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Audits have become a very grim part of reality for HME businesses, and the outlook for CMS’s audit program looks to get even tougher. This means providers must implement policies and procedures that will minimize the negative impact of audits.
If anything, HMEs are already living a worst-case scenario. Audit contractors recouped an outsized volume of DME claims, and because those recoupments have often been unwar- ranted, providers have appealed them with considerable success. The result was that CMS’s Office of Medicare Hearings and Appeals was so back- logged by appeals that it delayed assigning Administrative Law Judges to appeals for more than two years.
This put providers in a precarious position: how do they keep filing claims while dealing with an audit program so out-of-control it stalled out the appeals process? Yes, the industry can and must work to rein the out-of-control program, but providers need here-and-now solutions.
This is where having the right documentation policies and procedures becomes critical. Proper documentation not only ensures clean claims, but helps providers respond to auditor requests and negate recoupments in the first place. This month’s cover story gets various experts’ insights on claims documentation practices providers should implement.
Documentation . . . . . . Page 22
March 2015 Volume 22, Number 3
hme-business.com
Patient Satisfaction . . . . . . . . . . . . . . 21
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HME Business March 2015 Table of Contents Volume 22 No. 3
Bridging the Gap Medicare might have forced oxygen into heavily cost-conscious business models, but there are still many ways to maximize patient care.
Respiratory Review Respiratory Management’s Sixth Annual Respiratory Survey reviews the factors influencing shape the state of respiratory care today.
Stationary Oxygen Stationary oxygen equipment remains a key part of care for many long-term oxygen therapy patients. We look at some of the latest offerings.
32 36 38
8 HHS OIG: bidding could save N.Y. Medicaid millions; Industry advocates: Bidding Reform Act needs more provider support; AAHomecare to unveil Power Panel at Medtrade Spring; AAHomecare, HHS OIG meet on bidding study; HASCO expects Q4 2014 revenues of $22.7 million; Rhode Island provider gets the drop on Mother Nature; CU enhances A/R Allegiance integration; Resmed acquires Jaysec; Drive acquires Specialised Orthotic Services; Resmed’s Airview integrates with Brightree system; Mediware rolls out CareTend; Convaid, Fighting For Families help girl; Monaghan to take helm of Invacare in April.
6 Editor’s Note
21 State of Satisfaction Patient Satisfaction Data
39 Product Solutions Sleep Therapy Products
41 Advertiser Index
41 Industry Events
42 Observation Deck Being Part of the Solution
22 CMS’s Audit Mountain The steep challenges providers face when it comes to Medicare claims audits have only grown taller. HMEB talks to experts who offer smart documentation polices that can help them scale this difficult summit.
28 Medtrade Spring Preview Medtrade returns to Las Vegas’s Mandalay Bay Convention Center from May 30 to April 1. We look at some of the key events and educational opportunities, as well as preview some of the offerings that will be showcased at the expo.
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6 HMEBusiness | March 2015 | hme-business.com Management Solutions | Technology | Products
No matter what your profession, we often loose track of how important the work we do often is. Even a doctor or a scientist can get caught up in the humdrum routine of workaday life. As a result remarkable work can get lost in the day-today miasma of paperwork, emails, texts, meetings and phone calls.
That’s why I want take a moment and write this column as an homage to the home medical equipment providers, care givers, manufacturers and other professionals that make up this industry. I want to remind you that the work that you do is truly life affirming, and often life lengthening.
I want to tell you a story about my mother: My father passed eight years ago from lung and liver cancer; he was 89-years-old and coming up on his 90th birthday at the time. It was a heart-wrenching loss for our family, and especially my mom. She and dad had enjoyed a long marriage that truly was a long-running love affair. They had met after he exited the U.S. Navy at the close of the Second World War, they started a family, and raised three children, with yours truly bringing up the rear.
Me being the baby of the family, I accompanied them on a retirement move from Northern Ohio to Southern California, went off to college, became a magazine editor, married, started a family and did so all within a few miles of mom and dad. So, when dad passed away, his loss left a pronounced absence in all of our lives, but my mother — someone with an inspiringly positive attitude — kept living and enjoying her children and grandchildren, and life as a whole. She had turned a page on the next chapter in her life story, knowing she’d someday see dad again.
Mom moved out of my parents’ condo and into an assisted living apartment two miles from my home, and started having the time of her life making new friends and hanging out with my family, as well as some of my local cousins. In fact,
mom was so busy, that her social calendar was sometimes overbooked — that’s pretty good for an octogenarian.
Durable medical equipment helped make all that possible. In addition to her shower chair and grab bars in her shower and bathroom, a simple walker acted as a transformative tool that let her continue
living life to the fullest (and I do mean the fullest). With it, she went on family outings with us to church, restaurants, local attractions, museums and even some overnight stays at historic beach cottages that were built when she was a girl. With that walker, she joined her friends on bus visits to local sites such as the nearby harbor, beaches and canyon lands.
Thanks to that walker — some simple aluminum tubes, bearings, wheels and fasteners — mom was able to enjoy and explore her world and visit
with her family, friends and the people she loved, which was exactly the sort of thing that she lived for.
And there are a million moms and families across the country that are enjoying similar life experiences thanks to the equipment this industry provides. That’s a remarkable thing in which you should take immense pride.
Sadly, mom passed away due to a sudden medical issue while we were putting this issue together (and that’s why you might receive it a little later than usual). I am still in grief and mourning, and trying to come to terms with her loss, but I want to express my deep gratitude to this industry for making it possible for mom, my family and I to enjoy eight more years of happy living and making great memories. Thank you, I’ll savor every one of them.
David Kopf Editor HME Business
This Editor’s Note’s for You
I really need to take a moment to give credit where credit is due.
Editor’s Note Volume 22 Number 3
March 2015
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Steve Ackerman President
for VGM Retail Services
Team@Work
BLACKBURN’S
Brightree LLC
Medical Supplies Inc.
Harmar
Providers Association
Kelly J. Riley, CRT , RCP Director
Nat. Respiratory Network
American Association for Homecare
Advisor, US Rehab Division of VGM Group
Wayne van Halem President and Founder
The van Halem Group LLC
EDITORIAL ADVISORY BOARD
SECURITY, SAFETY & HEALTH GROUP
Chief Executive Officer Rajeev Kapur Senior Vice President Richard Vitale & Chief Financial Officer Chief Operating Officer Henry Allain Executive Vice President Michael J. Valenti Vice President, Erik A. Lindgren Information Technology & Web Operations Vice President, David F. Myers Event Operations Executive Chairman Jeffrey S. Klein
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0315hme_EdNote6.indd 6 3/2/15 7:32 PM
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More industry intelligence is available at hme-business.com.
Developing Stories — Monitor HME-Business. com regularly to stay on top of key industry stories unfolding in March, including bidding on the Round Two re-compete of competitive bidding, the continued efforts to get the MCBIA passed, and Medtrade Spring.
Upcoming Webcasts — The latest installment of the HMEB University webinar series, “Solving the Patient Cash Collections Dilemma,” is slated for March 5, and will be presented by Doug Gouy, industry advisor for A/R Allegiance Group LLC. Gouy will provide hands-on, how-to insights on effective ways providers can ensure smooth collection of patient payments. The webinar will be available as an archive after the
event. For more information, visit hme-business. com/webcasts/list/all-webinars.aspx.
