WASHINGTON, DC – CMS will eventually require “full compliance with DME face-to-face requirements” by a date to be announced in 2014.
The information released last week further states that CMS “expects all [DME] suppliers to have fully established…..internal processes and have appropriate documentation of required encounters by a date that will be announced in Calendar Year 2014.”
The 9/9/13 press release is almost a word-for-word reiteration of the 6/27/13 press release in which CMS stated that it would not bring enforcement actions until after 10/1/13. Jeff Baird, JD, chairman of the Health Care Group at Brown & Fortunato, points out that the effective date of the face-to-face rule remains 7/1/13.
Based on the language of the press release, Baird says he can make two contradictory arguments. “On the one hand, I can argue that DME suppliers do not have to be in compliance with the rule until the ‘date that will be announced in Calendar Year 2014.’”
According to Baird, this argument is supported by the following language in the release: CMS “will expect full compliance with the DME face-to-face requirements beginning by a date that will be announced in Calendar Year 2014.”
“On the other hand, I can argue that CMS will not start enforcing the rule until after ‘a date that will be announced in Calendar Year 2014,’ but that when CMS does start to enforce the rule, such enforcement will relate back to 7/1/13,” explains Baird. “This argument might be supported by the following language in the release: ‘CMS expects all [DME] suppliers to have…appropriate documentation of required encounters by a date that will be announced in Calendar Year 2014.’ Let us assume that in 2014, CMS announces that enforcement of the face-to-face rule will begin on 1/1/15. Assume that on 3/1/15, a DME supplier gets hit with a RAC audit. Will the RAC expect the supplier to have complied with the face-to-face rule for orders beginning on 1/1/15, or for orders beginning on 7/1/13? The answer to this is not clear in the language of the 9/9/13 press release.”
The lack of clarity adds fuel to the notion that audit and documentation concerns are not going away now or in the foreseeable future. Providers who wish to navigate these difficult waters have many options, including Medtrade, which is scheduled for Oct 7-10.
Issues such as alternative revenue sources will be covered in depth at Medtrade, which will take place in Orlando, Fla, this year. “Patient collection has recently become a critical issue as HME providers redefine their business models to accommodate for the sharp decline in Medicare reimbursement rates and rapid adoption of high-deductible insurance plans,” says Dave Cormack (pictured), president and CEO of Brightree. “Using staff to manually call patients is no longer an option for many providers. Now, modern technology solutions such as those from Brightree and Strategic AR can reduce outstanding accounts receivable balances, create operational efficiencies, and provide patients with a simple, positive experience either online or over the phone.”
Making the Most of the Medtrade Experience
Those who wish to take full advantage of educational opportunities may wish to arrive on Monday, Oct 7, where they can choose from among several workshops and/or seminars. No fewer than eight workshops and seminars are on tap for Monday, Oct 7, at Medtrade Orlando.
Featured presentations are:
• Using Brightree As a Business Management Tool: 10:00 AM – 6:00 PM – Speaker: Kathy Quehl, Training Team Leader, Brightree
• HME Sales Management Revenue Growth Summit: 1:00 PM – 5:00 PM – Speaker: Mike Sperduti, President and CEO, Emerge Sales Inc
• Success in Diversification: 1:00 PM – 5:00 PM – Speakers: Mark Higley, Rob Baumhover, Mike Mallaro
• Keeping Your Business Ahead of the Digital Curve: Tactical Strategies for Online and Content Marketing: 1:00 PM – 5:00 PM – Speakers: Anna McDevitt, Owner, Laboratory Marketing, Lisa Wells, Get Social Consulting LLC
• Operational Efficiencies in Today’s Marketplace: 1:00 PM – 5:00 PM – Speaker: Miriam Lieber, President, Lieber Consulting LLC
• Keep Your Hard-Earned Money: Surviving Medicare Part B DME Audits-A Hands-On Review: 1:00 PM – 5:00 PM – Speakers: Mary Ellen Conway, President, Capital Healthcare Group, Denise Fletcher, Attorney, Brown & Fortunato, and Wayne van Halem, President, The van Halem Group, LLC
• Mobility Documentation and Evaluations Then and Now: What is really needed? How do I get it?: 1:00 PM – 5:00 PM – Speakers: Peggy Walker, RN, Director of Reimbursement, US Rehab/VGM; Elizabeth Cole, MSPT, ATP, Director of Clinical Rehab Services, US Rehab/VGM
• THERAFIRM Certified Fitter’s Training Course: Understanding Venous Disease and the Business of Compression Hosiery: 10:00 AM – 6:00 PM – Speaker: Evan McGill, National Sales Manager, a division of Knit Rite “For those who make the commitment to attend Medtrade, choosing a multi-hour educational opportunity on the first day is a great way to maximize the full benefits of the show,” says Gaffney, group show director, Medtrade. “These seminars and workshops offer the chance to gain in-depth knowledge.
Registration for any of these sessions includes complementary access to the Expo. Some of these sessions also qualify attendees to access the Medtrade Conference as well at no extra charge. Visit Medtrade.com for complete details and to register.