FAOP 2015 Annual Meeting State of Regulation of the Profession Where We Came From, Where We Are, and Where We Are Going Karen B. Perrin July 31, 2105

Disclaimer DISCLAIMER The information in this session is for educational purposes only. It is not legal advice. All information provided is for general information purposes only. Transmission or receipt of the materials or information in this manner does not constitute legal advice, establish an attorney- client relationship, or create any duty of the presenter to any person. An attorney-client relationship with an attorney may be established only by an engagement letter or contract signed by the attorney or firm. Unsolicited information sent to the presenter by persons who are not clients is not subject to any duty of confidentiality on the part of the presenter. If you need legal advice, please contact an attorney directly.

Overview Where we came from: No regulation per se if you are good, you live and prosper, if you are bad, you die. Orthotics armor makers of middle ages bark and leather, medicine men Prosthetics Civil War amputations 1965 Medicare Where we are: One of the most highly regulated professions in the US because both service and products are involved. Atmosphere of distrust Most of the regulation has little to do with good results or patient care. Most has to do with whether you get paid for your work and if so, how much? Where we are going: Yet TBD the future is in YOUR hands! Complacency O&P devices will become mere commodities, ordered on the internet and telemedicine (via phone or internet). Patient can order online from ads. Orthotists and Prosthetists become technical/hot line operators. Education & Activism profession with its own input into the practice, paid for your patient care and creation of devices that aid them. Part of the team that treats the challenges yet to come. Collect evidence of what improvements youve made in patients lives by what you do.

AUDITS, APPEALS & DOCUMENTATION

CMS Rulemaking Authority Federal Law Legislation by Congress and US Constitution Federal regulation is one of the basic tools the government uses to carry out public policy. Congress provides the legislative authority for agencies to issue regulation through the rulemaking process. Public plays an important role by commenting on proposed rules that can lead to formal rulemaking can help shape decisions. What is a rule? Rules are government statements that either: Carry out or explain law or policy. Describe an agencys organization or procedures How does an agency identify a need for a rule? Many reasons which include: Legal (or Statutory) mandate Agency identification of a problem or potential reform (Retrospective Review) Petition for rulemaking Advisory Committee, Government Accountability Office or OIG recommendations What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Medicare Part A and Part B Audits CMS has numerous auditing initiatives, each with different goals, and reporting to different parts of CMS: Comprehensive Error Rate Testing (CERT) audits measure improper payments in the Medicare Fee-for-Service (FFS) program. FL - FSC (First Coast Solutions, Inc.) Medicare Administrative Contractor (MAC) audits are designed to prevent improper payments through evaluation of program vulnerabilities and taking necessary action. CGS, Inc. Supplemental Medical Review Contractor (SMRC) audits are also intended to prevent improper payments through evaluation of program vulnerabilities and taking necessary action. Recovery Audits, formerly known as Recovery Audit Contractor (RAC) audits, are for the purpose of identifying and correcting improper payments. FL - C2C Solutions (QIC) (Connolly RA) Zone Program Integrity Contractor (ZPIC) audits are intended to identify and stop incidences of fraud in the Medicare program. Criminal and monetary penalties. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Comprehensive Error Rate Testing (CERT) Audits The purpose of the CERT program is to measure and estimate improper payments in the Medicare FFS program. Includes both overpayments and underpayments. This requires the Director of Office of Management and Budget (OMB) to: Identify a list of high-priority federal programs of oversight and review, such as the Medicare FFS program. Estimate the amount of improper payments within those high-priority federal programs and submit such estimates to Congress. Report to the public actions the agency has taken or plans to take to recover improper payments and intends to take to prevent future improper payments. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Medicare Appeals Contractor (MAC) One responsibility of the MACs is to reduce the payment error rate by preventing improper payments in the first instance. Activities include providing an educational component including: Targeted provider education to items or services with the highest improper payments. Post-payment or pre-payment medical review targeted to those items or services with the highest improper payments. MACs are authorized to use statistical sampling and extrapolation as part of the medical review activities. Issuing new or revised local coverage decisions (LCDs), articles or coding instructions to educate the health care provider and supplier community regarding the MACs coverage and coding policies. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Supplemental Medical Review Contractor (SRMC) Audits This program is the newest addition to CMS audit programs. The SRMC is tasked to perform and/or provide support for a variety of tasks aimed at lowering the improper payment rate and increasing efficiencies in the medical review to reduce payment errors by preventing improper payments. Specific goals include the following: Using data analysis, identify provider noncompliance with coverage, coding billing and payment policies through data analysis. Perform medical reviews. Perform statistical extrapolations. Notify health care providers and suppliers of review findings and make recommendations for provider outreach and education or possible ZPIC referral. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Recovery Audits The RACs mission is to reduce Medicare improper payments through the detection and collection of overpayments, identifying underpayments and implementing action to prevent future improper payments. Improper payments are defined to include both overpayments and underpayments and may result from: Incorrect Payments Non-covered services Incorrectly coded services (including diagnosis-related group [DRG] miscoding) Duplicate services What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Medicare Integrity Program (MIP) The purpose of the MIP is to promote the integrity of the Medicaid program, by entering into contracts with entities tasked to identify and correct improper payment including those as a result of fraud and abuse. MIPs are authorized to: Engage in medical and utilization review as well as fraud review. Audit cost reports. Recover improper payments made. Educate healthcare providers and suppliers regarding benefit integrity issues. Develop a list of durable medical suppliers (DME) subject to prior authorization. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Zone Program Integrity Contractor (ZPIC) The primary task of the ZPIC is to protect the Medicare trust funds by identifying and stopping potential fraud rather than making a coverage or coding determination. They also determine if possible trends exist to cause integrity concerns such as: Identical or nearly identical documentation Use of higher-level codes more frequently than expected. Hours of billed care per day greater than normally would be expected on a workday. Crime: Probable cause, beyond a reasonable doubt, intent standards. The ZPIC will also evaluate charts for evidence of alteration. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Overview of the Medicare A & B Appeals Process POST PAYMENT AUDIT Stage 1 Redetermination Stage 2 Reconsideration Stage 3 ALJ Hearing Stage 4 Medicare Appeals Council Stage 5 Federal District Court Review Be determined to consider a hearing council for court. Administrative Remedies Judicial Remedies

