Based on OIG recommendations suggesting the Medicare program overpaid more than $90 million for 2017 nebulizer claims, CMS is asking certain DME suppliers, under the administrative authority bestowed by the 60-Day Overpayment Rule, to perform a self-audit of six years worth of claims. Once results are tabulated, CMS expects voluntarily refunds of any overpayments.
Every supplier should be troubled.
In a report issued by the OIG in October, the agency looked at 2017 claims for nebulizer medications. Medicare processed a total of 2.3 million claim lines for nebulizer medications in the time period analyzed, but the OIG only reviewed 120 of these from 65 different suppliers. 43 of the suppliers submitted 81 error free line items. The remaining 22 suppliers submitted 39 line items with errors. The OIG sample reviewed 0.005% of the claim population, but based on extrapolation the agency suggests the program overpaid suppliers by $92.5 million.
Such a small sample should not be considered credible in the context of the claim universe or even for the individual suppliers. Nonetheless, CMS is imposing a huge administrative burden with high costs by leaping to unsubstantiated conclusions and imposing the six-year lookback.
This is the second time CMS imposed self-audit requirements in the DME space. In June of 2018, the OIG looked at 110 out of 7 million PAP resupply claims (0.00157%). The OIG found 86 errors from 82 different suppliers (roughly one claim per supplier) totaling $13,414. By extrapolating the error rate, the OIG suggests there is as much as $631 million in overpayments to be recovered.
Not for nothing, this fascism doesn’t appear limited to DME providers. In an OIG report issued in June 2019, the OIG looked at 426 of 2 million polysomnography claims (0.02%). The OIG found 150 errors from 117 different providers (a little more than one claim per provider) totaling $56,668. The OIG recommended CMS notify the 117 providers of the overpayments in accordance with the 60-day rule, and once again, CMS obliged.
Aside from the obvious credibility concerns, more troubling by far is CMS’s blind application of the sanction before suppliers can contest the accuracy of the OIG findings or pursue their due process under the five levels of Medicare appeals. Nonetheless, this new trend is becoming the norm.
SOURCE LINKS
https://oig.hhs.gov/oas/reports/region9/91803018.pdf
https://www.govinfo.gov/content/pkg/FR-2016-02-12/pdf/2016-02789.pdf
Every supplier should be troubled.
In a report issued by the OIG in October, the agency looked at 2017 claims for nebulizer medications. Medicare processed a total of 2.3 million claim lines for nebulizer medications in the time period analyzed, but the OIG only reviewed 120 of these from 65 different suppliers. 43 of the suppliers submitted 81 error free line items. The remaining 22 suppliers submitted 39 line items with errors. The OIG sample reviewed 0.005% of the claim population, but based on extrapolation the agency suggests the program overpaid suppliers by $92.5 million.
Such a small sample should not be considered credible in the context of the claim universe or even for the individual suppliers. Nonetheless, CMS is imposing a huge administrative burden with high costs by leaping to unsubstantiated conclusions and imposing the six-year lookback.
This is the second time CMS imposed self-audit requirements in the DME space. In June of 2018, the OIG looked at 110 out of 7 million PAP resupply claims (0.00157%). The OIG found 86 errors from 82 different suppliers (roughly one claim per supplier) totaling $13,414. By extrapolating the error rate, the OIG suggests there is as much as $631 million in overpayments to be recovered.
Not for nothing, this fascism doesn’t appear limited to DME providers. In an OIG report issued in June 2019, the OIG looked at 426 of 2 million polysomnography claims (0.02%). The OIG found 150 errors from 117 different providers (a little more than one claim per provider) totaling $56,668. The OIG recommended CMS notify the 117 providers of the overpayments in accordance with the 60-day rule, and once again, CMS obliged.
Aside from the obvious credibility concerns, more troubling by far is CMS’s blind application of the sanction before suppliers can contest the accuracy of the OIG findings or pursue their due process under the five levels of Medicare appeals. Nonetheless, this new trend is becoming the norm.
SOURCE LINKS
https://oig.hhs.gov/oas/reports/region9/91803018.pdf
https://www.govinfo.gov/content/pkg/FR-2016-02-12/pdf/2016-02789.pdf