FREE Webcasts — There are two recent free webinars that are still online as archives for you to enjoy: “Your Audit Action Plan,” covered latest developments in CMS’s Medicare claims audit program and how providers should respond. This Brightree-sponsored event was presented by a variety of speakers from the American Association of Homecare and Brightree. Also “No Weak Links: How providers can forge an unbreakable supply chain,” showed providers how to implement new supply chains. This was presented by Ryan McDevitt of Brightree LLC, and sponsored by McKesson. For more information, visit hme-business.com/ webcasts/list/all-webinars.aspx.
e-Source — Sign up for our weekly e-news- letter, e-Source, to ensure you stay up to date on the latest industry news, trends and developments.
Follow and Friend us on Social media — You can find HMEB on Twitter at @hmebusiness, and on Facebook at www.facebook.com/ HMEBusiness. Keep track of us on both services to keep up on the latest headlines.
Voice Your Opinion — Have an opinion on how the industry is headed? Join the discussion between involved HME Business readers by posting your comments to any story on the site.
Provider Polls — Participate in our regular online polls, which are always visible in the right- hand margin of our site.
HHS OIG: Bidding Could Save N.Y. Medicaid Program Millions New York providers serving Medicaid patients might have to contend with competitive bidding in more ways than one. A new report from the Department of Health and Human Services’ Office of Inspector General says the New York Medicaid program could save millions of dollars if it implemented its own state-level competitive bidding.
The report reviewed 54 of the 70 selected DME items and found that the New York Medicaid program could have saved an estimated $8.9 million during 2011 and 2012 by establishing a competitive bidding program. The report found that Empire State’s Medicaid agency reimbursed providers approximately $50.8 million for DME items with payment rates above the average Medicare CBA payment rate during HHS OIG’s audit period. The OIG estimated that the state agency could have reduced its payments to $41.9 million if it had used a Medicare-style competitive bidding program.
In its review, the OIG said New York Medicaid could have reduced various broad categories by considerable percentages: • Oxygen supplies and equipment could
have been cut by 28 percent on average. • Standard power chairs, scooters and
related accessories by 14 percent. • Complex rehab by 11 percent. • Mail-order diabetic supplies by 9 percent. • Enteral equipment and supplies by 15
percent. • CPAPs, RADs and supplies by 18 percent. • Hospital beds and related supplies by 18
percent. • Walkers and related accessories by 32
percent.
The genesis for the study was a separate HHS OIG audit that concluded the New York Medicaid program could have saved an estimated $5.9
million on diabetic test strips during a one- year period if it had obtained pricing similar to that which Medicare obtained via its competitive bidding program.
HHS OIG has generated several reports suggesting various state Medicaid programs adopt competitive bidding and similar reimbursement cuts, including California, Illinois, Indiana, Minnesota, New Jersey and Ohio. n
Report from HHS Office of Inspector General recommends that the Empire State agency implement competitive bidding across 54 DME items.
The full report is available at http://1.usa. gov/1MCE6v8, and a summary of the report published by the American Association for Homecare is available at http://bit. ly/1AXcGv7.
n “We all know that the rates used for the analysis are unsustainable. Any short-term savings would be lost as access to the products is compro- mised, and other, more expensive care scenarios unfold, such as ER visits and inpatient stays. An additional consequence of reducing Medicaid spending is the loss of Federal match dollars to the New York economy, and the loss of the multiplier effect of that money. Jobs lost, unemploy- ment claims, and budget woes are just moved from one corner of the table to another. It’s never as simple as it seems; lower price points do not always result in lower cost.” n
Heard on the Web
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Two key bills that would reform competitive bidding continue to make gains in Congress, but industry advocates are urgently calling on HME providers to lobby their lawmakers so that the legislation can be brought to a vote as quickly as possible.
The Medicare Competitive Bidding Improvement Act (MCBIA), which comprises House and Senate bills that were launched as the 114th
Congress began at the start of 2015, aims to remove the central problem of suicide bidding from CMS’s competitive bidding program. To do that, the bills would require bidders in the Round Two re-compete and all future bids to obtain surety bonds that force them to accept bidding contracts. If a bidder declines a contract that is at or above its bid amount, the bidder forfeits the bond.
Industry Advocates: Bidding Reform Act Needs Increased Support from Providers
House bill gains co-sponsors while Senate bill hovers; providers urged to join grassroots lobbying effort.
American Association for Homecare President and CEO Tom Ryan called on providers yet done so to, “Get off the sidelines, get in the arena and join the fight!”
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n “Let’s face facts, over 98 percent of all suppliers did not, in Round Two, and will not, in the Round Two re-compete, receive any contract offers. Another fact is, Congress didn’t have skin in the game in the last bidding cycle and will not this time around, so why would they worry about requiring a Bond that is meant to stabilize prices?” n
Heard on the Web
The House bill, H.R. 284, was introduced by Reps. Pat Tiberi (R-Ohio) and John Larson (D-Conn.), who are both members of the House Ways and Means Committee. Since HMEB’s update last week, the bill picked up an multiple co-sponsors since its launch in January, with its total number of backers at 47 as of press time. Meanwhile, the Senate bill’s performance has been sluggish. S.148, launched into the upper chamber by Sens. Rob Portman (R-Ohio) and Ben Cardin (D-Md.) — both members of the Senate Finance Committee — remains at the four co-sponsors it began with.
Since the bills were introduced, industry
See Bidding Reform Act Support continued on page 12
Join the news discussion on HME-Business.com’s story comments.
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Senate, which quickly advance non-controversial bills that have bi-partisan support through the legislative process. They key is that the bills need far more co-sponsors than they currently have.
“We’re coming to a boiling point on H.R. 284 and S.148, said Jay Witter, senior vice president of public policy at the American Association for
Homecare. “Within two weeks of the bill introduc- tion, more than 2,000 letters to Congress were sent in support of the legislation. AAHomecare alone has had more than 60 meetings on Hill in the last few weeks and we are working our grass tops connec- tions to bring in key members on important commit- tees of jurisdiction on as co-sponsors.”
“We have made progress, but we can’t stop fighting,” said AAHomecare CEO Tom Ryan. “Homecare is going to continue to be a target for budget cutters. Without the constant pressure from AAHomecare in DC, enemies on all sides would close in, either cutting us down to the bone, or regu- lating us into oblivion. This is why we need to keep up continual pressure on in support of binding bids.”
To make that happen, Ryan said providers must get involved. HME businesses need to mobilize their teams to call and meet with their lawmakers and lawmakers’ staff to discuss the negative impact of suicide bidding and the need for the MCBIA to fix it.
“I keep a quote from Teddy Roosevelt taped up above my desk in New York,” said Ryan, “‘The credit belongs to the man who is actually in the arena, whose face is marred by dust and sweat and blood … and who at the worst, if he fails, at least fails while daring greatly, so that his place shall never be with those cold and timid souls who neither know victory nor defeat.’”
