Depending on the contractor, audits are very much up and running

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Friday, September 4, 2020

COLUMBIA, S.C. – Audits have started to pop up in a number of places, including more recently, from the SMRC, says Andrea Stark. 

“I haven’t seen any posts to the SMRC website announcing new audits, but I’m starting to hear the initial murmurings from suppliers they are receiving audit requests from the SMRC that may involve vents or oxygen – indicating a respiratory related review,” said Stark, a reimbursement consultant with MiraVista. “But they’re non-public audit requests so I can’t say how widespread it is – at present it seems targeted.” 

CMS announced in late July that it was giving its contractors the green light to resume* audit activities starting in August. 

Since the announcement, the RAC notified providers it will resume certain medical review activities, and the DME MAC for Jurisdictions B and C announced it will begin complex, post-pay, service-specific reviews on back braces and test strips, just to name a few. 

“We’re getting the signals that, while things may be slower with some of the audit contractors, other contractors are rolling on much more quickly,” Stark said. 

Here’s what else Stark had to say about what’s in store: 

Blessing and curse of relaxed policies 

The RAC for DME recently announced post-payment audits related to CGMs, following CMS’s decision to not enforce the clinical conditions for therapeutic CGMs in LCDs during the COVID-19 pandemic. 

“It’s another relaxed policy that came out,” Stark said, “and instead of breathing room for suppliers to provide the most relevant products, we’re seeing targeted audits. Even if contractors don’t review pandemic service dates, audits of these critical products divert much-needed resources from front-line suppliers.” 

During the pandemic, CMS will not enforce, for example, the type of diabetes that a beneficiary must have or the frequency of documented blood glucose testing to permit COVID-19 patients with diabetes to receive CGMs. 

‘A lot of activity at the OIG’ 

Stark noted the Office of Inspector General’s recent reports on two different providers of orthotics in Florida that it claims didn’t comply with Medicare requirements when billing for braces. 

“That’s just the tip of the iceberg for that product category,” Stark said, “just given the historical error rates and Operation Brace Yourself.” 

The OIG also recently announced that it will be reviewing: the contracts for ventilators awarded by the Department of Health and Human Services under the Defense Production Act in response to the COVID-19 pandemic; and the use of telehealth services during the pandemic.