Every year HHS' Office of Inspector General posts its annual work plan, a summary of reports it is or will be working on over the next fiscal year. For FY 2011, similar to prior years, a series of reports that focus on DMEPOS are included in the OIG's work plan.
Some OIG reports are required by Congress; others are done because the OIG has identified specific vulnerabilities in the Medicare program. Once reports are issued, they contain the OIG's specific recommendations to Congress and to the Centers for Medicare and Medicaid Services on how to address the problems. These reports are an important mechanism to understanding the government's specific areas of scrutiny.
Several reports related to Medicare's competitive bidding program are included on the OIG's DME work plan for the coming year. Following is a summary:
- Competitive Bidding Process for Medical Equipment and
Supplies
The OIG will review the process CMS used to conduct competitive bidding and subsequent pricing determinations for certain DMEPOS items and services in selected competitive bidding areas under Rounds 1 and 2 of the program.
The 2008 Medicare Improvements for Patients and Providers Act (MIPPA) requires the OIG to conduct post-award audits to assess the process CMS used for bidding and to look at its pricing determinations. The report is expected to be issued in FY 2011.
- Competitive Bidding Program: Supplier Influence on Physician
Prescribing
The OIG will review DME claims to determine the extent to which suppliers participating in the competitive bidding program are soliciting physicians to prescribe certain brands or modes of delivery of covered items that are more profitable. The competitive bidding law requires the OIG to conduct this review.
The OIG will also examine billing patterns to identify changes resulting from competitive bidding. This new report will be issued in FY 2012.
- Medicare Market Shares of Mail-Order Diabetic Test
Strips
The OIG will determine the brands and models of diabetic test strips reimbursed by Medicare. Under the competitive bid law, Congress required the OIG to complete a study of diabetic test strip products and submit it to the HHS Secretary before Jan. 1, 2011.
CMS may use the results of this study in future rounds of competitive bidding for mail-order diabetic test strips to ensure that suppliers that submit winning bids are able to provide beneficiaries' preferred types of test strips. The OIG will also determine the market shares of diabetic test strips that Medicare beneficiaries receive by mail order.
Additional reports unrelated to the competitive bidding program are also on the OIG's 2011 work plan, including:
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Medicare Payments for High Volume, High Dollar Categories of DME, including power mobility devices, hospital beds and accessories, oxygen concentrators and enteral/parenteral nutrition.
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Frequency of Replacement Supplies for DME. The OIG will select a sample of claims for frequently replaced CPAP supplies to determine whether payments met Medicare requirements.
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Medicare Payments to DME Suppliers for Power Wheelchairs. The OIG will review documentation for standard and complex rehab PWC claims to determine whether the equipment was medically necessary.
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Medicare Payments for DME Claims with Modifiers. The OIG will determine whether payments to DME suppliers met rules that require suppliers to use modifiers indicating that they have the appropriate documentation on file.
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Medicare Part B Payments for Home Blood Glucose Testing Supplies. The OIG will review Part B payments for home blood glucose test strips and lancet supplies.
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Enrollment and Monitoring for DMEPOS Suppliers. The OIG will assess the Medicare contractors' use of enrollment-screening mechanisms and post-enrollment monitoring activities to identify applicants that pose fraud risks.
Editor's Note: The government's FY 2011 runs from October 2010 through September 2011. Find the full OIG work plan at: http://oig.hhs.gov/publications/workplan/2011/.
Read more Washington Wit & Wisdom columns. View more competitive bidding stories.
A specialist in health care legislation, regulations and government relations, Cara C. Bachenheimer is vice president, government relations, for Invacare Corp., Elyria, Ohio. Bachenheimer previously worked at the law firm of Epstein, Becker & Green in Washington, D.C., and at the American Association for Homecare and the Health Industry Distributors Association. You can reach her at 440/329-6226 or cbachenheimer@invacare.com.