“So to paraphrase Teddy – Get off the sidelines, get in the arena and join the fight! Send Action. AAHomecare.org to everyone in your company and ask them to fill out a letter to their Congressperson.” n
AAHomecare to Unveil Power Panel at Medtrade Spring March 31 panel will show how providers’ grassroots efforts and industry’s top-level lobbying work hand-in-hand.
The American Association for Homecare’s Washington Update has been a regular fixture of Medtrade and Medtrade Spring for years, but now the long-standing industry legislative update will be accompanied by an in-depth look at the hows and whys of effective, coordinated industry advocacy.
AAHomecare’s new Power Panel, slated for Tues., March 31 at Medtrade Spring (which will be held at Las Vegas’s Mandalay Bay Convention Center) will feature a team of AAHomecare legislative and regulatory experts, as well as other industry experts, that will demonstrate how top-level legislative negotia- tions work in coordination with personal outreach
Bidding Reform Act Support continued from page 10
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and grassroots efforts from HME providers and other industry members. Real life examples provided by the Power Panel will illustrate the legis-
lative progress that can be made when various advocacy efforts are aligned, and why a unified strategy is needed to succeed on Capitol Hill. In that regard, the Power Panel will also help prepare individuals attending AAHomecare’s May 20-21 Washington Legislative Conference and related legislative meetings.
The Power Panel will include: • Cara Bachenheimer, senior vice president of government relations for
Invacare Corp. • John Gallagher, vice president of government relations for VGM Group
Inc. • Wayne Grau, vice president of legislative affairs for Managed Health Care
Associates Inc. • Mark Higley, vice president of regulatory affairs for VGM Group Inc. • Seth Johnson, vice president of government affairs for Pride Mobility
Products Corp. • Robert Steedley, Jr., president of Barnes Healthcare Services and
chairman of the AAHomecare board of directors.n
“We in the HME industry know the situation is much more complicated than simply stating providers are not carrying the necessary supplies. Low-ball bidding has made it impossible for honest suppliers to carry certain products when the reimbursement rate is lower than the cost of the product, and
documentation requirements from Medicare make the process difficult.”
— Kim Brummett, American Association for Homecare
AAHomecare, HHS OIG Meet on Bidding Study Meeting covered methods for examination of competitive bidding’s impact on patient access to care.
An 11-person team comprised of American Association for Homecare staff and industry stakeholders met with the Health and Human Services Office of the Inspector General (OIG) to discuss its upcoming study on CMS’s national competitive bidding program’s impact on patient access.
The group discussed the goals for the OIG report as well as the meth- odology that has been used in previous reporting on access and utilization rates, according to AAHomecare.
In particular, the association reported that it shared examples of how the bid program makes the process of acquiring or supplying home medical equipment extremely burdensome and has caused many patients to start paying out of pocket for the supplies they need. The association noted that the HME industry knows that paying out of pocket is not a positive shift for the many of the patients that can’t afford to do so.
Case in point: diabetes supplies. A survey on limited access to insulin pumps and testing strips for diabetes patients that was published by the American Association of Diabetes Educators showed diminishing access. Beneficiaries reported difficulties in finding providers with the supplies they needed or the replacement equipment for the insulin pump systems they
were already using, according to the research. “We in the HME industry know the situation is much more complicated
than simply stating providers are not carrying the necessary supplies,” said Kim Brummett, AAHomecare vice president of regulatory affairs. “Low-ball bidding has made it impossible for honest suppliers to carry certain products when the reimbursement rate is lower than the cost of the product, and documentation requirements from Medicare make the process difficult. This is a problem many AAHomecare members are well acquainted with.”
“It is our strong belief that the results of the OIG study will reflect that patient access is affected by competitive bidding,” said AAHomecare President and CEO Tom Ryan. “CMS wants to go with the line that it is good that oxygen claims are decreasing. But the truth is that COPD diagnosis has increased over the years, so how are those patients getting serviced? Competitive bidding not only hurts businesses by eliminating healthy, real competition, it also hurts patients.”n
HASCO Expects Q4 2014 Revenues of $22.7 Million Auto access company’s record-setting fourth quarter net revenues jump 15% from the same period a year ago.
Auto access provider HASCO Medical Inc. (HASC), which specializes in wheelchair accessible vans, parts and service, posted fourth quarter 2014 revenues of $22.7 million, marking the seventh straight quarter of record-setting revenue for the company
Based on preliminary unaudited information, HASCO’s fourth quarter revenues represented a 15 percent jump from the $19.7 million the company took in during the fourth quarter 2013. The company’s total net revenues for 2014 are expected to total approximately $91.2 million, marking a 25 percent gain over 2013’s $73.1 million revenues.
Notably, HASCO’s fourth quarter service were expected to total approximately $4.2 million, which was 36 percent from $3.1 million the company took in during the same period a year prior. The growth in service sales stemmed from increased repairs, lift installations, and sales of Electronic Mobility Controls driving equipment, according to the company.
“Our team’s relentless execution in the fourth quarter led to an unprecedented 25 percent growth in sales for the year in spite of the cold weather and mid-year retirement of the Ford E-series line of vans,” Hal Compton, CEO of HASCO Medical, said. “The growth was mostly organic as we increased awareness about our vehicular solutions to healthcare providers, physical therapists and groups specializing in disabilities. Results were further helped with the completed implementation of our new Customer Relationship Management solution and in-store enhancements aided by our partners at BraunAbility, Harmar, Pride and Q’Straint.”
Compton added that during the fourth quarter the company formed a new Commercial Sales department with specialized Commercial Mobility Consultants that focus on the needs of assisted living, rehabilitation centers and commercial fleet owners.
“For 2015 I expect continued growth from this group with the introduc- tion of the Dodge Promaster and Ford Transit wheelchair accessible vehicles,” Compton noted. “These vehicles offer improved fuel economy and myriad configuration options for our customers and we are bullish on their growth prospects. As a consolidator, we are poised in 2015 to make acquisi- tions and find new locations that support our growth plan.”n
Power Panel continued from page 12
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15hme-business.com | March 2015 | HMEBusinessManagement Solutions | Technology | Products
Rhode Island Provider Gets the Drop on Mother Nature In days before 2015 nor’easter, Absolute Respiratory Care used technology to anticipate and serve patient needs.
Facing down the Blizzard of 2015, Rhode Island provider Absolute Respiratory Care leveraged technology to assist patients that were threatened by the storm forecasted in their area.
The January 2015 nor’easter disrupted transportation with snow emergencies declared in six states, and travel bans in many states, as well. For patients needing oxygen services, such a scenario could quickly turn life threatening.
So, during the weekend prior to the forecasted storm, Absolute Respiratory Care used CareTouch’s contact services to initiate emergency outreach efforts to patients who might need oxygen and wouldn’t be able to travel. CareTouch quickly put a call program together and reached out to about 800 people to identify their need for oxygen. The call campaign also included suggestions for best practices, such as information on which tanks to use first in the event of a power outage.
“Utilizing CareTouch’s call service was the only way we could reach our patients fast and efficiently,” said Jayne Matoian, owner of Absolute Respiratory Care. “When patients are stuck in their homes without power, they need to know which oxygen tanks to use first.
“Some of our customers didn’t even know the storm was coming,” she continued. “With CareTouch’s help we were able to inform them, and make sure their portable tanks were filled ahead of time. Without oxygen, their health could have been negatively affected. We were able to take action before the storm hit to ensure that everyone was prepared.”