Administrative vs Judicial Remedies/Review Administrative Remedies: Medicare Appeal Stages 1 - 4: (Law by Contract) Administrative law is not for sissies. Supreme Court Justice, Antonin Scalia Contract with Medicare: DMEPOS Application, Medicare Manual, All Federal Legislation Private Commercial Contract - Arbitration or Mediation, Audit Provisions Judge Judy Contracts Certain rights cannot be waived by contract US Constitutional rights, i.e. due process. Before you can get to Stage 5, you must exhaust the Stage 1 - 4 Administrative Remedies. Judicial Remedies: Medicare Appeal Stage 5 : * Jurisdiction - Personal and Subject Matter Standing * Those without administrative remedies (manufacturers of medical devices, professional associations) may start here.

Appeals Process Flowchart

Appeal: Stage 1 Redetermination Initial Determination really not initial since they reimbursed your claim already. Following receipt of an initial determination, a request may be filed for redetermination. The request must be submitted in writing to the MAC that issued initial determination. Within 120 days following receipt of notice. Mac is required to conclude its redetermination review no later than 60 days beginning on day the MAC receives request. By an individual who was not involved in making the initial determination who is authorized to evaluate all evidence which may develop new issues relevant to the claims. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Appeal: Stage 2 - Reconsideration If party is dissatisfied with a redetermination decision, it may file a request for reconsideration. Your die is cast here. Give it the importance it deserves. The request must be submitted in writing to the Qualified Independent Contractor (QIC) identified in redetermination process. Within 180 days following receipt of notice of partially favorable or unfavorable redetermination decision. All evidence must be submitted at reconsideration review and if failure to do so, absent good cause, new evidence may not be submitted at subsequent stages of appeal. QIC must conclude its reconsideration no later than 60 days following date it receives the reconsideration review. If the QIC fails to meet the date, have the ability to escalate to ALJ stage of appeal. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Appeal: Stage 3 ALJ Hearing If party is dissatisfied with a reconsideration decision, it may file a request for ALJ Hearing. Must be within 60 days following receipt of reconsideration decision. An amount in controversy requirement applies. The ALJ Hearing will be conducted via video conference, telephone or in person (if teleconference is unavailable or extraordinary circumstances exist). An ALJ must conduct and conclude a hearing on a decision of a QICand render a decision by not later than the end of the 90 day period beginning on the date of request has been timely filed. If the ALJ fails to meet the date, a party may have the ability to escalate its appeal to the Council for review. In some circumstances the statutory 90-day adjudication ALJ appeals is extended. These exceptions could result in significant delays. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Appeal: Stage 3 ALJ Backlog ALJ Backlog and Potential Resolutions - the current audit environment has led to a significant increase in the number of requests for ALJ hearings submitted, which has led to an inability for the ALJs to timely adjudicate pending appeals. In an effort to alleviate some of the backlog, OMHA proposed three initiatives: Statistical Sampling Initiative Provides an option to address large volumes of claim disputes pending at the ALJ level of appeal. A trained and experienced statistical expert will first develop appropriate sampling methodology in compliance with Medicare guidance and randomly select the units for ALJ to review. Must be a total of 250 claims in only 1 of following categories: Pre-payment claim denials, Post-payment (overpayment) non-RAC claim denials Post-payment (overpayment) RAC claim denials from 1 