Home Health & Hospice Week

Inhalation Drugs:

Answer OIG Inhalation Drug Survey Carefully - Your Fees May Depend On It

 Ask for deadline extension, trade group recommends.

Attention, inhalation drug therapy providers: Don't toss that envelope from the HHS Office of Inspector General in the circular file - it's definitely not junk mail.
 
The OIG this month sent out surveys to a random sample of providers seeking information about services provided to Medicare patients in 2003 related to nebulizer-administered drugs. The initiative comes in the wake of the Centers for Medicare & Medicaid Services' decision to add a dispensing fee for Part B inhalation drugs.
 
CMS could use the data gathered by the OIG to make big decisions about the dispensing fee, "so it is critically important that any provider that received the questionnaire respond accurately," urges the American Association for Homecare. Providers need to capture and record all services provided to the identified patients to document accurately the costs incurred in dispensing inhalation drugs to Medicare beneficiaries, AAH advises.
 
The OIG is asking providers to respond by May 18. However, because completing the survey requires retrieving documentation for 2003 services, providers should ask the OIG to extend its deadline to June 20 to ensure they have time to comply fully with the information request, AAH recommends.

Document Services Outside the OIG's Box

The survey requires completion of a form for each inhalation-related service provided to patients during 2003. However, the questionnaire does not capture all dispensing fee service categories, so providers will have to use additional pages to document the provision of all the unlisted services, which would fall into the "other" category, AAH notes. For example, the survey does not ask about any after-hours or weekend services, and it excludes all billing activities.
 
AAH has requested a meeting with the OIG to discuss its concern that the survey may not collect accurate cost information, but at press time the OIG hadn't responded, says AAH spokesperson Michael Reinemer.
 
An OIG spokesperson declined to discuss the survey, saying the agency is simply too overburdened to offer details on its many initiatives in progress. However, he did note that pricing of inhalation drugs has been an ongoing concern of the OIG. "We done a lot of work on this matter over the years," he tells Eli.
 
Meanwhile, some inhalation drug providers are raising their eyebrows over the OIG's methodology. "Interestingly enough, no one I know has received a survey," reports Wayne Stanfield of the Home Care Alliance of Virginia. Stanfield worries the OIG hasn't selected participants that represent the mainstream.
 
Stanfield is also puzzled over why the OIG is collecting 2003 data when reimbursement cuts for inhalation drugs took effect earlier this year.