“Responding to patient needs is one thing, but anticipating their needs puts Absolute Respiratory Care on a completely different level,” added Matthew Dolph, CEO of CareTouch. “We were happy to get the call over the weekend and help execute the program quickly on
their behalf.”n
Vendor News
Resmed Acquires Jaysec Sleep equipment maker buys Internet tool that streamlines business, care processes for sleep providers.
Sleep therapy product maker ResMed has acquired software company Jaysec, which provides tools that help HME providers resupply patients and
CU Enhances A/R Allegiance Integration TIMS HME software better leverages COLLECTPlus collection service to automate billing, collections.
Computers Unlimited (CU) has upgraded the latest release of its TIMS HME billing and management software with enhanced integration with A/R Allegiance Group, LLC’s COLLECTPlus billing and collection service.
The COLLECTPlus program will better automate many of the billing and collections features TIMS users are already familiar with.
“We’ve had a long-term relationship with A/R Allegiance but saw the need to complete certain aspects of our integration with COLLECTPlus,” said David Schaer, president of CU. “This integration includes added features i.e., auto posting payments, dashboard sign-on, and enhanced statement design available to TIMS users at no additional cost.”
A key element of COLLECTPlus is that combines all the tasks related to billing and collections and combines them into a single-sourced dashboard.
“This completely automated process is transparent, highlighting where, when, and how your money is being collected … and at what cost,” says Keith Lilek, CEO of A/R Allegiance. “… we are thrilled that CU has chosen to integrate it into their programming.”n
0315hme_News818.indd 15 2/25/15 1:05 PM
Resmed’s Airview Integrates With Brightree System Integration will enhance patient management, workflows for sleep providers using Brightree.
ResMed’s AirView sleep patient management system will now directly integrate with HME billing and business management software Brightree.
“Directly integrating with ResMed’s comprehensive AirView patient management system gives Brightree users added capabilities within the software environment and workflows they rely on every day, making it easier for HMEs to focus on patient care as well as long-term
communicate with referral partners. Jaysec’s automated resupply solution, GoJaysec, uses interactive voice response, text and
secure emails to direct patients to a self-serve portal to easily authorize HME resupplies, such as CPAP masks and accessories. This targeted, periodic communication offers a cost-effective solution that automates resupply efforts while cutting down administrative work for the provider.
“Jaysec’s products streamline key HME business practices such as resupply, allowing home medical equipment providers to focus on delivering quality care for their patients,” said Raj Sodhi, president of ResMed’s Healthcare Informatics Global Business Unit. “Acquiring Jaysec furthers our commitment to helping HMEs drive business efficiencies while delivering positive patient outcomes.”
Founded in 2002, Jaysec serves nearly 100 HME customers in the United States, including national HME providers, as well as a smaller number of home healthcare providers. The Jaysec products will now be offered by ResMed, and Sodhi said that ResMed would supporting existing and new customers alike.n
Drive Medical Acquires Specialised Orthotic Services The Buy expands DME manufacturer’s presence in the specialized mobility seating market.
DME manufacturer Drive Medical Ltd., the European subsidiary of Drive Medical, has acquired Specialised Orthotic Services Ltd. (SOS; United Kingdom), a maker of specialized mobility seating solutions.
With expertise in postural management, SOS provides specialized seating systems and other rehabilitation products for mobility patients. As part of the deal Medical Limited also acquired SOS’s manufacturing and distribution facility in Staffordshire, England.
“The acquisition of Specialised Orthotic Services extends our already significant presence in Europe and expands our portfolio of products in the specialized seating and rehabilitation market,” said Harvey Diamond, Drive’s chairman and CEO. “The research and development team at SOS continually develops new products and services for customers to use in their homes and communities.
“This is a strategic acquisition for the Drive family of companies, and complements Drive’s U.S. Wenzelite line of mobility and seating products for children and adults,” Diamond added. “With the acquisition of SOS, Drive Medical has acquired a seasoned management team under the outstanding leadership of [SOS founder and current Managing Director] Gordon McQuilton MBE.”
Richard Kolodny, president of Drive Medical said SOS products such as the “P” Pod, Nessie and its range of postural seating systems will enhance Drive’s global product offering in the seating and positioning segment.
“We are confident that we will achieve additional growth in this area through the intro- duction of Drive’s complementary product lines to the SOS customers,” Kolodny said.n
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SimPle ComfortaBle Convenient
©2015 Invacare Corporation. All rights reserved. Trademarks are identified by the symbols ™ , sm and ®. All trademarks are owned by or licensed to Invacare Corporation unless otherwise noted. Form No. 14-435 Rev. 02/15 150215
14-435rev0215.indd 1 2/10/15 10:27 AM
After a long search, DME manufacturing giant Invacare Corp. has named Matthew Monaghan, a health and aerospace executive with a reputation for turnaround expertise, as its new president and chief executive officer.
The company has been searching for a new leader since the company’s previous President and CEO, Gerald Blouch, retired from his leadership positions with the company and his spot on its board of directors on July 31, 2014. Blouch had come into the CEO position after well-known company leader A. Malachi “Mal” Mixon, III suffered a stroke in 2010. Mixon then announced he was executive chairman of the company’s board of directors, effective Dec. 21, 2014.
Blouch was replaced by Robert Gudbranson, Invacare’s senior vice president and chief financial officer, who served as the company’s interim president and chief executive officer, while retaining his role as CFO.
Effective April, Monaghan will take the helm of the company effective April 1. Until then, Gudbranson will continued to serve as interim president and CEO, and then resume the role of senior vice president and CFO when Monaghan steps into the top spot.
Monaghan currently serves as senior vice president and general manager of Zimmer Inc.’s Global Hips business, where he is responsible for more than $1.3 billion in revenue and the division’s new product development, engineering, clinical studies, quality, regulatory affairs and marketing functions. He also oversees the company’s global reconstruc- tive research group.
Prior to joining Zimmer in 2009, Monaghan spent eight years as an operating executive for two leading private equity firms, Texas Pacific Group (TPG) and Cerberus Capital,
where he led operational improvements of portfolio companies. Among the most notable were the carve-out of a global medical device business from Baxter Healthcare, making significant improvements at a U.S. personal insurance business and running a consumer durable goods business spun off from Newell-Rubbermaid.
“Our Board conducted a thorough and comprehensive search over the past six months and unanimously concluded that Matt is best suited to lead Invacare through this critical time and into its next phase of growth and development,” said Dr. C. Martin Harris, Interim Chairman of Invacare’s Board of Directors. “In addition to his medical device background, he has proven turnaround experience, which will be critical to Invacare as it works through its short-term challenges.”
“I am honored to have been selected to lead Invacare at a time of unprecedented oppor- tunity for the company,” Monaghan said. “Invacare is well positioned to take advantage of the growing global home healthcare market. I look forward to working closely with Invacare’s Board of Directors, executive team and talented and hard-working associates to continue to turnaround this business, innovate, and resume the Company’s historical market leadership position.”
