Ask the Contractor Teleconferences (ACT) - CGS Medicare · CGS Ask the Contractor Teleconferences...

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Operator: Well, good day everyone and welcome to the Provider Outreach and Educaon - Ask the Contractor Teleconference. Today’s conference is being recorded. At this me, I would like to turn the conference over to Miss Zita Upchurch. Please go ahead Miss Upchurch. Zita Upchurch: Good aſternoon everyone and welcome to the CGS Ask the Contractor Teleconference for the DME MAC Jurisdicon C Suppliers. I’m Zita Upchurch with Provider Outreach and Educaon. And I’m joined today by addional representaves from our Provider Outreach and Educaon Department along with members with many of CGS operaonal areas who are here to help lend expert - their experse. I’d like to thank each of you for parcipang in today’s call. Your parcular parcipaon helps us to idenfy issues that are important to you so you may beer meet your educaonal needs and provide available resources to assist in the audit process. Please keep in mind that we are unable to answer quesons about individual claims or address any issues that would contain protected health informaon. For specific claims issues, please contact our provider contact center at 1.866.270.4909. To check claims status you should use our interacve voice response system or the IBRs at 1.866.238.9650. For addional resources our website is hp://www.cgsmedicare.com. Today’s call is focused on the Medicare audit program. There are four specific enes that conduct audits within the DME program. They are CTS’s medical review, housed within the jurisdicon C DME MAC operaons. And three other contractors, the Zone Integrity Contractor or the ZPIC, the Comprehensive Error Rates Tesng Contractor or the CERTS, and the RAC the Recovery Audit Contractor. Each has its own focus but overall goals are the same of all four contractors and this is to protect the Medicare Trust Fund. I’m going to take a brief moment to describe each one. CGS Medical Review Department conducts both pre-pay and post-pay claim audits with the goal to reduce payment errors by idenfying and addressing billing error concerning coverage and coding made by suppliers. The CGS Medical Review Department consists of our Medical Director, Dr. Robert Hoover, registered nurses, clinicians, and other specially trained support staff. CGS Medical Review performs both widespread probes which focus on specific policy groups or billing codes and suppliers specific reviews. The most common errors found in medical review probes can be broken down into three categories. Insufficient proof of medical necessity, incomplete or missing proof of delivery documentaon, and incomplete or missing detailed wrien orders. Next I’m going to talk about the CERT program. The CERT contractor for jurisdicon C is Advanced Med. And their process is conducted enrely on a post payment basis. It is focused on idenfying that claims were paid correctly. Claims are idenfied on a random sampling basis. Then the CERT contractor requests documentaon from suppliers for those claims. The CERT contractors then use local coverage determinaons and Medicare guidelines to perform a complete review of those claims. Let’s move on now to the ZPIC process. The Zone Program Integrity Contractors were implemented by CMS in an effort to ensure the highest integrity of its programs and healthcare security for all beneficiaries. This is accomplished by prevenng, detecng, and deterring Medicare fraud and abuse. Their dues include supporng law enforcement, answering complaints, data analysis, and supporng benefit integrity through medical review. Jurisdicon C has been divided into three different zones to carry out the CMS requirements. Zone 4 is reviewed by Health Integrity. It includes Colorado, New Mexico, Oklahoma, and Texas. Ask the Contractor Teleconferences (ACT) Moderator: Zita Upchurch Date: September 29, 2011 Confirmaon #: 1858418 Time: 1:00 pm CT Page 1 © 2011 Copyright, CGS Administrators, LLC.

Transcript of Ask the Contractor Teleconferences (ACT) - CGS Medicare · CGS Ask the Contractor Teleconferences...

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Operator: Well, good day everyone and welcome to the Provider Outreach and Education - Ask the Contractor Teleconference. Today’s conference is being recorded.

At this time, I would like to turn the conference over to Miss Zita Upchurch. Please go ahead Miss Upchurch.

Zita Upchurch: Good afternoon everyone and welcome to the CGS Ask the Contractor Teleconference for the DME MAC Jurisdiction C Suppliers.

