires that the supplier knew or should have known that the employee or entity was excluded. But, it is the OIG’s stance is that suppliers have a duty to check the exclusion status of an employee or contractor before entering into a relationship, or else run the risk of CMP liability.
With fines and revocation of billing privileges at stake, it is not worth the risk to hire someone without performing a check. Additionally, we recommend a retroactive check on existing employees if you have not screened them previously. To protect yourself against entering into a relationship with an excluded individual or entity, take a moment to search the OIG’s Exclusion Database, also known as the List of Excluded Individuals/Entities (LEIE). In addition to potential employees and vendors, be sure to screen each of your current employees for possible exclusions. The database is free, easy to use and is available here: http://exclusions.oig.hhs.gov/.
Below are some tips to keep in mind when searching the OIG’s Exclusion Database:
- You can search for up to 5 names at one time.
- Remember to screen all owners, managers and officers within the company.
- In addition to the employee’s current name, be sure to screen for aliases (i.e. nicknames like Charlie instead of Charles), hyphenated names and maiden names.
- For a broader search, type in the first few letters of the last name, with no first name.
- Don’t rely solely on the address or occupation listed to verify a match. The person may have moved and obtained a different position.
- If you locate someone you believe may be an employee, you can verify if they are the same person by clicking on the name and entering the employee’s social security number.
For more information on OIG exclusions see:
As discussed in yesterday’s blog, the Jurisdiction A DME MAC, NHIC, will no longer be issuing paper Acknowledgement Letters for redetermination requests effective April 1, 2012 – a trend that seems to be catching on. In another list serve released by the Jurisdiction D DME MAC, NAS announced that it too plans to eventually eliminate mailing paper Acknowledgement Letters as suppliers begin to utilize its Endeavor (a web-based alternative to calling the Jurisdiction D IVR) and IVR systems to verify the receipt and status of appeals.
Note: This change does not impact decision letters, only the acknowledgement letters sent to confirm your appeal was received.
Beginning yesterday, February 29th, suppliers in Jurisdiction D may obtain the status of an appeal by calling the MAC’s IVR and selecting the appeals menu option. You must wait at least 10 days from date your appeal is received for it to be uploaded into the IVR system and will need the following information to access the status of your appeal:
- Your National Provider Identifier (NPI)
- Your Provider Transaction Access Number (PTAN)
- The last five digits of your Tax Identification Number (TIN)
- The patient’s Medicare number
- The patient’s name as it appears on their Medicare card
- The 14-digit claim control number (CCN). This can be found on your remittance advice in the Internal Control Number (ICN) field.
NAS has not specified the exact date it plans to discontinue mailing Acknowledgement Letters; however, we don’t expect it to be too far down the road. Information on how to use the IVR to check on the status of an appeal is available on the NAS website here.
As technology improves and the push towards electronic health records progresses, we will likely see a reduction in the number of paper statements/letters mailed by contractors and a shift towards electronic communications. The latest example of this comes from the Jurisdiction A DME MAC, NHIC, which recently announced that they will no longer issue hard-copy Acknowledgement Letters when redetermination requests are received.
Effective April 1, 2012, suppliers in Jurisdiction A will need to call the MAC’s IVR system to check on the status of a redetermination request. According to the MAC, suppliers should wait at least 10 days after submitting their request for it to be received and uploaded into the IVR system. If you call the IVR 10 days after submission and are unable to locate your request, you should call NHIC’s customer service line at: 1-866-590-6731. Per NHIC, if a redetermination request is determined to be a reopening issue, it will be reassigned in the system as a pending reopening case.
Instructions on how to use the IVR to check on a redetermination request are available in the DME MAC A IVR User Guide at:
The Competitive Bidding Implementation Contractor (CBIC) recently published a series of webcasts to assist suppliers in submitting their bids for Round 2 of Competitive Bidding and the national mail-order diabetic supplies program. The bid window opened on January 30, 2012 (click here for info on other critical dates).