Publicly traded, Invacare detailed the terms of the employment agreement in a Jan. 22 filing with the Securities and Exchange Commission (http://1.usa.gov/1uHYTSL). The agreement runs from April 1 to April 1, 2020, with an initial annual salary of $750,000 per year. Monaghan’s annual Executive Incentive Bonus Plan has an initial bonus oppor- tunity of 100 percent of his annual salary. A Long Term Incentive Plan offers an annual equity grant with a value of $1.4 million as of the April 1 grant date.
The main challenge Monaghan will face stepping into the new role is Invacare’s two-year-old consent decree with the Food and Drug Administration that sharply curtailed the company’s research, development and manufacturing activities. The company is working on passing its third and last audit in order to lift the injunction. n
PEOPLE IN HME Monaghan to Take Helm of Invacare in April
we understand the investment our customers have made in their existing Mediware products, and we will continue to work to ensure their satisfaction with their current solutions.”n
Convaid, Fighting For Families Partner To Help Girl Wheelchair maker and nonprofit group work to give a new wheelchair to a four-year-old girl with cerebral palsy.
Lightweight wheelchair maker Convaid Inc. (Torrance, Calif.; convaid.com) recently partnered with non-profit Fighting for Families (Chicago; fighting- for-families.org) to surprise four-year-old Lydia Hayden, who was born with cerebral palsy, by giving her a new Convaid EZ-Rider wheelchair.
Fighting for Families raises money to provide support and additional services to families with children who have been diagnosed with cerebral palsy. Ancilliary services the group provides include rehabilitation therapy, equipment and support services. The non-profit group planned a special surprise celebration for Hayden and her mother, Teresa, which included an overnight stay at the Westin Chicago North Shore. In addition to the chair, Lydia was given sensory toys, a bed rail to protect her from falling out of bed, an iPad to help with speech development and motor skills.
Darren Nordquist, business development representative with Convaid, worked with Lydia to ensure proper wheelchair fit and that the chair met her exact specifications for safety, comfort and positioning. Nordquist also provided Teresa with a brief overview of the product so she would feel comfortable with the features, including the wheelchair’s ability to fold up compactly, allowing for easy transport.
“We feel fortunate to have been part of such a wonderful event for a very deserving family,” said Convaid CEO Chris Braun. “We value our partnerships with organizations such as Fighting for Families, as it allows us to broaden our reach and support more families in need of assisted mobility products.”
“While the physical items that Lydia and Teresa received are certainly important, they were also given hope, love and support,” said Bradley Egel, event coordinator with Fighting for Families. “I believe we succeeded in meeting both their physical and emotional needs. Thank you to Convaid for being part of this incredible surprise, and for [the company’s] generosity.”n
Mediware Rolls Out new CareTend HME Software Platform Latest HME software release designed to help providers expand current services into other homecare markets.
HME software company Mediware Information Systems Inc. has released its latest offering, CareTend, which combines the features of all the company’s various homecare solutions into one platform.
The CareTend software aims to enhance patient care across the post-acute continuum while helping HME providers, home infusion providers, home health agencies and specialty pharmacies expand from their current service lines into other homecare markets.
CareTend includes new, enhanced user experience features such as an interface designed for easy navigation with fewer clicks and greater personalization. For instance, users can customize their workspace to better fit their responsibilities and workflows. In terms of scal- ability and flexibility, CareTend is designed to support providers with multiple sites and large patient volumes, as well as less complex environments.
In recent years, Mediware has acquired different HME software makers and their products, such as Definitive Homecare Solutions and Fastrack. CareTend would bring all those offerings together into a single solution. That said, the company says it will work with customers on existing systems.
“We have designed data conversion utilities and incentives to make converting to the new platform as easy as possible,” said T. Kelly Mann, president and CEO of Mediware. “However,
business goals,” said Dave Cormack, president and CEO of Brightree. The AirView-Brightree integration is the latest development in a relationship between the two
companies that began in 2013 as part of an initiative to improve workflows for providers using systems and services from both companies. Moreover, the announcement is one of multiple enhancements planned for 2015, according to ResMed. Past advances have included Brightree integration with ResMed’s U-Sleep sleep compliance solution, as well as a data exchange agreement allowing HMEs to order ResMed equipment directly from the Brightree platform.
“ResMed and Brightree are committed to helping their HME customers deliver exceptional patient care while realizing their business goals,” said Raj Sodhi, president of ResMed’s Healthcare Informatics Global Business Unit.n
Medical, aerospace executive fills vacancy left after DME giant’s Pres. & CEO Blouch left top spot in July 2014, and longtime leader Mixon retired at end of 2014.
0315hme_News818.indd 18 2/25/15 1:05 PM
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One of the most critical aspects of growing any business
is surrounding yourself with the right people. Find the right person to fit
the mold, and your business can soar. Get it wrong and your business stays
stagnant, or worse, goes in the opposite direction. As business owners, we are
constantly looking for ways to grow our business. So why is it we are happy
to make large investments to move our business forward, but we cringe at
the idea of hiring another employee and paying market-rate for an excellent
worker? The truth is, having the right retail sales professional is the key to
taking your HME business to the next level. So let’s discuss who should be
running the retail portion of your business, what some of their responsibilities
should be, and how to train and communicate with them successfully.
What Retail Sales Traits to Seek As in any traditional retail business, HME retail sales staff need to be friendly,
compassionate, goal- oriented, self-motivated, and hard working. They also
must be able to communicate clearly and effectively with both their co-workers
and your customers. These characteristics will allow a retail seller to gain the
customer’s trust more easily, allowing them to learn about their health con-
cerns and find the best product to fit their needs.
While the traits above are consistent among most customer service
employees in both the HME and traditional retail industries, retail sales
professionals in HME businesses should also possess some additional traits of
traditional retailers when it comes to product and showroom merchandising.
These include knowledge of visual merchandising, product adjacencies, inven-
tory control and sales reporting, which are essential to managing the retail
portion of your business efficiently.
Internal Versus External Hiring When looking internally, it is important to make sure candidates meet all of
the aforementioned characteristics of an excellent retail seller. Internal staff
may often be excellent at the customer service portion of the responsibilities,
but they fall short in the equally important retail traits.
More often than not, the best retail sales professionals are found outside
of your company. Generally, external applicants are a better option, because
they bring fresh and different ideas, suggestions and experiences to the table.
I recommend two avenues for searching for employees externally. First, seek
referrals from friends or family members of current employees. Second, engage
in active recruiting. When you’re out shopping or eating, pay attention to the
people that help or serve you. If you notice someone that gives exceptional
service, offer to interview them for the open position you have. The benefit of
recruiting is you see the person doing their work firsthand.
When looking externally, be sure to keep an open mind about taking
someone from outside the HME industry and teaching them the ropes. As an
HME business owner, you are an expert in the industry and by spending time
with the new employee every day and answering the concerns they have, soon
he or she will become an expert too.
Giving New Retail Employees the Tools to Excel Once you find and hire the right person, it’s important to be clear about his
or her responsibilities and your expectations up front. Ideally a retail sales
professional is responsible for all aspects of the retail portion of your business
including: ordering, stocking, merchandising retail products, reviewing sales
reports, making operational decisions based on the reporting, and communi-
cating with and training other customer service representatives to reach sales
and business goals.