I’m Zita Upchurch with Provider Outreach and Education. And I’m joined today by additional representatives from our Provider Outreach and Education Department along with members with many of CGS operational areas who are here to help lend expert - their expertise.

I’d like to thank each of you for participating in today’s call. Your particular participation helps us to identify issues that are important to you so you may better meet your educational needs and provide available resources to assist in the audit process.

Please keep in mind that we are unable to answer questions about individual claims or address any issues that would contain protected health information.

For specific claims issues, please contact our provider contact center at 1.866.270.4909. To check claims status you should use our interactive voice response system or the IBRs at 1.866.238.9650. For additional resources our website is http://www.cgsmedicare.com.

Today’s call is focused on the Medicare audit program. There are four specific entities that conduct audits within the DME program. They are CTS’s medical review, housed within the jurisdiction C DME MAC operations. And three other contractors, the Zone Integrity Contractor or the ZPIC, the Comprehensive Error Rates Testing Contractor or the CERTS, and the RAC the Recovery Audit Contractor.

Each has its own focus but overall goals are the same of all four contractors and this is to protect the Medicare Trust Fund.

I’m going to take a brief moment to describe each one.

CGS Medical Review Department conducts both pre-pay and post-pay claim audits with the goal to reduce payment errors by identifying and addressing billing error concerning coverage and coding made by suppliers. The CGS Medical Review Department consists of our Medical Director, Dr. Robert Hoover, registered nurses, clinicians, and other specially trained support staff.

CGS Medical Review performs both widespread probes which focus on specific policy groups or billing codes and suppliers specific reviews. The most common errors found in medical review probes can be broken down into three categories.

Insufficient proof of medical necessity, incomplete or missing proof of delivery documentation, and incomplete or missing detailed written orders.

Next I’m going to talk about the CERT program. The CERT contractor for jurisdiction C is Advanced Med. And their process is conducted entirely on a post payment basis. It is focused on identifying that claims were paid correctly. Claims are identified on a random sampling basis. Then the CERT contractor requests documentation from suppliers for those claims.

The CERT contractors then use local coverage determinations and Medicare guidelines to perform a complete review of those claims.

Let’s move on now to the ZPIC process. The Zone Program Integrity Contractors were implemented by CMS in an effort to ensure the highest integrity of its programs and healthcare security for all beneficiaries.

This is accomplished by preventing, detecting, and deterring Medicare fraud and abuse. Their duties include supporting law enforcement, answering complaints, data analysis, and supporting benefit integrity through medical review.

Jurisdiction C has been divided into three different zones to carry out the CMS requirements. Zone 4 is reviewed by Health Integrity. It includes Colorado, New Mexico, Oklahoma, and Texas.

Ask the Contractor Teleconferences (ACT)Moderator: Zita Upchurch Date: September 29, 2011

Confirmation #: 1858418 Time: 1:00 pm CT

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Advanced Meds which handles Zone 5 includes Arkansas, Alabama, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, and West Virginia.

ZPIC activities for Florida, Puerto Rico, and the US Virgin Islands which is Zone 7 are completed by SafeGuard Services. The ZPIC’s conduct both prepay and post-pay audits using the same Medicare manual policy, LCDs, and NCDs used by the MACs.

Lastly, I’ll detail the work of the Recovery Audit Contractors or the RACs. Connolly Consulting performs the RAC work. And their jurisdiction covers the same states and territories of the jurisdiction C DME MAC.

The mission of the Recovery Audit Contractor is detect and correct past improper payments. And to implement actions that will prevent future improper payments.

RAC audits are post-pay audits only. The RACs choose areas of focus based upon CERT, OIG, and GAO reports along with data mining techniques and the experience and knowledge of their staff. One unique difference between the RAC program and the three others already mentioned is that their work covers all parts of the Medicare Program A and B. the other three audit programs focus only on the DME.

Before we open the line for questions, I would like to point out a few resources that can assist you as a supplier and prepare you for an audit. And are also excellent resources for quality claims submission.

