Provider Perspective
Views on the Industry's Regulatory Changes, Challenges
Gary Miller, director, Mt. Carmel Medical Equipment.
Editor’s Note: RM spoke with Gary Miller, director, Mt. Carmel Medical Equipment.
What are your thoughts on the national competitive bidding program? How has it affected the major categories you cover?
Gary: Currently, as a rural provider, our service area is not directly affected by the proposed competitive bidding program. However, in the second round of competitive bidding, I know that some of our service area will fall under that program. It is the hope of our company, that this program will not be implemented, as patients will be adversely affected as they are delayed in getting dismissed from the hospital and they are confused as they search for a new approved provider. As we prepare for competitive bidding, we need to remain mindful that some patients may have a different Medicare address on record than their current address that might be in our service area. We have had a couple of patients who live in our service area, but their bills are being taken care of by a family member in a different city. Consequently, the Medicare address on record may be the address of the family member who lives in that different city, which then may fall under the guidelines of the proposed competitive bidding program. We are concerned that those specific patients will be confused as they are forced to obtain service from a different provider who may be located two to three hours from their home. We will do our best to work with those patients in assisting them with locating a provider.
How are you coping with oxygen cuts and has your compliance program changed to meet the new PAP requirements?
Gary: We have been making sure that we are working with our vendors to obtain proper pricing. We have also decreased the number of vendors that we purchase from, which has allowed us to drive more business to them and allow them to provide us with discounts. In addition, we are evaluating patients to ensure that we are seeing them as needed, by both the equipment they are using and the patient’s individual needs. We are not seeing all patients every quarter, as we have done in the past. Our staff is much more aware of the cost of providing home services, and they have embraced vehicle routing for efficiencies.We are making sure that we are checking with patients when we are in a certain area to try to avoid duplicate trips to an area within days of a previous trip. We have also adapted our CPAP compliance program to make sure that we are contacting patients within the required time frames. Our billing software program, Brightree, allows us to schedule future deliveries and the patient notes remind staff members to contact patients within the required time frame. Patients are also informed that we may have to make the CPAP private pay if they do not follow Medicare guidelines, (after issuing an ABN).
“Staying up to date with the regulatory compliance issues has been our largest challenge.”
In what ways have the 9.5 percent cut affected your business this year?
Gary: We are working with vendors to ensure that we have the best pricing, and we are constantly evaluating the equipment that we are providing to avoid service calls. We have seen an up tick in our business, so the increases in sales have offset some of the loss from the 9.5 percent cuts. We streamlined office functions as well with our billing system and have seen numerous productivity gains in that area.
Why is it important that providers get complete orders for home oxygen and other respiratory, and how are providers negatively impacted by incomplete orders?
Gary: Our state board of pharmacy has visited our office in the past, and they checked our compliance to make sure that we had complete orders for the drug we supply (oxygen). The FDA and most state licensing boards that govern DMEPOS require that a complete prescription is obtained when oxygen is dispensed. This means that the name of the drug needs to be on the order, along with liter flow, hours per day, method of delivery and if possible length of need. Providers who are not obtaining this information prior to dispensing oxygen are potentially putting their state license at risk and are not in compliance with the FDA regulations regarding the dispensing of items that require a physician’s prescription. This will also apply to CPAP devices in the respiratory arena and limited DMEPOS items. Some states even require that the prescription be renewed on an annual basis. Suppliers who are not in compliance with this rule may also find themselves out of compliance with their accreditation company.
What is the biggest challenge your business has had to face with regards to all the changes taking place in the industry right now?
Gary: Staying up to date with the regulatory compliance issues has been our largest challenge. We have accreditation requirements, supplier standards, and DMEPOS quality standards and then we also have CMS billing requirements, state Medicaid billing requirements and state rules and regulations that affect DME specifically. It has become increasingly challenging to keep ahead of all these rules and regulations, and make sure that staff remain knowledgeable. Recently a patient corrected me when I explained that the new oxygen rules stated that the equipment would remain the property of the provider. The patient had just called 1-800-Medicare and was told that the equipment would convert to patient ownership, which was incorrect. The patient had to make up his own mind, as he had been told two different things. We did locate the CMS patient letter that explains the new oxygen rules and the patient accepted it as it was printed from the CMS Web site. Even in rural Kansas, patients have been affected when their provider has ceased operations and they are left to look for a new provider. Since the patients have already received oxygen service for three years, we take them on as courtesy after setting them up with the proper compliant paperwork (since no additional payment can be made from the Medicare program). This has created an additional challenge — one that the policy makers did not take into account when they drafted this policy.
This article originally appeared in the Respiratory Management September 2009 issue of HME Business.