“Finally Friday!” DMEPOS – The Next Big Thing for RACs?

FRIDAY October 9, 2015:

“Target Acquired

Got DME?

Buckle up.

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Appeal Academy | Finally Friday!

High-functioning sociopaths are not exactly good candidates to be a Physician Advisor. Here’s a one word list of characteristics to avoid: House.

[Yes, I’m aware I’ve used the portrait at the right for three weeks running, but hey, if the shoe fits…]

For months, I have wanted to talk about DMEPOS, but inpatient and IPPS has been such a target of CMS for so long (and still is), we have focused on that. Soon we will be focused on outpatient and OPPS, especially with the new Final Rule to be delivered from on high in November – and we will be hosting Bill Malm’s annual review of it this year in December, so watch for that. Anyway, I’m attending the American Orthotic Prosthetic Association 2015 National Assembly this week in San Antonio, and have the chance to meet and interview Sarah Brase-Davis, President and Attorney Consultant at National Orthotic and Prosthetic Appeal Advocates out of Newark, Delaware.

It so happens that Sarah was formerly an Attorney at Maximus, who we know as an AdQIC, and she is happy to talk about her experiences there!

Appeal Academy | finally friday!

Sarah Brase-Davis, President and Attorney Consultant at National Orthotic and Prosthetic Appeal Advocates

Sarah has also prepared some slides to talk about how we think DMEPOS providers are the next target of at least one RAC, Contiviti, formerly known to us all as Connolly Healthcare.

While there is still speculation as to when or even if CMS will allow work to proceed, there does not seem to be anything standing in the way, anymore, since April, 2015. At this time, we have sources checking with CMS on the status of the award for the Region 5 (All States, why not just say that?) Recovery Audit contract for DMEPOS/H&H to Connolly, LLC. It was awarded Dec 30, 2014, then work was delayed due to a post-award protests filed with the GAO in January and February. The two protests were dismissed by the GAO within weeks – I think because CMS withdrew the offending requirements.

As of June 4, CMS withdrew their RFQs for the new RAC contracts, but said nothing about the award already made to Connolly.

So what’s a supplier to do now? We’ll discuss…

  • DMEPOS was late to the party & not prepared
  • Actions taken and the results
  • DMEPOS & the MAC – a Love/Hate Relationship
  • Uh… Limits? What limits?

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