Industry to CMS: Build out phone demo

WASHINGTON - Industry stakeholders are throwing their support behind expanding a demonstration project that allows providers to speak with reconsideration professionals by phone to try and resolve their appeals.

AAHomecare on Feb. 22 submitted comments to CMS, recommending that the agency also consider applying the phone demo to the first level of appeals. Currently, it applies only to the second level of appeals.

“Although the demonstration at the second level of appeals has been a positive experience for suppliers, we believe instituting a discussion at the first level of appeals will enable CMS to significantly reduce the backlog at the Office of Medicare Hearings and Appeals,” wrote Kim Brummett, vice president of regulatory affairs for the association.

The backlog at the administrative law judge level, the third level of appeals, was 877.2 days in fiscal year 2016, according to AAHomecare.

The association also recommends that CMS gather data on the type and volume of denials that are overturned and that are found to be errors by the processing contractor.

“To improve the appeals backlog, education on claims processing must target both suppliers and contractors,” Brummett wrote.

Finally, AAHomecare recommends that CMS “evaluate policies that are disproportionally contributing to the appeals backlog and adjust the language to meet the intent of the requirement by allowing for some flexibility,” Brummett wrote.

C2C Innovative Solutions, the Qualified Independent Contractor that is conducting the phone demo, is already doing this on an informal basis, says Andrea Stark, a reimbursement consultant with MiraVista. CMS has made the unprecedented move of giving C2C “discretion” to overlook minor technical errors that would, otherwise, sink a claim, she says.

“That's something we haven't seen before,” she said. “For example, if there's a doctor's signature and there's a fax date, they can accept that as the signature date as long as it's before claim submission, versus saying there's no signature date. C2C can make those kinds of connections that give providers the benefit of the doubt.”

CMS has also been expanding the demonstration on its own. In March, C2C Innovative Solutions will begin considering cases for manual wheelchairs, external infusion pumps, power wheelchairs, prosthetics, miscellaneous respiratory products and surgical dressings.

“Where the ALJ is seriously backlogged, this is really the first CMS innovation that is really worth a darn,” Stark said.

In February, C2C began considering cases for orthotics, medications, NPWT, lymphedema pumps and repairs; and in January, for CPAP devices, hospital beds, enteral nutrition, support surfaces, nebulizer meds, ostomy and urological supplies, and therapeutic shoes. When C2C kicked off the five-year demo in 2016, it considered cases only for oxygen equipment and diabetes testing supplies.

C2C is also working with larger providers to work on consolidating multiple cases to make the process more streamlined, Stark says.

“Otherwise, they're doing them all onesie-twosie,” she said.