Are You on the NSC's Naughty or Nice List?

DME suppliers face an era of increasing scrutiny from the government. As Medicare and Medicaid reimbursements drop and the government commences various reform initiatives (including competitive bidding), the National Supplier Clearinghouse (NSC) has begun increased oversight of providers, both new applicants and those already up and running.

Even though the catalyst for such scrutiny may have been the recent Medicare billing scheme involving power mobility equipment, the NSC has always been required to perform periodic supplier audits to verify continued compliance with the CMS 21 Supplier Standards. So, long after the power wheelchair scandal is considered old news, NSC scrutiny will continue.

These days, you do not have to engage in fraudulent activities in order to be in the hot seat. The NSC seems to have created a number of “secret” rules that have not been written down or communicated well, so it is difficult for suppliers to avoid revocation proactively. This is important because it is much easier to comply than it is to get your number back if it is revoked.

The lack of effective communication is probably unintentional, the result of having too much to do too quickly. Regardless, the NSC has made its list and is checking it twice. They will find out if you've been naughty or nice.

What Do You Need to Know?

The rules are not difficult to embrace. They require you to implement checks and balances into your day-to-day operations to ensure that important policies or licenses do not lapse, and to formalize relationships that already exist. But the NSC is still learning how to operate during this new era. The rules its agents apply are not necessarily consistent among all site inspectors, and they may actually change from one visit to the next.

Even so, some patterns have emerged, and paying attention to the following “secret” compliance tips can help.

• Supplier Standard No. 1 requires suppliers to comply with all federal and state licensure requirements. The “federal” part of this rule is fairly easy, since the rules are applied to all suppliers. The state requirements can be more tricky. You must verify any certificates, business licenses or special qualifications that are required in the state where you will be conducting business. For example, does your state require a “bedding license?”