Audits: Expert Shines Light on Worrying New Trends

Top-line audit concern includes HHS OIG adding PAP supplies to Its workplan. Wayne van Halem will discuss several new, worrying audit developments and how to prepare for them in Dec. 11 webinar.

HME providers will soon face some troubling audit developments, and Wayne van Halem, president and founder of audit consulting firm The van Halem Group (a division of the VGM Group), will host a Dec. 11 webinar showing providers how they can get on top of those issues.

The most immediate audit concern is HHS OIG’s recent decision to add sleep re-supply items to its workplan.

“This is very similar to what they did back in 2018, which had pretty significant results for our industry,” van Halem told HME Business.

That resulted in Medicare releasing a report stating that the majority of PAP claims didn’t pass muster and had resulted in more than $600 million in overpayments.

“It was significant,” van Halem explained. “[Medicare] took a relatively small sample of claims for PAP replacement supplies; they audited them; they only looked at 110 claims; they found that 86 of the 110 did not meet Medicare requirements; and as a result of that, they extrapolated the overpayment and estimated that CMS overpaid $631.3 million for PAP replacement supplies.

“Caught up in that were a number of suppliers who were part of the 110 claims,” he continued. “The ones that had claims denied then received notices from CMS through the contractor that they were now required to perform a six lookback audits, which is really significant and challenging for a lot of providers out there.”

Six-year lookbacks are a difficult, expensive process that involves hiring third-party experts, such as statisticians. If claims don’t meet guidelines, those are deemed overpayments and the money must be refunded to Medicare. Van Halem has said his firm has seen the cost go as high as $1 million, he says. Think about it: one denied claim can result in refunding a significant sum to the Federal government.

On top of the HHS OIG’s addition of PAP supplies to its workplan, the UPIC contractors are sending letters that include similar language to the OIG reports. Also, HHS OIG’s workplan will cover more product categories, as well.

As a result, van Halem’s Dec. 11 webinar, “Getting in Front of Troubling New Audit Developments,” which will cover several key learning objectives:

  • What is in the OIG workplan — it’s not limited to PAP supplies and more categories are coming.
  • Important trends in the UPIC audits.
  • Understanding the true impact of a six-year lookback.
  • How to can prepare your business to mitigate these troubling new developments.

Providers can register for the webinar at

About the Author

David Kopf is the Publisher and Executive Editor of HME Business and DME Pharmacy magazines. Follow him on Twitter at @postacutenews.

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