Observation Deck

Repair Guidelines Need Repairs

How DMEMAC medical directors set the allowed labor limits on repair services needs to change.

Those of us in the business of providing home healthcare DME and supplies are very committed to helping people live better lives. But every supplier is in business to drive a profit. We provide all the services and products within a continuum of care. We are not social service agencies; we are not non-profit agencies.

Our profit margins determine how extensively we can provide comprehensive services and give us the ability to obtain and retain educated staff to competently service our customers. And, in no division is this dynamic more evident than in the DME repair arena.

Power Mobility Repairs

For example, the lifetime of power mobility devices (PMDs) is five years so repairs are inevitable. PMD users often rely on their equipment up to 18 hours per day, and they need to know that they can obtain the required skillful services they need quickly. Suppliers need to be able to provide those services efficiently and profitably.

For several years our industry has struggled with the capped labor limits allowed when providing repair services. This particular issue is in the hands of the four DMEMAC medical directors. They decided the limits, not CMS. They can increase those limits if we can provide data showing the labor unit caps allotted for specific repairs is too low. To date, the supplier community and even this writer have been unable to convincingly do so, indicating we must gather more data to support our position. As a result, in most repair scenarios, suppliers are unable to bill the actual labor time provided when completing a repair.

Let’s take the labor payment out of the equation and discuss the allowable set for repair replacement parts. Seriously skewed by inclusion of certain codes in the competitive bid categories, in competitive bid areas where any supplier may do repairs for the single price allowed, we’ve seen a diminishing number of suppliers willing to do the work. And we’ve all heard from beneficiaries who can’t get their products fixed anymore.

Compounding the situation is the demise of a large national PMD supplier whose customers now must turn elsewhere for service, but providing that service is not without liability if you do the work. The beneficiary is not on record at your business.

Illustrating the Point

It is in our genes to want to help. Here’s a likely scenario: The beneficiary explains they can’t find anyone to fix their power wheelchair. Often, they don’t have a back up chair to use. We recognize their need.

 A complete intake process ensues making certain coverage exists, determining the accurate primary and secondary insurance to bill. To qualify for repair and replacement parts under the Medicare guideline, the beneficiary would have had to qualify for the specific PMD when it was obtained from the original supplier. But the original documentation is not in the hands of the beneficiary and the prescribing doctor is unable to find the packet he or she sent the original supplier, or is reluctant to take time to search through records. If by chance the prescribing physician does try to find “something,” the data you receive is not comprehensive.

Meanwhile, the beneficiary is waiting.

The company who provided the PMD is now out of business or no longer provides repair services. If still in business and they have the information you seek, they are not mandated to provide it to you.

Regardless of what the customer outlined on the phone as the problem, you must evaluate what needs done and the parts that are needed. The beneficiary says they cannot come into your service facility; you need to send a technician out to their residence to a comprehensive estimate.

Meanwhile, the beneficiary is waiting.

Medicare doesn’t pay for travel unless you do the work non-assigned, having the beneficiary sign an Advance Beneficiary Notice (ABN) explaining all the inconsistencies that prevents you from simply doing the work and filing the claim directly with Medicare for payment. Wisely, you begin a discussion to collect the total fee up front so payment is retained in event of audit. CMS says it doesn’t plan to audit repairs, but does that statement offer any real comfort?

If the beneficiary doesn’t have the ability to pay, do you take the risk of filing assigned? Do you refuse to do the repair? Do you tell the beneficiary to call 1 (800) MEDICARE and see what CMS suggests?

Meanwhile, the beneficiary is waiting.

A Growing Problem

The repair conundrum has been mushrooming since the onset of Round One. The original nine competitive bidding areas (CBAs) recognized the problem early on. Contract awardees were required to do only warranty repairs. Companies that did not win contracts found themselves inundated with repair calls because many contract holders didn’t choose to continue doing general repair services. Many simply said it was not profitable. When the situation was exacerbated by the expansion of an additional 91 CBAs in Round Two, individual voices became a choir. Our industry is outraged. So are beneficiaries and the advocacy groups that represent them.

CMS has recently requested comments from stakeholders regarding the expansion of competitive bidding pricing throughout America by 2016. CMS suggests that possibly it is time to modify the payment structure for certain DME and Enteral nutrition by requesting a single bid for furnishing all related items and services needed on a monthly basis, including repairs. While on the surface it might seem a logical fix for CPAP and Enteral Nutrition under the bid program (to CMS), if expanded, this “bundled” thinking would further challenge suppliers to place sustainable bids.

Bottom line, as the number of beneficiaries requiring DME increases, the need for repair services will increase. How will CMS insure beneficiaries have prompt access to repair services? How can suppliers afford to do the work if payment is below cost coupled with the continual fear of audits?

Since 2011, Competitive bidding has seriously interrupted the continuum of care across America dismembering the supplier network and upending solid patient-supplier relationships. Its tentacles are about to spread further by 2016.

Well, forget the low-balled pricing issues, forget the non-binding bids, and forget the delivery delays patients are incurring for new equipment. The repair dilemma alone underscores one of the bid program’s serious structural flaws.

It’s time we connect the dots for our congressmen. Outcome data is what they need to help change policy. Let’s make sure beneficiaries who are having a difficult time finding a supplier to do their repairs reach out to their representative and explain their difficulty and how it is affecting their health. In working to stop competitive bidding, let’s all work hard to make sure the repair issue adds fuel to the fire for passage of H.R. 1717!

This article originally appeared in the April 2014 issue of HME Business.

About the Author

Georgie Blackburn is vice president of Government Relations and Legislative Affairs for Pennsylvania-based provider BLACKBURN’S. She can be reached at georgie.blackburn@blackburnsmed.com.

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