RAC. Pre-hearing conference held for consent and order. Once order is issued, becomes binding. All appeals then combined into single appeal and findings made on those units. ALJs decision then extrapolated to the universe of claims. Settlement Conference Facilitation Pilot Provides an alternative dispute resolution process designed to bring the appellant and CMS together to discuss the potential of a mutually agreeable resolution claims appealed to the ALJ hearing level. Pilot limited to Part B appeals. Must include all pending appeals for same item or service and at least 20 claims must be at issue (or $10,000 if 20 claims are not at issue). Administrative Settlement for Part A Inpatient Hospital Claim Appeals CMS offered certain hospitals an administrative agreement to settle claims pending in the appeals process for 68% of the net allowable Part A amount. Hospital must agree to settle all of its pending appeals; it may not choose to settle some claims and continue to appeal others. Limited to dates of admission prior to October 2013 and limited to claims denied for the reason that services should have rendered as outpatient or observation services. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Settlement Conference Facilitation Pilot Settlement Conference Facilitation is a pilot alternate dispute resolution process designed to bring the appellant and the Centers for Medicare & Medicaid Services (CMS) together to discuss the potential of a mutually agreeable resolution for claims appealed to the Administrative Law Judge hearing level of the Medicare claim appeals process. If a resolution is reached, a settlement document is drafted by the settlement conference facilitator to reflect the agreement and the document is signed by the appellant and CMS at the settlement conference session. As part of the agreement, the requests for an Administrative Law Judge hearing for the claims covered by the settlement will be dismissed.

Get More Information for Medicare Appeals ALJ Appeals Information System (AAIS) The AAIS website offers suppliers the following status information: Received OMHA has received the suppliers appeal, but it has not been assigned to an ALJ for review. Assigned The appeal has been assigned to an ALJ for review, and the name of the ALJ will also be provided online. Deliberation The decision for this appeal is being developed by the ALJ indicated online. Decided This appeal has been decided. This includes appeals that have been dismissed or escalated, or decided (favorable, partially favorable, or unfavorable). Despite the websites weekly updates, supplier appeal status will not be available until the case is uploaded into OMHAs tracking system, a process that takes least 4 months from the date the supplier files the appeal, according to OMHA. (Beneficiary-filed appeals receive priority and will be available online within a week of filing.) In addition, the website will not offer status on appeals that were decided or otherwise closed for 180 days, or appeals for which the supplier has requested settlement through CMS.

Appeal: Stage 4 Medicare Appeals Council If party is dissatisfied with an ALJs decision, it may file a request for Council review. A request for review must be within 60 days following receipt of ALJ decision. Council will engage in fresh look at the appeal and may motion to review an ALJs decision or dismissal. Party may request to appear before the Council to present oral argument and may be accepted if decision cant be made on written submission alone; ( i.e. law, policy, etc). Council is required to conduct and conclude a review a decision on an ALJ hearing in 90 days. If the Council fails to issues its decision, have the ability to escalate the appeal to Federal District Court. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Office of Medicare Hearings and Appeals (OMHA) Adjudication Timeframes Requests submitted after April 1, 2013 Deferred Assignment and Filing Alert for Requests and Additional Documentation Escalation Rights Not guaranteed 2 step process

