Home Health & Hospice Week

Work plan emphasizes medical necessity documentation.

Durable medical equipment providers should redouble efforts to ensure their services are medically necessary--and are thoroughly documented as such.

The HHS Office of Inspector General's work plan for fiscal year 2006 identifies several target areas for DME, with most of those relating to proof of medical necessity.

"There weren't a lot of surprises in the plan," attorney Seth Lundy of Fulbright & Jaworski's Washington office tells Eli.

The OIG will examine the following areas of DME provision:

• DME payments for home health patients. The OIG will review medical records for DME items and supplies furnished to beneficiaries receiving home health services to determine if the items were reasonable and necessary.

• Medicare payments for therapeutic footwear. The agency will look at documentation of medical need for therapeutic footwear. A previous OIG report found that a significant percentage of payments made for such footwear lacked adequate documentation.

• Medical necessity of DME. The OIG will consider the appropriateness of payment for items including power wheelchairs, wound care equipment and supplies, and glucose test strips.

• Medicare pricing of equipment and sales. Investigators will compare Medicare rates for certain equipment and supplies with the rates paid by other federal and state programs as well as with wholesale and retail prices.

• Home blood glucose testing supplies. The OIG will assess the appropriateness of Medicare Part B payments for test strips and lancets.

The DME payment system is about to undergo big changes with the upcoming implementation of competitive bidding and supplier quality standards, Lundy notes. That raises questions about how relevant the OIG's findings might be.

"Any recommendations the OIG makes may not be applicable to the new payment system," Lundy observes. "The work plan may be outmoded."

Note: The OIG work plan is online at www.oig.hhs.gov/publications/workplan.html.