CGS provides 19 policy specific documentation checklists covering the medical policies that have the highest claim billing. These include glucose monitors and supplies, power mobility, manual wheelchairs, PAPS, and oxygen. These forms are located in the forms in medical review section of our Website. A thorough and complete intake process is vital to obtaining appropriate documentation. And to that end CGS provides a sample intake form.

Obtaining quality documentation during the intake and billing process is one way to ensure your response to audit will be timely. Additionally, CGS provides several letters that can be effective in communicating with referral sources. These letters also available on our Website are signed by our medical director.

They explain to physicians that suppliers are partner in providing care for the beneficiary. It also informs the physician that payment will not be made for the needed services if they do not provide the corresponding medical record. And that it could result in the beneficiary having to cover the cost of the services themselves.

And lastly the letter informs the physician that it is a Federal requirement to provide this information and that it is in keeping with HIPAA registry rules.

Our tools available are the jurisdiction C educational opportunities to include, workshops, informative webinars, and online education modules relevant to your business. Registration is currently open for the webinar focused on the audits process. If you would like to support the information that we are providing here today.

We’re now going to open the lines for the question and answer portion of our call. As a reminder please limit your question to those pertaining to the audit process. We will not be able to answer questions pertaining to individual claim issues. And please contact our provider contract center at 866-270-4909 to resolve any of those questions that you may have.

We are going to limit your questions to one per supplier so that we may be able to address as many callers as possible.

Operator, will you please go ahead and open the lines for questions?

Operator: Absolutely, Miss Upchurch. Well, ladies and gentlemen, if you wish to ask a question, please press star then 1 on your touch-tone telephone. You’ll hear a prompt asking you to record your name and if you’re using a speakerphone, please make sure your mute function is turned off. Once again, everyone, that is star 1 if you would like to ask a question. And again, everyone, that is star 1 if you would like to ask a question.

We’ll hear first from Amanda

Amanda, your line open; please go ahead with your question.

Amanda: Okay we have a question. We’ve called team and spoke to a few different people. And they have told us that we aren’t able to send in the prepayment audit within the 30-days. Once we have that denial some have said it still needs to go to the medical review first prior to going into redeterminations and then others have said as long as you have the denial you can go ahead and send to redetermination.

Zita Upchurch: No, ma’am. It needs to go into the medical review department first.

Amanda: Even if you’re after that 30-day.

Zita Upchurch: All of this information - if you did not provide within the time it was requested it will go to the department first that requested it.

Amanda: Okay, so even if it’s outside of that 30-day window that’s allowed we still need to go to medical review before going into the appeals process. Is that correct?

Zita Upchurch: Yes, ma’am.

Amanda: Okay, thank you.

Zita Upchurch: You’re welcome. Have a wonderful day.

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Operator: Moving on to Gerard Francisco.

Gerard Francisco: Thank you very much. My question - my question is in reference to discharge summaries from hospitals as part of the medical documentation.

As you are aware, there are different entities that require for medical documentation. So for example if we are talking of oxygen and our initial evaluation would be the discharge summary coming from the hospital in which is being ordered.

Thus the discharge summary has to be signed by the physician because in almost all cases the physicians will be on the discharge summary as well as the name of the hospital. But not all the times is the physician - is the discharge summary actually signed by the physician.

Mark Loney: Hi, Gerry, this is Mark Loney with Provider Outreach.

I guess focus on the core elements of what’s required. Your detail written order needs to be signed by the supplier. You have to have a verbal order to dispense. That meets those requirements as well.

As far as discharge summary or a specific piece of paper in that situation being signed by the doctor, there’s not a policy requirement for that, so.

Pay attention to those core elements. And you know, there might be some paperwork that you gather to support the medical need for the item or proper delivery of the item that aren’t necessarily signed by the physician.

Carol Bradley: Mark, can you hear me?

Mark Loney: Oh, I think Gerry was asking if that is the face-to-face evaluation does it need to be signed and the answer is absolutely yes.

Mark Loney: Yes. I understood that - let me back up since we’re doing a transcript. Carol Bradley with Medical Review is the one that spoke there.

I understood the question to be specific to oxygen. If it’s - if it is with something that requires a specific face-to-face timeline that would be a different answer.

