The Council for Quality Respiratory Care (CQRC) has responded to the Centers for Medicare & Medicaid Services’ (CMS) request for information (RIF) on its Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH) initiative.
CQRC released its formal comments on March 31 while acknowledging “the significance of the [Trump] administration’s effort to strengthen the integrity of federal health care programs” and the need to root out “illegitimate actors while enhancing oversight and accountability in these programs.”
In writing to CMS Administrator Mehmet Oz, M.D., CQRC described its members as “legitimate U.S. businesses who operate in all 50 states and U.S. territories” and employ approximately 29,000 people who support 3.128 million people living with respiratory diseases and conditions.
Among CQRC’s recommendations:
— Use technology-based systems to prevent fraud and abuse of supplemental oxygen “by adopting standardized data elements that can be collected from electronic medical records to establish medical necessity for supplemental oxygen.” Via the ePrescribing platform, “CMS and its contractors would receive the information necessary to establish medical necessity in an electronic format that would increase their ability to promote payment accuracy and efficiency.”
— Reinstate “comprehensive” supplier financial documentation qualification requirements to prevent fraudsters from participating in Medicare’s upcoming competitive bidding program.
— Hold suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) accountable for the bids they submit during Medicare’s competitive bidding program.
— Create stronger patient protections such as “having CMS provide up-to-date information about each beneficiary’s own cost-sharing responsibilities.”
— Make audit and appeals processes transparent by annually releasing data such as the number of appeals “filed by provider or supplier type; descriptions by provider and supplier type of the top three reasons for the
denials at the lower review levels; the number of denials overturned in favor of the provider and supplier by provider or supplier type, as well as the number of denials upheld in favor of the government; and descriptions by provider and supplier type of the top three reasons for the overturning denials in favor of the providers and suppliers, as well as the top three reasons for denials being upheld in favor of the government.”
“We encourage CMS to review the provisions of the SOAR Act [Supplemental Oxygen Access Reform, S.1406/H.R.2902] that would strengthen current laws to prevent fraud and abuse, promote Medicare program integrity, and protect beneficiaries if the legislation were enacted,” CQRC Chair Robin Menchen said in the letter. “We are committed to eliminating fraud and abuse so that legitimate suppliers can provide medically necessary services to beneficiaries in the care setting that is the most appropriate for them — their home.”
