What awaits in the aftermath of self-audits?

YARMOUTH, Maine - Industry stakeholders are watching to see how the Office of Inspector General and CMS respond to provider self-audits on CPAP supplies.

About a year and a half ago, more than 80 providers were asked to conduct self-audits looking back six years, and their responses ran the gamut from not responding, to reporting an overpayment and sending a check, according to Jeff Baird.

“It's going to be interesting,” said Baird, chairman of the Healthcare Group at Brown & Fortunato. “How serious are they going to be; how are they going to react to the responses they get?”

Back in the fall of 2018, following an OIG report, the DME MACs requested that certain providers conduct self-audits on claims for CPAP supplies within 180 days. Providers that identified overpayments then needed to contact the DME MACs within 60 days of the review to adjust the claim, pay it or negotiate a payment plan.

Baird suspects providers that didn't respond “will likely have problems,” and providers that conducted self-audits and found nothing might be looked at further.

“Will they say, 'Wait a minute, that doesn't make sense; we're going to audit you and see if we agree with you,'” he said.

For providers that reported overpayments and paid, “will the OIG and CMS be satisfied with that?” Baird asked.

Stakeholders do know that the OIG and CMS have asked the DME MACs to report back to them on any overpayments reported by providers, so “that lends me to think that they are going to look at it,” said Wayne van Halem, president of the van Halem Group.

van Halem says self-audits are becoming the “standard” going forward and points to another recent request, this time to more than 20 providers of inhalation medications, as well the UPICs picking up the six-year look-back language.

“It's a slippery slope, because providers could end up doing nothing but (self-auditing),” he said.

Baird agrees that the self-audits for CPAP supplies are a “shot across the bow.”