Resource Links for RAC and Status of Appeals RAC: New RAC reviewer for DMEPOS http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance- Programs/Recovery-Audit-Program/Recent_Updates.html RAC Changes http://issuu.com/americanoandp/docs/february_2015_almanac/21?e=6562073/11238678 Appeal Status: Checking for Status of Appeal http://www.hhs.gov/omha/contacts/offices.html

Appeal: Stage 5 Federal District Court Review If party is dissatisfied with an Councils decision, it may file a request for Federal District Court review. An amount in controversy (AIC) requirement applies. The AIC is recalculated each year. In 2014, the threshold for review was $1,430. In 2015, it is $1,460. Must request a Federal District Court hearing within 60 days of receipt of Councils decision In a federal district court action, the finding of fact by HHS are deemed conclusive with substantial evidence support. In certain circumstances, a party may obtain expedited access to judicial review. (EAJR) May be granted if review entity (3 reviewers with ALJ or members of Appeal Board) certifies that Council does not have authority to decide question of law or regulation. The request for EAJR must be in writing. Review entity has 60 days to issue certification for EAJR or deny request. If time frame not met, may bring civil action in federal district court within 60 days of the expiration of time period. A decision to certify EAJR or deny request is not subject to review by HHS. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Legal Challenges to Part A&B Audit Determinations Evidentiary Considerations (Documentation for Appeals) A.Advocating the Merits Draft a position paper outlining the factual and legal arguments in support of payment. Provide medical summaries, charts, etc. that could prove valuable to the decision maker. Also engage a qualified expert to support merit. B.Treating Physician Rule Argument can be made that a treating physicians judgment that a service is medically necessary, is entitled to deference over that of a non-physician medical review contractor. C.Waiver of Liability When a Medicare contractor determines an item or service was not medically necessary, resulting in overpayment, and the provider did not know or could not have been expected to know, that payment would not be made, then nonetheless entitled to reimbursement for the item or service provided. D.Provider without Fault If exercised reasonable care in billing for and accepting payment; or if the overpayment is identified subsequent to the fifth calendar year, then if a provider is without fault, then liability for the overpayment shifts to the beneficiary. E.Challenges to Statistical Extrapolations CMS granted wide latitude in designing and performing a statistical study, providers and suppliers may successfully challenge the validity of the statistical sample and projection: statistical extrapolation may not be used to determine an overpayment. If there is a sustained high level of payment error or documented educational interventions (of the contractor) has failed to correct the error. What are.Medicare Appeals, Gustafson, Pendleton, 2015 American Bar Assn, Health Law Section

Documentation How to meet the challenges of good documentation. Consistency and clarity are KEY! Concise and accurate patient documentation not only helps deliver quality patient care, it also can help ensure timely and complete reimbursement. Remember, not documented, not done. O&P Industry is a professional health care discipline with higher levels of accreditation therefore satisfactory patient documentation becomes important in aiding outcomes research and achieving evidence-based practice. O&P had traditionally documented what we do, not why we are doing it. By explaining the why component within the clinical documentation, you can communicate to those not familiar with O&P, especially payers. Help them understand the cause and effect. Mitchell Dobson, CPO, FAAOP, Director of Compliance, Hanger It is not good enough that you have a prescription anymore. Your prescription has to include your evaluation to confirm that the script is not only appropriate, but meets the patients functional requirement. It is a ABC accreditation and Medicare quality standard, that the practice will conduct a diagnosis-specific patient evaluation... Ted Markgren, CO, Chief Surveyor ABC How to Meet the Challenges of Good Patient Documentation Healio O&P News. Fall 2010

SOAP Notes - Documentation SOAP Notes: S = Subjective Information you gather from the patient. The patients story. Avoid closed-ended yes/no questions. Why did they come in? What are their goals? O = Objective Explain what you see about the patient upon beginning the appointment. Was patient wearing the brace or prosthesis? Avoid using judgment based statements. Corroborate the physician notes, paint same picture to create synchronicity between charts. A = Assessment Clinical knowledge. State what is going on clinically. Explain what needs to be done to address reason for visit and why. P = Plan Describe what you did to alleviate the problems diagnosed in the assessment section. What actions did you take? Include a clear and concise plan for follow up including specific timeframe.

Common Denial Reasons The 5 most common denial reasons are: 1.The physicians records did not provide detailed documentation to support the medical necessity of a custom orthosis. 2.The documentation is insufficient to support that substantial modifications were made for the custom-fitted item billed. 3.No documentation was received in response to an ADR. 4.Proof of delivery is invalid or missing. 5.Detailed written order/prescription is invalid or missing.

