OIG Work Plan shines bright light on HME

WASHINGTON - The Office of Inspector General's 2011 Work Plan zeros in on some new HME targets, paying particular attention to competitive bidding, sleep and the National Supplier Clearinghouse.

"I think we are seeing a lot of instances of the OIG in its Work Plan looking to determine whether providers can justify the appropriateness of what they are doing, either from a clinical perspective or a documentation perspective," said industry attorney Neil Caesar.

The OIG investigates allegations of government fraud, waste and abuse. New areas that it will examine in 2011 include:

Competitive Bidding Program: Supplier Influence on Physician Prescribing

The OIG will review DME claims to determine the extent that providers participating in the program solicit physicians to prescribe products and services that are more profitable.

Industry attorneys do not think this is a big deal, but providers and physicians should put in place protocols to demonstrate that all equipment prescribed and provided is clinically necessary, they say.

Medicare Enrollment and Monitoring for Suppliers of DMEPOS

The OIG will investigate whether the NSC does everything in can to keep crooks from getting Medicare supplier numbers. This sounds reasonable, and the industry has regularly called for greater oversight of the NSC. But it could also cause major problems for legitimate providers, said industry attorney Clay Stribling, president of HC Comply.

"There is always the danger that pressure brought to bear on CMS or the NSC leads to restrictions on all providers," he said. "Do you really want an NSC that is going to be more restrictive and bureaucratic about technical details for compliant providers?"

Frequency of Replacement Supplies for Durable Medical Equipment

Preliminary OIG work shows that some HME suppliers automatically ship CPAP supplies with no physician refill order in effect. That's not good, and the OIG plans to sample claims to see if payments for supplies meet Medicare guidelines.

"I think the OIG is saying here what they said about diabetic supplies years ago: 'We're not going to allow any auto reshipping. We expect you to check with these patients, and we expect you to verify that they need this,'" Stribling said.

The OIG also intends to cover some familiar territory in 2011. Power wheelchairs and diabetes supplies (two big-ticket items) attract their share of attention. Respiratory drugs, lower limb prostheses and parenteral nutrition also come under the microscope.

To read the entire OIG 2011 Work Plan, go to: http://oig.hhs.gov/publications/workplan/2011