Industry to senate: Make these changes

Friday, August 24, 2012

Among the white papers submitted by DME providers, there were several common recommendations, including:

• Competitive bid winners should not be automatically audited because of increased claim submissions;

• CMS should promulgate objective criteria/benchmarks established to define how and why a provider is placed on prepayment audit, and how a provider can be removed from prepayment audit;

• CMS should reinstitute CMNs for all equipment or create standardized forms for physicians to fill out that establish medical necessity;

• Suppliers should be allowed to respond to beneficiary/former employee complaints that lead to an investigation;

• CMS should educate physicians on information that must be in a patient’s file or progress note to establish initial and continued medical need and continued use;

• Suppliers should not be required to second-guess a physician’s medical opinion to establish medical necessity; and

• Auditors should not be able to deny claims that have received advance determination of Medicare coverage (ADMC) approval by the DME MAC.