Domos HME Consulting Group

In This Issue
New Service - Domos HME Billing
CAC - Important Updates!
Good News from CMS - PECOS
CMS - Consignment Closets
Reminder - PAP Sleep Study Rule
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Winter 2010 Newsletter

There's lots of news in this edition of our newsletter. I'm thrilled to announce a new outsource billing and collections service we will be offering very soon.

But there is much more to report as well. For instance, we finally have some good news from CMS for a change! Two items of good news, in fact!

I also wanted to remind our Continuous Accreditation Compliance (CAC) program clients that we have recently posted a number of new and revised policies due to regulatory and accrediting body changes.
Lastly, I've also included a reminder about a Medicare sleep study requirement that has recently gone into effect, along with some helpful links to make sure you've got the new documentation that is required.
Read on for more information about all of the above.

And, as always, thanks for subscribing!
New Service - Domos HME Billing

I'm very excited to announce that Domos HME Consulting Group will be adding outsource billing and collections services to  the many services we already offer for HME suppliers.

I'm passionate about the value of independent providers in this industry, and I've been thrilled with the opportunity to help so many start new DME businesses over the years, and to help others improve their reimbursement processes. 
The addition of a competitively priced billing and collections service furthers our mission to allow our clients to focus on providing quality care to their patients, and growing their business -- instead of getting bogged down in the regulatory mishmash of insurance reimbursement. We know why independent providers got into the DME business, and it wasn't because they loved the reimbursement process!  
The service will go live late this spring. I'll be sending out more details then, but if  you're interested or have questions now, please don't hesitate to give us a call at (425)-882-2035 
CAC Updates!

Clients that subscribe to our CAC program to recieve policy updates as they are mandated by accrediting bodies and / or federal regulations will notice that several updates have been recently posted to the CAC reference site.


These include the myriad of policy changes to the HIPAA manual resulting from the passage of the HITECH amendment. We have also updated and developed policies in response to accrediting body standard changes (which tend to occur, at least for some accrediting bodies, at the end of or beginning of a new year).


The HIPAA regulatory changes are particularly important because they place additional responsibilities on covered entities (read DME businesses) to track and report unauthorized disclosures of protected healthcare information. In addition, DME providers and their business associates have much more accountability (and consequences) around protecting PHI.


We have also updated the mandatory HIPAA employee training materials to reflect these changes, and added a printable summary of the changes to the CAC announcement so our clients would have the option to share the changes with staff members prior to their annual in-service.

Good News from CMS - PECOS
We've been conditioned to hear bad news whenever CMS makes an announcement, but we finally got some good news last week.

The deadline for physician PECOS registration, the provider number database system that physicians must be registered with so that DME providers will be paid for patient equipment ordered by those physicians, has been extended to January of 2011, canceling the previous April 2010 deadline. (Say what? THEY don't complete the equivalent of their 855s enrollment, and THEY get paid by CMS, but DME providers won't get paid? Yes, it's a crazy world!)

My hat is off to the DME supplier who asked during an Ask the Contractor conference call, "So what should we do, just pick up the equipment after April if the physician hasn't registered?" Perhaps CMS reconsidered when faced with the implications of the previous policy deadline.
Should you wish to continue to identify physician's currently enrolled, as required, in the database so you can continue to cajole the rest into compliance prior to the Jan 2011 deadline, you can do that here: Currently Enrolled Physician Database (courtesy of VGM).

Also, be aware that your HME software vendor may have added a feature to check the PECOS database. After Jan 2011 a check for PECOS compliance should be part of the process when adding a new physician to your billing software database.
CMS - Consignment Closets
In another bit of good news, CMS has indefinitely rescinded its rule, scheduled to take effect in March of this year, prohibiting consignment inventory or stock and bill arrangements in physician offices. The notice rescinding the rule can be found here.
Keep in mind, this does not affect the longstanding OIG opinion that "lease or rental payments" by providers to physicians that exceed fair market value for the space to store inventory may be considered a bribe to the physician in exchange for DME referrals. As always, we continue to advise providers to steer well clear those type of situations.
Reminder - PAP Sleep Study Rule
Just a quick reminder that CMS policy, effective Jan 1st, 2010, requires that qualifying sleep studies must be interpreted by a physician with one of the following credentials:
  1. Current certification in Sleep Medicine by the American Board of Sleep Medicine (ABSM); or

  2. Current subspecialty certification in Sleep Medicine by a member board of the American Board of Medical Specialties (ABMS);or

  3. Completed residency or fellowship training by an ABSM member board and has completed all the requirements for subspecialty certification in sleep medicine except the examination itself and only until the time of reporting of the first examination for which the physician is eligible;or

  4. Active staff membership of a sleep center or laboratory accredited by the American Academy of Sleep Medicine (AASM) or The Joint Commission (formerly the Joint Commission on Accreditation of Healthcare Organizations - JCAHO).

The ABSM lookup is here.
The ABMS lookup is here.

The AASM lookup is here.

CMS is suggesting DME providers retain documentation that interpreting physicians meet the requirement. In addition, we are also hearing a few tales about accreditation surveyors asking providers how they are ensuring compliance with this policy prior to billing Medicare. For those reasons, if you haven't already, you may want to bookmark these links.
Thanks for reading, and as always, please don't hesitate to call us with any questions!
Domos HME Consulting Group
on the web:
phone: 425-882-2035