ARLINGTON, Va. — The American Association for Homecare is
hoping 13 will be HME's lucky number, at least when it comes to
healing the industry's black eye from fraud and abuse.
On Friday, the association unveiled a 13-point plan it believes
could eliminate most of the Medicare fraud attributed to the HME
sector.
"The home care sector has zero tolerance for illegal activity,
and we are frustrated that the problem seems to be growing rather
than shrinking," said Tyler J. Wilson, AAHomecare president and
CEO. "Taxpayer dollars lost to fraud represent theft of resources
needed by seniors and people with disabilities. So, we are sharing
these aggressive new recommendations with Medicare and its
contractors, Congress, the Department of Justice, and the FBI in
the hope that we can keep criminals away from the Medicare
program."
AAHomecare's 13 specific recommendations include:
- Mandating site inspections for all new HME providers. A July
2008 GAO report underscored the need for CMS to ensure that its
contractors are conducting effective site inspections for all new
applicants for a Medicare supplier number. - Requiring site inspections for all HME provider renewals. All
renewal applications should require an in-person visit by the
National Supplier Clearinghouse, the contractor CMS uses to ensure
integrity in the Medicare program. - Improving validation of new home care providers. Additional
validation of new providers should be included in a comprehensive
and effective application process for obtaining a Medicare supplier
number. - Requiring two additional random, unannounced site visits for
all new providers. Two unannounced site visits should be conducted
by NSC during the first year of operation for new HME
providers. - Requiring a six-month trial period for new providers. The NSC
should issue a provisional, non-permanent supplier number to new
suppliers for a six-month trial period. After six months of
demonstrated compliance, the provider would receive a "regular"
supplier number. - Establishing an anti-fraud office at Medicare. CMS should
establish an office with the sole mandate of coordinating detection
and deterrence of fraud and improper payments across the Medicare
and Medicaid programs. - Ensuring proper federal funding for fraud prevention. Increase
federal funding to ensure that NSC completes site inspection and
other anti-fraud measures. - Requiring post-payment audit reviews for all new providers.
Medicare's program safeguard contractors should conduct
post-payment sample reviews for six months worth of claims
submitted to Medicare by new providers. - Conducting real-time claims analysis and a refocus on audit
resources. Medicare must analyze billings of new and existing
providers in real time to identify aberrant billing patterns more
quickly. - Ensuring all providers are qualified to offer the services they
bill. A cross-check system within Medicare databases should ensure
that homecare providers are qualified and accredited for the
specific equipment and services for which they are billing. - Establishing due process procedures for suppliers. CMS should
develop written due process procedures for the Medicare supplier
number process, including issuance, denial and revocation of the
Medicare supplier number. The procedures must include, for example,
an administrative appeals process and timelines. - Increasing penalties and fines for fraud. Congress should
establish more severe penalties for instances of buying or stealing
beneficiaries' Medicare numbers or physicians' provider numbers
that may be used to defraud the government. - Establishing more rigorous quality standards. Ensure that all
accrediting bodies are applying the same set of rigorous standards
and degree of inspection to their clients.
Several anti-fraud measures the association suggested were
incorporated into the Seniors and Taxpayers Obligation Protection
(STOP) Act (S. 3164), a bill to reduce Medicare fraud that was
introduced earlier this year. (See HomeCare Monday, Aug. 4.)
In July, the Medicare Improvements for Patients and Providers
Act—the same law that delayed competitive
bidding—closed a loophole that would have allowed
non-accredited providers to serve beneficiaries, and CMS has
mandated a Sept. 30, 2009, accreditation deadline for HME providers
nationwide.
