In 2014, CMS announced that Connelly LLC, currently a contracted auditor in Medicare Region C, was awarded the contract to become the first national recovery auditor for DMEPOS. The new national RAC will review claims throughout the entire country for durable medical equipment orthotics, prosthetic and supplies, hospice, and home health effective Jan. 1, 2015.
The Centers for Medicare & Medicaid Services reported on Dec. 30, “CMS has awarded the Region 5 Recovery Audit contract to Connolly, LLC. The purpose of this contract will be to support the Centers for Medicare & Medicaid Services (CMS) in completing this mission through the identification and correction of improper payments for durable medical equipment, prosthetics, orthotics and supplies (DMEPOS), and home health/hospice (HH/H) claims submitted under Title XVIII of the Social Security Act (the Act).”
“The Recovery Auditor will review all applicable claims types through the appropriate review methods and work with CMS and the DME and HH/H MACs to adjust claims to recoup overpayments and pay underpayments. This award marks the beginning of the new Recovery Audit contracts and is the start date of the implementation of many improvements to reduce provider burden and increase transparency in the program.”
This announcement leaves a few unanswered questions: Will RAC activity increase/decrease with this change? Will the auditors remain focused on technical issues or move toward the intent of the program by targeting medical necessity?
If a RAC audit is received involving the Face to Face ruling under the ACA 6407, remember all auditing contractors, except CERT, are not to audit on the Face to Face encounter. This portion of the ruling is still waiting for that “date” to be announced of enforcement. This is retroactive to the implementation date of July 1, 2013. The attached letter can be used to fight this part of the audit. Please note the Face to Face ruling went into law July 1, 2013, stating both a detailed written order and face to face encounter must be received by the DME supplier prior to delivery. Which means suppliers should already be implementing this process. The DME MACs have been auditing on the detailed written order since Jan. 1, 2014.
F2F Press Release
VGM will keep you updated of any further news about this significant change.
Be sure to contact the reimbursement team for any issues or questions.
Ronda Buhrmester, CRT Dan Fedor
Reimbursement Specialist Reimbursement Specialist
Respiratory, General DME, F2F ruling Complex Rehab and Power Mobility Devices
O: 888-665-6518 O: 844-794-8459