An audit crystal ball
HME providers often gripe that they need a crystal ball to foresee where Medicare audits might go next.
But there’s something even better than a crystal ball, says Denise Fletcher, a healthcare attorney with Brown & Fortunato: CMS leaves plenty of clues providers can use to anticipate future audits.
Fletcher will share her tips for navigating audits and the difficult appeals process at Medtrade, and offered this first glance.
HME News: What’s the audit climate like right now?
Denise Fletcher: The right hand doesn’t seem to know what the left hand is doing. Sometimes they’ll ask for documentation on the same claim. One of my clients had an extrapolated overpayment, and the ZPIC should have put it into the RAC warehouse to prevent a RAC from looking at the claims. They didn’t do that, so my client was getting an audit from the RAC on claims he was already making payments to. It’s very frustrating.
HME: What’s one of the tips you’ll provide at Medtrade?
Fletcher: I will talk about how to stay a recoupment. They cannot collect an overpayment until the second level of appeal. But you have to file the appeal, and they have different deadlines for that. If you want to stop them from offsetting a post-payment audit at redetermination, you have to file at 30 days instead of 120 days. They’ve shortened that timeframe.
HME: You say that CMS leaves clues about where audits will go next. What’s an example?
Fletcher: The OIG work plan comes out every October. This is their roadmap for the coming year. If they say they are going to be looking at oxygen, that tells me I should be doing an internal audit on my oxygen qualifications. There’s no such thing as a random audit. They won’t waste their time and money.