Stand up to physicians
Just before we went to press with this issue, I listened to an "ask-the-contractor" teleconference for HME providers on CMS's comprehensive error rate testing program (CERT). The DME MACs hosted the teleconference as part of a new education initiative. They planned to walk HME providers through the CERT process and review frequent errors. What they got: an earful from HME providers who wanted to know why they're on the hook if physician documentation isn't up to snuff.
HME providers asked a similar question a few months ago during an Open Door Forum when CMS's Provider Enrollment, Chain and Ownership System (PECOS) came up. They wanted to know why they're on the hook if physicians don't register with the system before April 5. (After that date, Medicare will begin denying an HME provider's claims for equipment if it was prescribed by an unregistered physician).
On the one hand, I can see where HME providers are coming from. It's not easy to tell anyone to do anything, let alone a physician. The reality is there's a hierarchy in the healthcare industry (like all other industries), and HME providers aren't in the same league as physicians. HME providers know this; one provider who spoke out during the "ask-the-contractor" teleconference summed it up this way: "Who are we to question what the physician is putting in the patient's chart?"
On the other hand, I can see where Medicare's coming from. Who do you think is better equipped to make sure documentation is up to snuff: an HME provider who bills for equipment dozens of times a day and relies on reimbursement for that equipment for his livelihood, or a physician who considers it only one aspect of care for patients who are elderly or have chronic diseases like diabetes? I think Medicare has picked the right guy.
Regardless of how you feel, none of this will change anytime soon. During the "ask-the-contractor" teleconference, a DME MAC official told providers: "You're not going to like what I'm about to say, but it truly is the responsibility of the supplier to have the information readily available to support the medical need and the criteria for the equipment you're providing."
So what are HME providers to do? They're between a rock and a hard place, for sure, but they need to realize they do have some control over the situation. During the teleconference, DME MAC officials encouraged HME providers to do a thorough intake process. (By the way, that got me to thinking: Do HME providers regularly take on patients with lousy or incomplete documentation, thinking they'll straighten it all out later? If they do, they're not doing themselves any favors). You could translate that this way: HME providers need to stand up to physicians. They need to refuse to take on a patient if the physician's documentation is lousy or incomplete. If all HME providers take this stand, sooner or later, if physicians can't find anyone to take their patients, they'll get their act together.
At the end of the day, remember this: HME providers may not be in the same league as physicians, but physicians need HME providers as much as HME providers need physicians. hme