Webcast topics include:
- An overview of the Round 2 and national mail order competitions (published 12/20/11)
- A webcast specific to the national mail order program for diabetic supplies (published 01/09/12)
- Important program rules outlined in the Request for Bids (RFB) Instructions (published 01/13/12)
- How a bid is evaluated (published 01/20/12)
- Details on financial documentation requirements (published 01/25/12)
- How to submit a bid (published 01/27/12)
The webcasts are free and available for viewing 24 hours a day, 7 days a week. In addition, a DBidS reference guide is also available to assist suppliers in using the online system to place their bids.
Today, January 30, 2012, marks the official opening of the bid window for Round 2 of Competitive Bidding. Suppliers who wish to compete in Round 2 and/or the national mail-order competition for diabetic supplies may now log into DBidS (CMS electronic online bidding system) and place their bids. A reference guide to assist you in placing your bid is available here.
Now that the bid window has opened, suppliers who wish to submit a bid must be mindful of the following critical deadlines:
- If you have not already done so, you only have 10 days left to register your authorized official (AO), backup authorized official (BAO), and any end users (EUs) who will be submitting bid information on your behalf. Users must register through CMS’ IACS system for a DBidS user ID and password. The registration window will close at 9pm EST on February 9, 2012. If your AO has not completed the registration process by this date, you will not be able to bid.
- In order to be considered, your final bid must be in the DBidS system before 9pm EST on March 30, 2012, at which time the bid window will close.
- All required financial documentation for your bid must be receivedby the CBIC in hardcopy form no later than March 30, 2012.
- February 29, 2012 is the covered document review date (CDRD). While you technically have until March 30th for the CBIC to receive required financial documents, if you would like to have your documentation reviewed for missing information, your packet must be received by the CBIC by February 29, 2012. Suppliers whose hardcopy documentation is received by 11:59pm EST on Feb. 29th will be notified of any missing financial documents within 90 days of the CDRD and given 10 additional days to submit the missing information.
Look for more details on what types of financial documents the CBIC will be looking for and how your documentation must be submitted in the upcoming February 2012 issue of Vista Notes.
MiraVista has just released the first issue of a brand new newsletter geared specifically towards your DME billing department!
We call it, The Vibe.
The 2-page newsletter contains short synopses of current billing news and tips, and is designed to be easily read and quickly digested.
Have a question you’ve been meaning to get an answer to? Ask the Expert! Each issue of The Vibe features an “Ask the Expert” column, where suppliers have the opportunity to submit questions and receive answers directly from our professional staff of billing experts.
And did we mention it’s FREE?!
By coupling The Vibe with a Vista Notes subscription, you can be sure that your billing staff, managers and owners are always up to date on the ever changing DME industry.
We’d love to hear your first impressions! Comments on the new publication may be sent to: email@example.com.
CMS has released the January 2012 Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) reimbursement fee schedule. CMS updates the fee schedule twice a year, in January and July. In addition to Medicare, many other health plans like TRICARE use the reimbursement rates established in the DMEPOS Fee Schedule to set their allowed amounts.
If you would like to lookup reimbursement rates by HCPCS code, the new fee schedule has been uploaded to the PDAC website at: https://www.dmepdac.com/dmecsapp/do/search. You may also download a complete CSV file of all HCPCS codes and their corresponding allowables at: http://www.cms.gov/DMEPOSFeeSched/LSDMEPOSFEE/list.asp#TopOfPage (Download DME12_A).
In addition to fee schedule changes, the 2012 update also includes:
- An average 3.6% increase to the allowed labor payment rate for HCPCS K0739, L4205, and L7520;
- A new maintenance and servicing fee of $67.51 for capped oxygen concentrators and transfilling equipment (previously $65.93) – eligible to be billed once every six months, beginning six months after the equipment caps.
- A new rental payment amount of $176.06 for stationary oxygen equipment (previously $173.31).
- New, revised and deleted HCPCS effective January 1, 2012.
Full details on all of the changes and updates contained within the 2012 DMEPOS fee schedule are included in the December 2011 issue of Vista Notes. If you are not currently receiving Vista Notes, you may subscribe here.