Gerard Francisco: Yes, actually, Carol, thank you for jumping onto the call. That was exactly the context of the question because, as you know, for oxygen and I’m using for example the prepayment audit process. The CGS letter actually has a reminder towards the end of the letter about the record being authenticated.

And the challenge that we are having from - from medical documentation obtained from hospitals in which - in which the scenario is the patient was submitted to the hospital. And then

the patient is being discharged from the hospital with an order for home oxygen.

When we obtained that medical documentation that would serve as our initial evaluation not all instances is the discharge summary signed by the physician. Many times they are but not all of the times.

So our question is, of course, we have a CMN, we have the copy of the test that was performed at the hospital within two days prior to discharge. We are also relying on the discharge summary to serve as our initial evaluation. Must that piece of document actually bare the physician’s signature in whatever format, you know, electronically signed by.

Carol Bradley: <inaudible> signed by the physician either handwritten or electronic. CMS, you know, CMS says for us to consider any medical record we have to - it has to be signed by the physician, yes.

Gerard Francisco: So Carol, what would be your recommendation if some medical documentation such as discharge summaries that hospitals are sending us does not bear a physician’s signature. How do we - how do we report it back to them?

Carol Bradley: You have to get an attestation statement signed and send that with the documents.

Gerard Francisco: I see and in reference to that scenario also sometimes the piece of paper that we receive from the hospital would be the discharge order coming from the discharge planner...

Mark Loney: Gerry, let me - let me...

Gerard Francisco: ...and the discharge - and there is typically a nurse at the hospital. That piece of paper would not be signed by the physician. It’s signed by the - by the discharge planner. Do we need...

Mark Loney: Let me jump in here for a minute here, please.

Let’s make a distinction between authenticating a document or authenticating a record and something actually being hand signed by the physician. We’re getting I guess very nuts and bolts here about specific types of documentation.

A discharge statement from the hospital might contain information that is not generated by the physician, is really going to apply to the situation and the documentation that you gather.

If you’re using a piece of documentation to support medical necessity or the need for the oxygen, it’s going to have to be authenticated that it was created by the physician. If there’s other discharge information on another piece of paper or another electronic communication that you receive simply

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about the patient’s time of discharge and maybe a medication list or what have you. That’s not something that would have to be hand signed by the physician.

It needs to be authenticated; we need to be able to tell how it was created. So just make sure, I guess, stick to the - the requirements that medical necessity information needs to be authenticated by any of the audit agencies that it was created by the doctor. That could happen a variety of ways given paper or electronic documentation.

Gerard Francisco: Thank you.

Mark Loney: Thank you.

Operator: Louis has our next question.

Louis: Yes. My question is that when we get a denial specifically for like a CO150 same or similar because the patient has had the equipment for one or two months from a previous provider. And it’s been picked up and we go to redetermination with the pick-up documents and get that, our month of service, paid. Why are the subsequent months of service all denied for the same CO150?

Mark Loney: Give us just a moment here, (Louis). We’re going to have a discussion here real quick around the table.

Louis, without - it gets a little tough to - to take look at, you know, in a general term without taking a look at the specific claim.

I think you’re correct in your assumption that once you get a new piece of equipment set up that claims on down the line shouldn’t continue to be denied as same or similar. If those...

Carol Bradley: <inaudible>.

Mark Loney: ...should not, yes. If those claims had processed once your - your good initial data service has paid. It would seem to me that they may be denying an error something that telephone reopening’s can fix.

They might have to, you know, change the way something is set up so that it’s reading the correct payment to pay. But if, you know, all those things being - being equal if the new one is set up and now subsequent ones have been denied after the original one was set up then it looks like maybe something that’s happening in error that reopening’s going to fix.

Louis: So you say we should be able to go to a telephone reopening for that second...

Mark Loney: Right.

Louis: that we think.

Mark Loney: For any of the denials that happen once your initial was set up.

Louis: Okay, thank you.

Mark Loney: Thank you.

Operator: Moving on to Deanne.

