1) Arizona has apparently received some changes to its HCPCS validation which is reflected in this announcement by CGS.
This has some far reaching implications beyond the Arizona brand name. If you are using other devices similar to Arizona you should heed the coding advice provided by the CGS listserv. While this was announced by CGS the DME MAC B and C carrier, Noridian (A/D) carrier will likely follow suit.
Ref: https://www.cgsmedicare.com/jb/pubs/news/2020/10/cope19279.html
2) CGS has announced they are performing post payment audits on:
A) Surgical dressings Alginate dressings and foam (A6196 and A6212) which are largely prescribed and dispensed by DPM's.
https://www.cgsmedicare.com/jc/pubs/news/2020/09/cope18770a.html
B) AFO post payment audits:
OTS devices described by HCPCS L1902 L1906 L1971 and night braces custom fit and OTS L4396/L4397 are all subject to a post payment audit.
Reference: https://www.cgsmedicare.com/jb/pubs/news/2020/10/cope19128.html
Both A and B above are HCPCS driven. A single PTAN cannot be asked for more than 25 charts in a quarter and if you pass the audit (100% passing) your PTAN will be excused from future audits for the remaining period of the time frame of the audit. I suspect that Noridian will likely follow suit on these same audits as these directives come from CMS and CERT (see below).
All DME post payment audits (at least until further notice) are for dates of service prior to March 1 2020. If you receive a letter with a post payment audit requesting data for a date of service subsequent to March 1, 2020 this is contrary to CMS guidelines and is most likely an error on the part of the contractor. Please contact the contractor and advise them of this error.
Also it is advisable if you are having staffing issues due to Covid 19 and have difficulties meeting any audit request deadlines, please contract the contractor (you may need to send them something via email) and advise them that you need an extension. They have been very understanding and they should easily grant you an extension.
CGS is also offering an Ask the Contractor Teleconference on WIdespread Post Payment Audits on November 19 2020
The link for registration can be found at: https://register.gotowebinar.com/register/5968420005405929999
Lastly, DME Contractors are not picking on podiatrists. There are currently many other post payment audits out there including for knee orthosis, spinal braces and many other DME items.
So we are not in this alone. The difference is Recent Cert Data (2018) provides intolerably high error rates for all DME prescribed and dispensed by DPMs (over 70%). And the DME Contractors know DPMs are easy pickings. I encourage you to use any down time you have from clinical duties to enhance your chart note templates and ensure your workflow processes conform to Medicare's requirements.
I would urge those who derive revenue streams from DME to both register for these resources and contract with an expert on DME issues.
Should you be contacted by your DME MAC for a post payment audit, there are also resources available from your professional liability carrier (Administrative Defense Coverage) to assist you with you by providing legal and expert witness assistance at minimum or no charge to you. Failure to contact your liability carrier prior to contacting Medicare (or any third party requesting recoupment), may result in nullifying your ADC policy not being able to provide assistance should you either fail your audit or that failure escalate into something more serious.
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