To continue to push your employees to reach their goals, implement an
incentive program. Incentive programs should be based on both customer
service goals and retail sales and business operations expectations. With the
right retail-minded person in the position, incentives and goal tracking will
not only push them to reach goals but also continue to exceed expectations.
In order for your retail sales person to reach their full potential, set up an
ongoing training program that reinforces the roles laid out in the job descrip-
tion. The goal of training is to supply employees with the tools they need
to meet or exceed your business goals in customer service, product knowl-
edge, and selling. There are endless resources available for you to train your
employees. Ideally, you should offer a combination of individual online course-
work, hands-on sales training, role playing and training on specific products
provided by vendors. Exposing your sales person to a variety of training types
will give them the experience to handle every customer situation.
The final step in coaching your retail sales professional to succeed is
creating a clear workflow structure and communication channel between you,
your retail sales person, and all other employees involved in the retail side of
your business. Start by creating organizational charts and clearly explaining
the workflow to the entire team. An organizational chart defines who an
employee will be expected to work with on a regular basis, allowing them
to communicate goals, expectations and outcomes related to retail sales and
customer service. Workflow charts show who is responsible for the commu-
nication, outcomes and tasks for customer service, purchasing, management
and retail sales among other tasks. Finally, job descriptions should be revisited
annually with the employee and senior leadership to manage changes in the
business and remind everyone of their responsibilities and tasks.
The process of hiring and training a new employee can seem daunting, but
when executed correctly and efficiently, the right retail sales professional can
take your business from stagnant to soaring. n
Finding Your Retail Champion How to find, train and give employees the tools to excel at running your retail business.
Provider Strategy
By Rob Baumhover
Rob Baumhover, director of retail programs with VGM & Associates (Waterloo, Iowa; www.vgm.com), which assists VGM members to diver- sify their HME businesses through improved retail operations. He can be reached via email at [email protected].
0315hme_ProviderStrat20.indd 20 2/26/15 2:52 PM
Outcomes are everything when it comes to providing healthcare, and reporting those outcomes is critical. One of the more “softer” types of patient outcomes data is patient satisfaction. That said, satisfaction is critical and there is a way to generate hard data for that soft subject that can yield worthwhile insights into patient care performance.
Recording patient satisfaction is something that providers are already recording. CMS requires accredited providers to document patient satisfaction as part of their accreditation standards. If providers neglect to do so, it can cost them points on their accreditation score. When a provider is accredited, it must continue to meet or exceed CMS quality standards, and to ensure that happens, every accrediting organization (AO) has to have a standard that relates to a provider collecting patient satisfaction and complaint data from their customers.
CMS doesn’t dictate the measures providers should use to collect the data or what questions to ask patients. In fact, CMS basically looks for a pass/ fail grade given by the provider’s AO regarding the provider’s overall patient satisfaction collection standards. Therefore, each AO differs in its standards of patient satisfaction data collection.
Data as a Valuable Tool While providers are reporting patient satisfaction, the question is, are they recording it and trying to use it as a tool to sharpen their performance and differentiate their services to their referral partners? Beyond just tracking their internal performance, what about comparing it to other providers’ data or national trends?
One Accrediting Organization that is helping providers accomplish that is The Compliance Team Inc. The AO has all of its provider clients use the same tool to collect their customer satisfaction data. This funnels the information they convey regarding patient satisfaction into a database, where it is compared against thousands of other providers. The result: a nationwide patient satisfaction benchmarking resource.
“Providers in our database have the capability to benchmark themselves against the thousands of providers in the database,” says TCT Founder and President Sandra Canally, RN.
To that end, TCT expanded enrollment for its web-based patient satisfaction reporting and benchmarking service last year to include all DMEPOS provider organizations whether accredited by The Compliance Team or by another Medicare-approved accreditation organization.
To date, the firm has collected, aggregated and benchmarked more than 1.3 million patient satisfaction surveys while garnering 10 million standardized data points from providers based in all 50 states, Puerto Rico and the US Virgin Islands, according to Canally.
Enrollees of the online benchmarking service are given on-line access to standardized DMEPOS questionnaires that are utilized to conduct follow- up patient satisfaction phone surveys. The results are then uploaded to The Compliance Team’s national database for aggregation and peer benchmarking.
This Month’s Data: Oxygen To give providers an idea of some national satisfaction trends, The Compliance Team is working with HME Business to provide regular updates on its nation-
wide data. For this month, we’ve picked a key care category: Oxygen. At the outset, it should be clear from the chart, “Oxygen Patient Satisfaction
— 2008 to 2015,” that nearly all patients are satisfied with the services, care and equipment they are getting. But that is not the important data, according to Canally. What’s important is to examine the negative numbers. Providers need to understand who wasn’t satisfied and why, because those are the outliers that will help them improve their businesses. For instance, looking at the chart, let’s say a provider generally does well in delivering oxygen equipment, but had 10 patients over the past two years that did not think that their equipment was delivered in a timely manner — that’s 10 soured patients, possibly 10 soured referral partners, and a fairly decent amount of bad word-of-mouth.
A provider can compare its business to the national trends and see where it might be falling off, and when. Let’s take the first the first item on the chart as an example. If a provider notices delivery satisfaction is down, it can narrow the time constraints to start seeing why so that it can start correcting the problems.
“Were they short delivery personnel on a given day; did they have an incor- rect address,” Canally explains. “There are all sorts of scenarios that could come into play. … It’s all about process.”
But chances are, many of the delivery issues are related to intake, and that is a place that providers can improve.
“The DME receives an order, maybe a patient is being discharged, and the oxygen needs to be waiting at the patient’s home when the patient arrives,” she explains. “… We look at things operationally, so in my mind it relates to [providers’] intake process. What exactly happened during the intake process? Is it a problem between intake and disbursement from the warehouse?” That ability to pinpoint areas of improvement will become critical in the future of healthcare, and will be a key asset for providers to help them improve and reinforce their reputations for reliability, dependability and service. Expect more TCT satisfaction data in future issues. n
The State of Oxygen Satisfaction
New feature from HMEB: Data from accrediting organization The Compliance Team sheds some light on key pieces of patient data.
State of Satisfaction
Equipment/supplies were ready for patient use upon delivery.
Received and understood instructions on proper application and use of equipment/supplies.
Feel condent to operate/use equipment/supplies.
Received info on my Rights & Responsibilities, complaint process, billing, contact numbers, and reasons.
Response to my questions, problems, concerns were addressed in a timely manner.
Satised with the equipment or supplies.
Satised with the service. Would recommend to others.
Yes No N/A
96.77% 0.22% 3.01%
97.16% 0.11% 2.73%
96.69% 0.27% 3.03%
96.63% 0.40% 2.97%
96.17% 0.18% 3.65%
95.45% 0.16% 4.39%
96.95% 0.34% 2.71%
97.12% 0.11% 2.77%
Source: The Compliance Team Inc.
By David Kopf
There’s no easy way for providers to soar over Medicare audits, but preparation and diligence applied to claims documentation today can help providers scale what seems like an insurmountable challenge tomorrow.
Today’s audit of an HME provider’s Medicare (or even private payor) claim can be a very stressful and costly event. All documentation maintained by the provider to support the medical need for the claim and performance of the service being paid is also subject to audit. So the maintenance of accurate and retrievable documentation is crucial to the successful completion of an audit.
