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From The van Halem Group: Get Your Compliance Program Audit-ready

Posted on in Billing/Reimbursement, HME Government Issues

Compliance – Who’s Taking Notice?

The Affordable Care Act (ACA) mandates that any provider or supplier enrolled in Medicare, Medicaid, or CHIP must implement a compliance program.

To date, CMS has only extended this compliance requirement to skilled nursing facilities (SNFs) and nursing facilities (NFs) in order to receive payment under the Medicare and Medicaid programs, but times are changing.

Long before the enactment of the ACA, the OIG developed seven elements of an effective compliance program that were published to the Federal Register. The OIG has consistently provided compliance guidance to include education and other free resources. In fact, the OIG issued a new compliance resource on March 27, 2017: “Measuring Compliance Program Effectiveness: A Resource Guide.” The purpose of this guide is “to give health care organizations as many ideas as possible…to assess [their] compliance program.

In July 2015, the Department of Justice (DOJ) quietly established a Compliance Counsel under the Fraud Section. The goal of the counsel is to assist in investigations and prosecutions to determine if providers and suppliers have an effective compliance program.

Fast-forward to February 2017 when the DOJ published an “Evaluation of Corporate Compliance Programs” guide on its website. This guide contains a list of topics and sample questions that can be used when evaluating a company’s compliance program.

You Need a Compliance Program…Now

Given the DOJ’s recent push for compliance, combined with the OIG’s latest publication, if you bill Medicare or Medicaid, you need to have a compliance program in place. Even more important, the compliance program should be effective. Consider the following when evaluating your current compliance program:

  1. The effectiveness of the compliance program. Are your policies and procedures appropriately implemented, communicated, and evaluated?
  2. Communication of program with employees. Do your employees receive both appropriate and repeated compliance training? Are they able to report concerns both easily and comfortably?
  3. Is compliance included at the decision-making level?
  4. Does your compliance team have the necessary resources to perform functions?
  5. Compliance must be part of company culture, not just a paper program. Do your employees understand the importance of compliance in their daily activities?
  6. Risk awareness. What is your ability to identify, analyze, and address risks affecting your company?

It is increasingly important to maintain compliance in our industry. As CMS continues to develop audit programs to protect Medicare dollars, the likelihood of a compliance requirement for DMEPOS suppliers is high. At the van Halem Group, we are here to support  your compliance needs. If you have any questions or would like to further supplement your current compliance package, give us a call at 404-343-1815!

Audit Alerts

DME contractors perform pre- and post-payment reviews on a continual basis. Through data analysis, the medical review department determines the codes they will review and then send Additional Documentation Request (ADR) letters to suppliers that bill those codes.

Click here for the list of codes currently being reviewed among all four DME jurisdictions and for a list of CMS-approved issues that Performant Recovery, the National Home Health and Hospice and DMEPOS Recovery Audit Contractor (RAC), has posted to its website.

BUSTED! Owner of Georgia Medical Supply Firm Gets 25 Months for Medicare Fraud

Carla Cartwright, a resident of Savannah, Georgia, and owner and operator of three businesses including Parker & Noble Therapeutic Supplies, was sentenced to a 25-month prison term and was ordered to pay restitution of $750,000 for Medicare fraud.

Cartwright was convicted of falsely billing Medicaid for unnecessary and undelivered medical equipment and devices from 2009 to 2016, authorities say. Read more.

The van Halem Group at Heartland Conference 2017

The van Halem Group will be well represented at VGM’s Heartland Conference the week of June 12. Below are the dates and times of presentations by The van Halem Group associates:

Monday, June 12 (Pre-conference session)
9 a.m. – Noon: Kay Koch (with VGM’s Ronda Buhrmester) – “What Keeps You Up at Night? Getting a Plan in Place for Documentation”

Tuesday, June 13
9:30-10:30 a.m. – Wayne van Halem – “2017 Mid-Year Audit Update”
3:30-5 p.m. – Kelly Grahovac – “Audits: Get Noticed Just by Submitting These Codes”

Wednesday, June 14
9:15-10:15 a.m. – Kay Koch – “De-coding Documentation: Complex Rehab Wheelchairs & Seating”
10:30-11:30 a.m. – Wayne van Halem – “Telehealth: Make the Right ‘Call’”
 4-5 p.m. – Lisa Eick – “The Power and Pitfalls of the Electronic Medical Record”

Thursday, June 15
1:30-3 p.m. – Wayne van Halem – “Common Sense Approach to Compliance”
1:30-3 p.m. – Kay Koch (with VGM’s Dan Fedor) – “No MORE Mobility Addendums!”
 3:15-4:15 p.m. – Lisa Eick – “Are You on Par for PAR?”

In addition, if you’d like to visit one-on-one with representatives from The van Halem Group during Heartland week, you can schedule the time that works best for you by clicking here.

If you have not registered for Heartland, you still have time. Click here to sign up today.