Audits, Appeals and Documentation Resources Audit Resource Links: O&P Faces a New Era, O&P News, April 2015 Proof of Delivery Issues-Joint DME MAC Publication http://www.cgsmedicare.com/jc/pubs/news/2014/0814/cope26478.html Molly McCoy L/CPO Produced the SPSCO program. http://www.mccoyconsultingnow.com/blog/ Appeal Resource Links: Guerilla Guide to Medicare Claims "Box Appeals" By James P. Kelly 2011 Updated 2015 https://www.healthlawyers.org/Events/Programs/Materials/Documents/MM14/v_Kelly.pdf Medicare Appeal Forms: https://med.noridianmedicare.com/web/jeb/forms Filing Request for ALJ Hearing: http://www.hhs/gov/omha/Tips%20for%20Filing/%20for%20Hearing/tips_for_filing_requests_for_hearing.pdf http://www.hhs/gov/omha/Tips%20for%20Filing/%20for%20Hearing/tips_for_filing_requests_for_hearing.pdf Medicare Appeals Process: http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network- MLN/MLNProducts/downloads/MedicareAppealsprocess.pdf Documentation Resource Links: Clinical Outcomes and Documentation Education (CODE): http://www.spsco.com/education/code/ Education of specifics of Documentation Requirements and the State of P&O Documentation: http://www.spsco.com/education CMS Documentation Requirements: Prosthetist Survey Results: http://www.oandp.com/articles/2014-04_05.asp The New Reality: Documenting O&P Medicare Claims: http://www.oandp.com/articles/2013-03_01.asp

HCPCS Coding, Competitive Bidding and Fee For Service

Overview (Coding, Competitive Bidding, FFS) This is the area where statistics are born: O & P originally set-up as not solely product (DMEPOS) supplier or not solely a service provider (CPT codes), but a combination of both. This is part of the reason it is such a highly regulated area. Definitions: HCPCS The Healthcare Procedure Coding System is a set of healthcare procedure codes based on the American Medical Associations Current Procedural Terminology (CPT) Level I CPT Codes Level II Products, Supplies, Services, not including CPT codes Competitive Bidding Transparent procurement method in which bids from competing contractors, supplies or vendors are invited by openly advertising the scope, specifications and terms and conditions of the proposed contract as well as the criteria by which the bids will be evaluated. Competitive bidding aims at obtaining goods and services at the lowest prices by stimulating competition, and by preventing favoritism. Fee for Service (FFS) A system in health care by which particular services are paid for individually rather than provided as part of a comprehensive plan. Prospective Payment System (PPS) A payment system used in conjunction with Part A Medicare. Reimbursement is provided according to the insured or condition at the time of admission to the hospital.

HCPCS Coding I.HCPCS Coding Application to add or revise a code. A.CMS/HHS primarily medical in nature, needs FDA registration B.Issue annually requirements national decision required (unless statutorily require item) C.Usually filed by manufacturers, but can be brought by other companies II.HCPCS Code Verification to verify into an existing code. A.PDAC B.Issue after review C.Application 1.Written Application 2.Product Sample 3.Products requiring coding verification 4.Coding verification process 5.FDA information usually filed by manufacturers

HCPCS Decision Tree

HCPCS Coding Items requiring coding verification reviews: A number of items require coding verification review by the PDAC contractor. As noted in the Local Coverage Determinations (LCD) and related Policy Articles that include these codes, claims for these HCPCS codes will be denied if the products requiring coding verification review are not listed on the PDAC Product Classification List. Coding decisions are updated frequently. Suppliers should refer to the Product Classification List often to ensure DMEPOS items billed have been coded by the PDAC. The Product Classification List is located on DMECS which is located on the PDAC website at: https://www.dmepdac.com/dmecs/index.html https://www.dmepdac.com/dmecs/index.html

PDAC - Medicare Pricing, Data Analysis and Coding Tips for completing HCPCS Coding Verification Application: Section A: Submitter Identification Section B: Marketing Information Section B asks for the HCPCS code that best meets the description of the product Search the Local Coverage Determination (LCD) Review and select the HCPCS code in the policy that best meets the product description. Search DMECS to determine if there is an existing code for the product. Section D: Product Listing on DMECS Product Name Manufacturer and/or Distributor Name Model Number Section E: Authorized Office Signature Information to submit with the application