You need to adopt sound strategies for good documentation because there are no true ways to become audit-proof and too many factors to predict in good confidence which claims will be chosen.
“Audits are only random in terms of CERT — and that is only because they do a random sample of claims to review,” says Kelly Grahovac, Senior Consultant, The van Halem Group, “Contractors use various factors when determining the types of services to review. There are definitely algorithms or ‘triggers’ that contractors use, such as spikes in billing or denials (supplier specific review) or date of death and inpatient dates that are system edits. And as always, codes with high reimbursements or those that are suscep- tible to abuse are always on the radar. Codes with high CERT error rates are often identified for a widespread prepayment review. Documentation on
By Joseph Duffy
0315hme_Documentation2227.indd 22 2/25/15 12:08 PM
“Sadly, I have no idea.”
“How do my patient satisfaction results stack up against other providers?”
In today’s “show me” world, third-party payers, referral sources, prospective patients and their families want to see proof that your organization’s quality is as good as you claim.
The Compliance Team’s Patient Quality Measurement (PQM) Service gives you the tools to show them how good you really are. Secure and simple to use, The Compliance Team’s web- based service is the DMEPOS industry’s oldest and largest database of its kind. Going back to 1998, we have now collected, aggregated, up-loaded and benchmarked over 1.35 million patient satisfaction surveys — that’s nearly 9 million data points and counting.
As a subscriber, you’ll have the ability to compare your patient satisfaction results in specifi c equipment and supply categories to other providers throughout the USA, Puerto Rico and the US Virgin Islands. In addition to generating industry-wide reports on a macro level, multi- site organizations also fi nd The Compliance Team’s PQM Service especially helpful in obtaining intra-company site comparisons. The best news is that our PQM Service is now open to all DMEPOS providers whether accredited by The Compliance Team or by another Medicare approved accreditation organization. For more information about our surprisingly affordable service call us at: 215.654.9110 or go to: TheComplianceTeam.org/PQM_Service.aspx
Scaling CMS’s Audit Mountain
its own is not a trigger, but if there are certain codes that require specific documentation, such as those affected by the face-to-face requirements, then those codes could be audited.”
Because all documentation dealing with Medicare is at risk of being scrutinized once a claim is audited, whether pre- or post-payment, and because the time frame in which Medicare can perform an audit is six years, it is essential that providers maintain accurate, complete and easily accessible backup for all submissions, says Esther Apter, CEO, MedFORCE Technologies, Inc.
“Our clients have dramatically reduced the strain of audits by using a process management tool that requires the completion of defined docu-
mentation at various stages in the initial authorization or reimbursement process,” she says. “Taking care of proper documentation along the way means you won’t have to scramble after the fact and delivers confidence that you can instantly retrieve everything you need and reduce the burden of audits.”
What’s Being Audited? Kim Brummett, vice president of Regulatory Affairs for the American Association for Homecare, says that documentation being audited includes proof of delivery, written order prior to delivery, detailed written order, ABN, and medical necessity documentation in addition to lab results.
“There are no specific types of documentation being audited more than others,” she says. “Each MAC chooses what it wants to audit. This information is available on their websites, both what is coming up for audit and how these audits score quarterly or whenever the MAC feels like posting the information.”
Apter points out that as reported in the 2013 CMS Audit Report to Congress, only 2.3 percent of all claims and only about 2 percent of the disallowances recovered are DME claims. However, 21 percent of claims corrected by Recovery Audit Contractors (RAC) are DME. Other sources have shown that while DME is 4 percent of Medicare spending, the DME MAC error rate is 51.9 percent compared to Carrier/MAC (9.9 percent). Overall, DME is disproportionately affected by CMS’s policies, underlining the need for stringent record keeping in the DME/HME space.
“The most commonly reviewed documents are physician office notes, and this is across the board for all provider types,” she says. “HME providers are also often audited for delivery documentation, special documentation required for specific types of DME, such as proof of utilization of CPAP devices, and oxygen levels for oxygen providers.”
Grahovac says that from an HME perspective, many of the codes affected by the new face-to-face requirements are seeing increases in audits.
“It’s easy to enact new rules and then see if they are being followed,” she says. “A change as simple as the requirement to have the physician’s NPI on the order is an easy error that can result in an overpayment, which brings more money back into the Medicare program. And, as always, the legibility and quality of physician documentation is on the front of the audit standard. I’m not familiar with a statistic matching documentation to audits per say, but the CMS website does provide data on the DME POS categories with the highest denial rates. [http://go.cms.gov/17mzs3g]. Of course, each of the required documents outlined in the applicable LCD is going to be reviewed as part of any audit, for example, order, proof of delivery, refill requests and continued medical need.”
Why Are Audits so Challenging? According to Apter, HME provider’s audit challenges are much the same as other types of providers. First is the sheer volume of audit requests and the costs associated with providing requested documentation in a traditional paper-driven office. Offices using paper files can be forced to invest many man-hours in finding, copying and preparing documentations for audits. Auditors frequently go back two or three years and can request documentation from as long as six years ago. Older files are often difficult to find. Secondly, tracking audit results and follow-up is a concern. Appeal time limits can be tight and missing a date can cost a supplier its right to appeal, resulting in a loss of revenue. Using a process manager that tracks
Auditing the Audits HME Audit key looks to show impact of Medicare audits on providers
According to AAHomecare, the out-of-control Medi- care audit system puts paperwork before patients, jeopardizes critical care for patients due to the overwhelming number of rubber stamp denials, and hangs small businesses out to dry in the ALJ claim backlog.
“We want smart audits. We want them to be thorough, make sense, and hold people accountable,” says Kim Brummett, vice president of Regulatory Affairs for the American Association for Homecare. “We’re making a stand against a broken process, but we don’t have the hard data to back it up. At the end of the day, anecdotal stories, while powerful, are not enough.”
The HME Audit Key is a way for providers to anonymously show how audits are hurting their business without fear of reprisal from audit contractors. Using a password-protected survey tool, providers can track and share their audits safely and securely with the same third party that the American Hospital Association trusts with their audit data.
The HME Audit Key is simple and easy to use, but as this goes to press, it is still in a beta phase and all benefits might not be available. If you register, it will be deleted at the end of the beta testing period. An announcement will be made when enrollment formally opens.
Once the system is fully built, tested and launched, audit data will be collected on a quarterly basis from HME providers.
By using Provider Consulting Solutions, the same group that created the AHA RACTRAC, we bring the credibility of an objective third party to the table.
Collecting this data will enable AAHomcare to advocate for common sense reforms using strong data and facts, rather than self-reported numbers and anecdotal stories.
AAHomecare is managing and ensuring the security of this project on behalf of the entire industry. With your help, they can use the HME Audit Key to analyze audit data trends and show policymakers why and where the audit system is broken. For more information, visit https://www.hmeauditkey.org. n
“Although it is impossible to completely mitigate the risk of an audit, implementing validation rules within your billing system will help audit-proof claims by ensuring all required documents have been obtained to support a potential audit. … This will improve efficiency while still helping to ensure an audit-proof claim.”
