Heartland Sneak Peek: COVID Flexibilities Are Now Audit Opportunities

Published in Member Communities on April 21, 2022

Wayne van Halem & Denise LeardBy Wayne van Halem, President, The van Halem Group

One of the biggest uncertainties of moving into a post-pandemic world is how CMS will decide to audit claims submitted during the public health emergency. There were a number of “waivers” and “flexibilities” that CMS put into place to try to get equipment to patients quickly and safely, and inevitably, a few bad actors will try to take advantage of the situation. That, coupled with CMS ceasing audit activity for a period of time, lends itself to potential compliance concerns.

We are already seeing Unified Program Integrity Contractors (UPICs) auditing pandemic claims for respiratory equipment with CR modifiers and identifying overpayments, so that is the likely tool in the CMS arsenal that they will utilize to perform these audits.  Unfortunately for suppliers, if the UPIC identifies an overpayment, it also implicates the six-year lookback rule where suppliers need to do their own self-assessment and voluntarily report overpayments on all claims submitted during the previous six years.

Obviously, the potential impact and burden on suppliers is significant and to date, CMS has not issued clear guidance on what parameters are being set for these types of reviews. What is also unclear is how CMS will handle claims for equipment set up during the pandemic, which also could lend itself to issues for suppliers whose patients may not qualify under normal circumstances. 

Amongst all the uncertainties, one thing that has been made clear by CMS is that they do intend to audit pandemic claims and as previously noted, already are. An understanding of the audit climate will be integral to avoiding ongoing issues and overpayments. As we help clients navigate through these types of issues, we gain an understanding of what CMS actions are and how to mitigate the risk as much as possible, from both a legal and compliance point of view. Suppliers will need the knowledge and understanding to prepare themselves for the inevitable audit requests on pandemic claims as well as an assessment of the parameters that CMS is using and what additional initiatives that CMS may implement in the future.

Heartland LogoPlease join me and Denise Leard at Heartland Conference where we will discuss current audit initiatives and documentation pitfalls that should be avoided. Learn more and register at vgmheartland.com.  


TAGS

  1. audits
  2. cms
  3. education
  4. heartland
  5. the van halem group

From Our Experts

Online Registration Closes June 6 for Heartland 2022 thumbnail Online Registration Closes June 6 for Heartland 2022 Online registration for VGM's 21st anniversary Heartland Conference will close June 6. Guests will still be able to register on-site for the in-person educational event June 13-15 in Waterloo, Iowa. Online Registration Closes June 6 for Heartland 2022 thumbnail Online Registration Closes June 6 for Heartland 2022 Online registration for VGM's 21st anniversary Heartland Conference will close June 6. Guests will still be able to register on-site for the in-person educational event June 13-15 in Waterloo, Iowa. Distinguishing Your O&P Practice thumbnail Distinguishing Your O&P Practice Healthcare is increasingly moving to outcomes-based care models. Tomorrow's clinicians should prepare for refined and repeatable articulation of their impact on patient outcomes with referral sources, patients, and payers. Worker's Comp Prosthetic Bill In Iowa Passes House and Senate thumbnail Worker's Comp Prosthetic Bill In Iowa Passes House and Senate Today the Iowa legislature passed a bill allowing for prosthetic devices for a person injured on the job as long as it is medically necessary. Why the Right to Repair is NOT the Right Thing to Do to Address Delays in Wheelchair Repairs thumbnail Why the Right to Repair is NOT the Right Thing to Do to Address Delays in Wheelchair Repairs Right to Repair legislation has popped up in several states and is a topic that impacts all U.S. Rehab members. If passed, it could have devastating consequences to patients attempting to repair their own medical equipment. Heartland Session Sneak Peek: Inventory Management, Procurement, & Cash Flow thumbnail Heartland Session Sneak Peek: Inventory Management, Procurement, & Cash Flow Many members lament the challenge of staying cash flow positive while maintaining an inventory that allows them to serve their patients in a timely manner. Join Gerry at Heartland for a discussion on all things inventory management, procurement, and cashflow. Heartland Sneak Peek: Power Standing Mobility: From Research to Application thumbnail Heartland Sneak Peek: Power Standing Mobility: From Research to Application Providing power standing wheelchairs can be a complicated and overwhelming experience for even the best ATP or clinician. How do you get everything right and ensure that your client/patient gets the best outcome and the best equipment possible? The Importance of the Limb Loss and Preservation Registry thumbnail The Importance of the Limb Loss and Preservation Registry In this episode of Industry Matters, OPGA president, Todd Eagen, talks with Dr. Kenton Kauffman of the Mayo Clinic about the Limb Loss and Preservation Registry.