PDAC - Medicare Pricing, Data Analysis and Coding Product Sample Requirements To prevent a delay in processing a coding verification application, a sample product must be submitted for certain DMEPOS products. Sample products submitted as part of this process should be identical to and exact examples of the product(s) that are dispensed to Medicare beneficiaries. For coding verification applications submitted on or before June 18, 2012, the product sample requirements are as follows: Samples are required for the following products: Orthotics Pre-fabricated (OTS and Custom-Fit), and custom fabricated by a manufacturer/central fabrication facility Prosthetics Prefabricated components, e.g. feet, knees Samples are not returned

HCPCS Coding OTS HCPCS Codes (Spinal Orthoses) How were they created? Did they follow Medicare procedure for adding a new HCPCS code? What public policy do they support?

Competitive Bidding What is the Competitive Bidding Program? The competitive bidding program replaces the outdated prices Medicare has been paying with lower, more accurate prices. Suppliers submit bids to certain medical equipment and suppliers at a lower price than what Medicare now pays. Medicare then uses these bids to set the amount it pays for those equipment and supplies under the Competitive Bidding program. Qualified, accredited suppliers with winning bids are then chosen as Medicare contract suppliers. http://www.medicare.gov/what-medicare- covers/part-b/competitive-bidding-program.html http://www.medicare.gov/what-medicare- covers/part-b/competitive-bidding-program.html Helps the providers and Medicare save money. Ensures access to quality medical equipment, supplies and services from suppliers that can be trusted. Helps limit fraud and abuse in the Medicare program. What are the implications for you?

Fee for Service Fee Schedules: Fee For Service (FFS) A fee schedule is a complete listing of fees used by Medicare to pay doctors or other providers/suppliers. This comprehensive listing of fee maximums is used to reimburse a physician and/or other providers, based on HCPCS codes on a fee-for- service basis.

HCPCS, Competitive Bidding & FFS Resources HCPCS Resource Links: http://www.cms.gov/Medicare/Coding/MedHCPCSGenInfo/Downloads/HCPCS_Decision_Tree_and_Definitions.pdf http://www.cms.gov/Medicare/Coding/MedHCPCSGenInfo/Downloads/HCPCS-Application.pdf Verification PDAC: https://www.dmepdac.com.review/tips_coding_verification_app.html https://www.dmepdac.com.review/product_sample_requirements.html https://www.dmepdac.com.review/items_requiring_coding_verfication_reviews.html Competitive Bidding Resource Links: What Medicare Covers: Competitive Bidding http://www.medicare.gov/what-medicare-covers/part-b/competitive-bidding-program.html Directory of Competitive Bid Items: http://www.medicare.gov/supplierdirectory/commonProductsList.html?zip=32204

Professionalism: Evidenced-Based Practice, Protocols, Data Collection

Professionalism: Evidence-Based Practice EVIDENCE-BASED PRACTICE: 1.Know how to read and evaluate research articles and studies. Randomization Blind/Double Blind Studies White Papers/Anecdotal Case Studies 2.Know how to read and evaluate statistical data. Charts/Graphs Standardization in a customized world 3.Create or have created bibliographies or studies that relate to specific aspects of your practice. 4.Collect your own anecdotal data* on specific aspects of your treatment plan and collaborate with other O&P, physicians, physical therapists, et al. * Past trouble spots and complaints of patients and other caregivers is a great starting point to formulate changes. 5.Build standards of care protocols/treatment plans based on your own experiences and research. Use the above to document what you do and why you do it. In your notes, worksheets you create, etc..

AOPA Q2 2015 Legislative Update Medicare Orthotics and Prosthetics Improvement Act of 2015 (S.829 and HR 1530) The Medicare Audit Improvement Act of 2015 (HR 1526) Medicare Proposed Rule on Prior Authorization for Certain Prosthetic Items Medicare Proposed Rule on 2016 Inpatient Acute Hospital Payment Rates and Expansion of Post Acute Care Bundling Initiatives Authority of CMS contractors to implement policy regarding the definition of custom-fitted orthoses. DME MACS Revise Proof of Delivery Requirements ICD-10 Transition

Contact Information Karen Perrin, Attorney at Law [email protected] P.O. Box 330438 Atlantic Beach, FL 32233