OIG Finds PWC Documentation Lacking; Medical Necessity Next Up for Study

WASHINGTON — According to the Office of Inspector General, three out of five claims for standard and complex rehab power wheelchairs did not meet Medicare documentation requirements during the first half of 2007. Those claims accounted for $112 million in improper Medicare payments out of the $189 million total allowed during the six-month period, the OIG said in a report posted Dec. 30.

Based on a random sample of 375 claims selected for review, the report said 60 percent did not meet one or more documentation requirements and two out of five had multiple errors. In addition, the OIG said, suppliers submitted incomplete documents almost three times as often as they failed to submit required documents.

Medicare currently requires the following documentation to support power wheelchair claims:

• power wheelchair prescription;
• supporting documentation from the beneficiary's medical record;
• specialty evaluation report (for complex rehab chairs only);
• detailed product description;
• home assessment report; and
• proof of delivery.

According to the new report, error rates ranged from 1 percent of claims with no proof of delivery to 40 percent of claims for which the supporting documentation and detailed product descriptions were not submitted or were incomplete.

The specialty evaluation report and a detailed product description were the documents most often lacking on complex rehab claims, the report found.

The OIG also noted that documentation error rates varied by power wheelchair type and supplier volume: Complex rehab claims had a higher documentation error rate (93 percent) than standard power chair claims (58 percent); and standard PWC claims from low-volume suppliers — those that submitted fewer than 10 standard PWC claims in the study period — had a higher documentation error rate (72 percent) than those submitted by high-volume suppliers (55 percent).

Based on its review, OIG recommended that CMS improve compliance with PWC documentation requirements by conducting additional reviews of claims; recovering overpayments and considering further actions against suppliers that do not meet documentation requirements; and increasing education for suppliers and prescribing physicians about documentation requirements.

The OIG also recommended that CMS take appropriate action on the sampled claims found to be in error. CMS concurred with the recommendations. For the complete report, go to http://oig.hhs.gov/oei/reports/oei-04-07-00401.pdf.