Domos HME Consulting Group

In This Issue
Editorial - Medicare Physician Documentation Rules
Tax Breaks for Small Business
Domos HME Billing - Live in May
New CMS PAP Documentation Rules
Medtrade - Las Vegas
Join Our Mailing List
 Click to visit or join our page as a fan!

Spring 2010 Newsletter

Okay, I admit it -- although I was going to send this email soon anyway, the fact that I woke up Monday morning to read about more draconian rules set by CMS sent me a bit over the edge. That prompted me to move this edition of our newsletter to the top of my priority list. So, for the first time ever, this newsletter contains a bit of editorial by me.
I'm also including information about new tax breaks for small businesses included in the healthcare "reform" law; the new CMS PAP documentation rules (yes, the ones that sent me a bit over the edge); and an update about our new outsource billing service.
Lastly, I wanted to let everyone know where I can be found at the Medtrade show in case any of you are attending. Would love to see you there if you're going!
As always, thanks for subscribing!
Editorial - Medicare Physician Documentation Rules
The first thing I do when I get up in the morning is grab a cup of coffee and read the HME news that is out there to be had. I used to read industry news at night, but I found it kept me from sleeping. These days I find mornings suit me better because the news is bound to fire me up for the day.
This Monday we woke up to new CMS rules pertaining to additional physician documentation required to meet coverage criteria for bi-level PAP devices. They have now added three more elements that are required to be documented in the physician notes. (More information on specifics included below in its own newsletter article.)

By now most of you have heard about the 97% denial rate on the recent Jurisdiction D pre-payment audit of 117 Group II power wheelchair claims. 80% of those were denied for lack of medical necessity documentation. And not because the physician notes weren't there, but because the auditors were not satisfied with the documentation contained in the physician notes.
Say what you will about CMS, but one thing you can't say is that they're stupid. They know that it is difficult, bordering on the impossible, for DME providers to coax physicians to include this much information in their chart notes. But ask any CMS representative and they will tell you -- it is the provider's job to educate physicians about these requirements. Sure, they will give you letters to give to physicians, but it is still the provider who isn't paid when the documentation falls short.
We've been witness to the healthcare "reform" debate for a year, and we've heard plenty of politicians railing about private health insurance companies slithering out of their duty to pay for care when a premium payer is clearly in need of that care. What we haven't heard is that Medicare is one of the worst, if not THE worst offender. (PDF download - Scroll to top of page to 3 see a comparison of denial rates among payers. Yes, this report is about CPT codes for physicians, but the DME denial rate is far worse). 

Let's make no mistake, this is exactly what some of these documentation requirements do -- allow Medicare to slither out of paying for needed care. After all, it's not like there are physicians out there trying to foist bi-level PAP devices onto seniors who don't need them. CMS is clearly attempting to second guess the physician's judgement more and more obtrusively.

So what can you do besides keep trying to educate physicians, and review your documentation with one eye on a microscope and another on the LCD (before providing equipment!)?
One -  educate your congressional representative about this and other CMS rules that are impacting patients and providers alike. And perhaps even remind them that you are an employer in this age of layoffs.
Two - don't provide the care unless you are sure the patient qualifies. The tendency we have to take the order anyway and provide the care when there is a doubt as to coverage shields both the patient and the physician from these rules (and puts you at risk of not being paid!).

Be clear with physicians and patients alike about why you cannot provide the product when you don't have the documentation that is required. Nothing is likely to change until at least some of those patients and physicians are objecting to CMS and their congressional reps along with us.
Tax Breaks for Small Business Owners

Now for some relatively good news for small business owners... the healthcare reform law contains what can be substantial tax breaks for companies with 25 or less employees.


Specifically, the healthcare reform law "Offers tax credits to small businesses to make employee coverage more affordable. Tax credits of up to 35 percent of premiums will be immediately available to firms that choose to offer coverage. Effective beginning calendar year 2010. (Beginning in 2014, the small business tax credits will cover 50 percent of premiums.)"

It's not as simple as all that, however -- you'll want to check with your accountant to see how these provisions may benefit your business. But I suspect that most of our clients providing health insurance benefits for their employees will see some tax benefits in the new law. CNN Money has a good wrap up article that discusses the overall impact of the law for the small business owner.
Domos HME Billing - Live in May
We're live in May with our new billing outsource service. We're proud to be using Pacware software, which we believe is an excellent software program to manage HME businesses. We've been teaching providers best billing practices for over a decade, and now we can put those practices into place for companies that wish to outsource the billing process.
What makes our outsource service different from our competitors? In short, outstanding customer service, long term reimbursement expertise, and a passion for being a full service HME business consulting solution for our clients.

We truly are invested in the success of our clients, and we value our relationships with them. We pride ourselves in making each of our clients feel like they are the most important client we have!
Our billing and collection service will feature a web form that will allow you to input your new patients and their orders directly into our system, and will also provide you with the ability to print accreditation and CMS compliant delivery invoice agreements / tickets, and physician order forms if needed.

In addition, each of our outsource billing clients will be provided free access to a password protected web site, complete with always up to date cheat sheets and other instructional resources to help your staff with the intake process. Our clients will also receive advice and consultation on billing issues at no extra charge.

Our fees are contingency based, so we don't get paid until you get paid. If you're considering outsourcing the billing and collections process for your organization please give us a call to discuss what we can do for you.
New LCD on PAP Coverage
If you have patients that are not tolerating CPAP and have received an order from their physician to move to a bi-level device, be aware of the new physician documentation requirements to justify payment for the E470 device. From the Medicare policy:

For beneficiaries changing from an E0601 to E0470 due to ineffective therapy while on E0601 (either during a facility-based titration or in the home setting), the treating physician must document:

  • The beneficiary tried but was unsuccessful with attempts to use the E0601 device; and
  • Multiple interface options have been tried and the current interface is most comfortable to the beneficiary; and
  • The work of exhalation with the current pressure setting of the E0601 prevents the beneficiary from tolerating the therapy; and
  • Lower pressure settings of the E0601 fail to adequately control the symptoms of OSA or reduce the AHI/RDI to acceptable levels.
Again, our best advice is to educate physicians prescribing E0470 devices for Medicare patients about the new requirements, and do not deliver the device until you have the required chart notes in hand and have reviewed them for compliance with these new coverage criteria!
Medtrade - Las Vegas
We won't have a booth at the Medtrade show in Las Vegas this Spring but we'll certainly be there at the show -- May 11th - 13th. I'll be presenting a seminar on Tuesday May 11th at 2:45 PM. The theme is "Mission Possible" -- how to manage the ever increasingly complex reimbursement process.
Please feel free to stop and say hello if you have time. And if managing your reimbursement process is getting you down, stick around for the presentation. I promise to include lots of practical tips for reimbursement managers.
Current and prospective clients are also welcome to schedule time with us while we are Las Vegas -- just call the office prior to the show to schedule a time.
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