Wheelchairs, pressure-reducing surfaces, and other 'usual suspects' also make the cost-cutting list. The HHS Office of Inspector General's Compendium of Unimplemented Recommendations for 2010, formerly known as the Red Book and the Orange Book, is the OIG's annual list of rules it thinks government regulators should make stricter or enforce more vigorously to save money and reduce fraud. Oxygen suppliers have been working hard on Capitol Hill to secure a repeal of the 36-month cap. But the Centers for Medicare & Medicaid Services should shorten oxygen equipment rental further to 13 months, this year's Compendium recommends. "If Medicare rental payments for oxygen concentrators were limited to 13 months, the program and its beneficiaries would save about $3.2 billion over a period of 5 years," the OIG claims. Other DME-related recommendations in the Compendium include: • Ensuring medical equipment providers' compliance with Medicare enrollment standards (with an estimated savings of $30 million); • Adjusting acquisition costs and services for power wheelchairs (savings: $84 million); • Ensuring that claims for pressure-reducing support surfaces meet coverage criteria; • Reducing reimbursement for negative pressure wound therapy pumps; • Strengthening the appeals process for Medicare equipment suppliers in South Florida; and • Eliminating Medicare's vulnerability to fraudulent or excessive inhalation drug claims in South Florida. A Lot of Hot Air? "The most striking observations about the list of reports are their lack of recognition of payment reductions the home medical equipment sector has received and the lack of recognition of services that home care providers furnish when providing durable medical equipment," notes the American Association for Homecare. OIG reports are misleading, often glossing over the true costs of providing home medical equipment to Medicare patients at home and instead focusing solely on acquisition costs, AAHomecare claims. "As is usually the case, the OIG used bad data and troublesome assumptions to focus attention on why the DME industry is overpaid and the source of enormous fraud and abuse," criticizes Wayne Stanfield of the National Association of Independent Medical Equipment Suppliers. "They still refuse to acknowledge that payments to suppliers have been reduced consistently over the past 10years." And they fail to recognize the service component in providing DME. "The 36-month cap and the 11.8 percent cut to fees last year have already crippled the home oxygen industry, forcing scores of suppliers out of business and many others into financial distress," Stanfield protests. "Reducing the cap to 13 months would in fact be the death knell for the home oxygen business as we know it." "We are becoming a non-profit industry who is expected to work for nothing and give the rest away," Stanfield adds. Beneficiaries are already seeing access problems when they move or travel, Stanfield maintains. The OIG's suggestion to reduce the cap time would increase those. Note: The compendium is online at www.oig.hhs.gov/publications/docs/compendium/compendium2010.pdf.