Durable Medical Equipment Medicare Administrative Contractors (DME MACS) will be contacting Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) suppliers that submitted claims using both a group name and national provider identifier (NPI) as the ordering NPI for ordered or referred services.
The physician’s name and NPI, not a group name and NPI, must be used as the ordering name and NPI on the claim. Once CMS turns on the edits for ordering/referring services, claims using a group NPI will be denied.
Physicians may verify their individual NPI using the NPI Registry on the CMS website.
DME supplier standards #30 states
“DMEPOS suppliers must remain open to the public for a minimum of 30 hours per week with certain exceptions.”
We have a satellite office that we see patients and as it happens also dispense DME items to them. We, however, do not meet the 30 hours requirement. There is a family practice doctor who is at the location the rest of the time so the office is not technically closed.
Will this create problems for us in a DME audit?
Our main office meets the 30 hours and we dispense DME items from it. Someone is available to answer our phones also most of the week.
Physicians offices who supply DME to their own patients are exempt from the 30 hour requirement. The issue of the family physician sharing the same office space is also not an issue as physicians who supply DME only to their own patients can share office space. This is irrespective of whether both physicians have (or only one has)supplier number(s).
Physicians who own a commercial DME company, however, are not exempt from the 30 hour rule, nor may they share space together. Examples would be a podiatrist who owns a shoe store or a pulmonologist who owns an oxygen supply company. Both would be precluded from sharing the same physical space and both would need to be open to the public for a minimum of 30 hours.
Bottom line: your scenario exempts you from the both the 30 hour rule and the sharing space rule.
Often, a DMERC re-validation investigator will come to inspect your office completely unannounced. To help you be more prepared for it, here is a list of things they might look for.
- Podiatry licenses for all doctors
- Special instructions for diabetic patients form
- Medicare DMEPOS Supplier Standards form
- Proof of Delivery / Return Policy form
- DME Complaint Log form
- List of vendors making orthotics fabrications
- List of vendors making diabetic footwear and qualifications of vendor
- Instructions and Warranty of products
- May take pictures of your DME storage area
- May take pictures of sign outdoor signs
It is our hope that this list will help you be more prepared if you ever have an unannounced visit from an investigator.
Our healthcare system is on a path that is economically unsustainable. One of the greatest challenges to providing broad-based, affordable healthcare coverage is the huge cost associated with diabetic foot disease. The significant costs of treating ulceration, infection and amputation are to rise significantly, based on the increasing incidence of diabetes ands demographic changes.
It’s been demonstrated that a multi-pronged approach to diabetic preventative foot care can effectively reduce the likelihood of foot disease and its associated costs. Podiatrists are well-positioned to implement frequent examinations, direct patient self-care and provide of properly fitting footwear.
Medicare has created programs that support such an approach and offer podiatrists a way to significantly improve practice revenue. The implementation of effective practice protocols is the key to reducing patients’ likelihood of ulceration, and reducing the costs to Medicare while increasing podiatrists’ earnings. A concerted commitment on the part of physicians and patients holds the promise of mutual benefit.