— Sunil Krishnan, Brightree.
will not pay if the physician’s notes don’t back it up,” she says. “Suppliers not only have the challenge of getting the physician to provide documentation, but even worse, they are tasked with educating them on what the documentation needs to say. Then, don’t forget — it has to be signed. And that signature has to be legible. A supplier has many obstacles in providing a beneficiary with equipment.”
these deadlines and can even guide providers through the process is key to ensuring that these opportunities are not missed.
“Even once the appropriate documentation is pulled together, it can be a challenge for HME providers to stay on top of submissions,” Apter says. “When you send by email or fax, it can feel like your submission went into a black hole. That is why we had MedFORCE certified as a one of the first HIH providers, so we can assist our clients in electronic submission of medical documentation.”
Carri Johnson, vice president of Operations, Revenue Cycle Management, Brightree, says that one of the greatest challenges within the HME auditing process is responding to audits within a timely manner. The process of gathering all of the required documents requested in the audit and then ensuring that all of these documents are valid can be very time consuming. Given that a response is expected from the date of the letter, time is of the essence. If you fail to send required documentation in a timely manner, she says, you will begin to receive additional audits, which could lead to an unmanageable workload. In the case of rentals, neglecting to respond to audits will cause the payor to recoup money not only for the original audit date for a rental, but also for all prior or subsequent rentals.
Grahovac says the biggest challenge for HME providers is with the clinical documentation.
“A supplier can have wonderful internal documentation, but that claim
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“Know that if an audit reveals a large number of claims with little to no documentation for the services billed, it will inevitably result in more audits. The goal of these audit contractors is to recoup improper payments and they are going to go where the money is.”
— Kelly Grahovac, The van Halem Group
0315hme_Documentation2227.indd 25 2/25/15 12:08 PM
Scaling CMS’s Audit Mountain
How to Make Sure Your Documentation Is Audit Ready Providers cannot prevent their claims from being audited, says Sunil Krishnan, Vice president of Revenue Cycle Management, Brightree. However, responding to audits in a timely manner decreases the risk of receiving numerous additional audits. In order to keep up with incoming audits, providers should have a process in place to quickly locate and assemble all necessary documents for a claim. The use of an intelligent technology solution that automatically prompts for the necessary documents will help keep the process consistent.
“Although it is impossible to completely mitigate the risk of an audit, implementing validation rules within your billing system will help audit-proof claims by ensuring all required documents have been obtained to support a potential audit,” she says. “These validation rules reflect the requirements of different payors and will automatically prompt for collection of payor- specific information. This will improve efficiency while still helping to ensure an audit-proof claim.”
Krishnan says it is also important to have all documents to support an audit and not just the documents for a claim to get paid. Progress notes is an example where you may not initially need documentation for the claim to get paid; however, this information could be requested later in the case of an audit.
Mary Ellen Conway of Capital Healthcare Group says her office hears constant cries from providers who can’t get prescribers to hand over documents that providers need in case of audits. In these types of desperate circum- stances, she says it is perfectly fine to ask for outside help.
Conway says her clients will have her make presentations to prescribers, such as discharge planners, where she explains the importance of getting the providers the needed documentation. She lets prescribers know that the provider can’t afford to pay back millions of dollars years from now after being audited. She points out how frustrating it can be for prescribers who work with other providers that don’t collect the documentation and set a
different precedent. At the end of the day, it’s easier for the prescriber not to do the work.
“‘So how can we help you?’” Conway says to reluctant prescribers. “‘Can we give you templates? What will make your life easier?’” Conway says they will supply them with outside information and hold conferences to educate them about long-term consequences of not using a provider that follows the rules.
At the end of the day, Conway says a prescriber who refuses to help the provider is basically helping to eliminate local provider businesses that will not be able to afford the final tally of an audit.
To help prescribers comply with your documentation needs, Conway says to hand them the resources they need, such as a copy of the LCD, and highlight all the items they prescribe to you. Make sure it’s laminated or in a state that can’t be wrinkled or lost. Conway’s No. 1 tip to be audit-ready is to collect the documentation from the prescriber at the time of the referral.
Brummett suggests that providers follow all of the rules; know what the requirements are in the PIM, supplier manual and the LCDs; and be sure the intake process evaluates all of the requirements before setting a patient up. Suppliers can use checklists provided by AAH, the DME MACs and other consultants.
Apter says you can mitigate audit risk with the following steps: Become familiar with the provider manual and all regulations that affect
the service of the product being provided. This ensures you will provide the service or product in a way that ensures you will be reimbursed.
Have a clear understanding of the activities needed to get from providing the service or product to payment, including the documentation needed to support each step. You need to have a line of sight from start to finish to make sure you stay on track.
Create a consistent process to assure that the necessary documentation is obtained at each step of the process. It saves time and effort to gather what is needed at the time of service, rather than have to backfill later. Train personnel to understand the process and all requirements. They need to be reviewing documents accurately to assure that they meet the requirements. Because of the quantity of rules and the fact that they often change, having a central workflow that forces users through the correct steps for each product line should help to ensure that the needed documentation will be on file to support payment in an audit. Finally everyone should put in place a well-documented and implemented internal audit process that periodically reviews files for accuracy and completeness. This will catch any errors or incomplete files before it reaches the demanding CMS audit phase.
One of the biggest documentation mistakes you can make is not reviewing the clinical documentation you have on hand, says Grahovac.
“Too often, a supplier gets audited and the documentation does not substantiate the service,” she says. “Scrambling to obtain documentation from months or even years back is difficult and doesn’t always yield positive results. It’s almost like you are setting yourself up for failure. And know that if an audit reveals a large number of claims with little to no documentation for the services billed, that will inevitably result in more audits. The goal of these audit contractors is to recoup improper payments and they are going to go where the money is.”
Another documentation mistake is not having the documents on hand when a claim is submitted but believing they can be obtained if you get audited. Krishnan says in the event that a claim is audited, the payor will
“Taking care of proper documentation along the way means you won’t have to scramble after the fact and delivers confidence that you can instantly retrieve everything you need and reduce the burden of audits.”
— Esther Apter, MedFORCE Technologies Inc.
Mary Ellen Conway
of Capital Healthcare
hand over documents
types of desperate cir-
cumstances, she says it
for outside help.
then ask the provider to provide proof of all the pertaining valid documents. If the provider did not obtain these documents prior to submitting the claim, they might find it rather difficult to do so after the fact.
Grahovac says it’s important to remember that the supplier is responsible for educating the physician on the documentation needed.
“It would be ideal to have a good relationship with the referral source, allowing for open communication should the need for additional documentation or addendums be needed,” she says. “While that may not always be the case, from a business perspective a good habit to adopt is that of reviewing the documentation as it comes in to ensure it supports the equipment being provided. If there are repeated inconsistencies, consider your source and the risk involved in continuing to take on those referrals. The bottom line is that suppliers must be proactive in order to be prepared.”
Though difficult to predict, signs indicate that Medicare audits will continue to increase in both volume and frequency. With CMS encouraging contractors to extrapolate, Grahovac says the amount of funds coming back
Joseph Duffy is a freelance writer and marketing consultant, and a regular contributor to HME Business magazine and Respiratory & Sleep Management. He can be reached via e-mail at [email protected], or joe@proofe- rati.com.
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