AAHomecare Outlines Audit Reform Objectives

Association advises Senate Finance Committee, gearing up to launch legislation, other initiatives.

Work is being done by the American Association for Homecare and other healthcare associations to draft legislation to reform the Centers for Medicare and Medicaid’s current audit program, and representatives of the association met with the Senate Finance Committee to discuss audits today.

Kim Brummett, vice president of regulatory affairs for the American Association for Homecare met with and discussed various recommendations with the Senate Finance Committee at a special roundtable meeting today, after the association outlined a broad set of objectives for reforming CMS’s current audit program earlier this week Medtrade Spring this week.

Brummett met with the committee to share her expert understanding of the audit process and her experience dealing with the Centers for Medicare and Medicaid services. She was joined by Jeff Mastej, director of compliance and audit for Rochester, Mich.-based provider Wright & Filippis and chairman of AAHomecare’s Regulatory Council.

At the meeting, AAHomecare presenting the following recommendations based on input from its members to the committee:

  • Stop new audits until the backlog is cleared up.
  • Stop interest penalties until an audit is through all levels of appeals.
  • Stop the recoupment/repayment process until an audit is through all levels of appeals.
  • Issue guidance to Durable Medical Equipment Medicare Administrative Contractors (DME MACs) to allow for timely filing over-ride on continuous rental or supply claims.
  • Issue guidance to DME MACs to require reopening after a re-determination on a technical denial.
  • Evaluate the Qualified Independent Contractor (QIC) to determine if this step is effective or merely a stop-gap on the way to the Administrative Law Judge.
  • Assign greater weight to clinical inference: let the medical record speak to the need of the patient and pay for services based on those facts.

 “Today’s roundtable was an excellent opportunity to explain those recommendations to the Committee as they prepare a legislative solution to the audit problem,” Brummett said.

Earlier in the week, during AAHomecare’s March 11 Washington Update at the Medtrade Spring event held at the Mandalay Bay in Las Vegas, Brummett presented a set of much broad and far-reaching audit reform recommendations to providers attending the event:

  • Conduct independent reviews of contractors to hold them accountable.
  • Interest penalties for MACs when claims are overturned.
  • Remove ability for MACs to issue “clarifications.”
  • Enhance review of DME providers who do not respond to audit requests.
  • Limit the number of audits a DME provider can receive during a given period.
  • Reinstate “clinical inference” policy.
  • Require that electronic health records include DME medical necessity documentation.
  • Mandate use of a template such as in the power mobility device prior authorization demonstration.

The objectives represent a blend of goals the industry has in terms implementing improvements in the audit system while working in conjunction with the MACs, which have a good deal of discretion in the process, while other objectives would be put into some form of legislations, according to Brummett. That legislation, according to Jay Witter, vice president of Government Affairs for the association has been in the works for a couple years with various parties.

“It’s very close to being finalized,” Witter said at this week’s Washington Update. “We’re very sensitive because of competitive bidding efforts on the Hill; we don’t want to ask for too many things. But we are close. We have built the foundation and we will be making an announcement very soon about a huge audit effort.”

Witter noted that the advocacy challenge for the industry and provider advocates will be to simplify audits, which are a very complex issue. To that end, the association is also collecting provider stories about their audit frustrations and the negative impact the program is having on their businesses and patients. These will be used to help sell is legislative case on Capitol Hill. To submit stories, providers should email auditproblems@aahomecare.org.

About the Author

David Kopf is the Publisher and Executive Editor of HME Business and DME Pharmacy magazines. Follow him on LinkedIn at linkedin.com/in/dkopf/ and on Twitter at @postacutenews.

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