When it comes to CPAP requirements, 'it's complicated'

With audits ramping up around the country, CPAP providers say they devote more time and effort than ever before to keep up with Medicare policy.

"We have weekly meetings where we are always addressing all of the compliance issues and assuring that we go through our checklists," said Lisa Feierstein, president of Active Healthcare in Raleigh, N.C. "It's always and endless and it's important to make sure that every (policy) change is on every piece of paper that relates to it."

That's particularly challenging for CPAP providers, who must keep up with what feel like ever-changing CPAP rules.

For example, in August, the DME MACs revised the four-month-old LCD requirement for switching a patient from a CPAP to a bi-level device. The treating physician must document that the beneficiary has been fitted with an appropriate interface and using it without difficulty and that the beneficiary cannot tolerate the current pressure setting of the E0601. Lower pressure settings must have been tried and failed.

Providers are happy with the change, which simplifies the requirement, but they must, once again, update their policies and educate referral sources.

"It is frustrating when things change," said Todd Cressler, president/CEO of Harrisburg, Pa.-based CressCare Medical, who quickly notified referral sources. "Since we are on top of all these issues, (the referral sources) appreciate it."

One way for providers to gauge how well they are complying with documentation requirements: Conduct a test run.

"Go through 50 records and five referral sources," said Kelly Riley, director of The MED Group's National Respiratory Network. "If three of those referral sources can get you timely, accurate information and the other two don't, don't (accept business from them). You're putting you're company at grave risk."

You don't need to tell that twice to Sam Jarczynski.

"The only way we take the order is with the face-to-face upfront," said Jarczynski, president of Rx Stat in St. Petersburg, Fla. "We need the Epworth study and measurement of the neck size and all of that. We are also super-diligent with prescriptions and CMNs."

In the end, being proactive pays off, say providers.

"If Medicare came in today and said they needed to do an audit, I wouldn't be scrambling," Feierstein said. "Not that it's easy. It is complicated and over-regulated."