Deanne: Yes, I believe I heard Zita say that there is a Federal requirement to provide information to the supplier by the physician when requested. Can you tell me if that is in any request for information situation or if that is only in an audit situation?

Mark Loney: Yes. The - I don’t know about every specific instance but I know that the letter - the physician communication letter - references the exact portion of the Social Security Act. And I’m being told its Code of Federal Register 42 that describes all those situations.

I know for sure if you have an audit request in hand, it’s required. I would be hesitant to name any more specific situations but that letter addresses the specific section of the Social Security Act that talks about it.

Deanne: And that reference, again, was?

Mark Loney: CFR, Code of Federal Regulations 42.

Deanne: Okay because I’ve heard that physicians are not legally required to respond to <inaudible> documentation unless it is in an audit situation. So if there was any way that we had any information we could use to go to physicians when we’re requesting...

Mark Loney: Sure.

Deanne: ...documentation that would be very helpful because, as you have heard often that’s probably one of our biggest struggles.

Mark Loney: Sure. You know, if you want - if you want to print out that exact language to provide that would - that might be helpful.

Like I said I would agree with you. I know absolutely for sure once you’re holding an audit request they would have to provide that. I don’t know what other situations as far as general practice but, you know, everybody in the - in the care chain for the patient is a covered entity under HIPAA law, so.

I don’t, you know - if you want to use that exact language that might be good.

Deanne: All right. Thank you very much.

Mark Loney: Thank you.

Operator: Moving on to Eric.

Eric, your line is open; if you’re on a speakerphone, please depress your mute function or pick up your handset. Eric, again, your line is open please go ahead with your question.

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Well, hearing no response, I’ll remind the audience once again that it is star 1 for questions. And we’ll now hear from Stephanie.

Stephanie: Hi, good afternoon. Thank you for taking my call. I just have a general question. We’re getting a lot of calls from patients and facilities referencing us bringing out new medical equipment for these patients, the current equipment is broken, broke down. The companies have gone out of business, their phone numbers are disconnected and I’m just wondering is there any way that we can start servicing these new patients.

Mark Loney: This is - yes, I realize this something that we’re seeing a little bit more of in some specific geographic locations and certain product categories. When you are taking on care for a patient though, the existing payments and what’s on file and what’s already been done still applies, so it’s probably something you would have to investigate on a patient by patient situation and then make a business choice whether to do it or not.

Stephanie: Right, well let’s say they’re basically hospital beds and oxygen. The hospital is three or four years old, they’re falling apart. Their wheels are coming off and the company’s out of business.

The concentrators are not calibrating properly and the companies are out of business. So is there any way that we could...

I’m sorry?

Mark Loney: Sorry, go ahead.

Stephanie: I was just wondering is there any way that we could in and give the new equipment and be able to get new capped rentals.

Mark Loney: Not inside a reasonable useful lifetime, you know, given five years, 60 months or unless there’s a specific incident of damage. And we can use those rules to start a new capped rental. But unfortunately if the equipment’s there and it’s reached a cap the other company being out of business is not reason enough to start a new capped rental.

Stephanie: Well, how do they go about getting it fixed properly? I mean, can we fix it for them and charge for that?

Mark Loney: You can bill for repairs for some equipment, certainly, if the equipment has repair billing. And it’s going to vary between, you know, what kind of equipment it is. You can bill for repairs on it but we can’t just start a new capped rental without, you know, without being past that reasonable useful lifetime.

Stephanie: Okay, thank you.

Mia Gott: Stephanie, this is Mia Gott with Provider Outreach and Education. From an audit perspective, you do want to make sure one of the top errors that are being called through the CERT contractor is if you decide to repair that equipment. That you are providing the medical necessity for the piece of equipment itself so that your repairs are payable.

Stephanie: Okay. Thank you.

Mia Gott: You’re welcome.

Operator: Caller, please go ahead; your line is open. Caller, if you’re on a speakerphone, please depress your mute function or pick up your handset.

Well, hearing no response, let’s move on to Amanda. Amanda, your line is open; please go ahead with your question.

Amanda: Hello, yes, I had a question about we have a lot of the medical review audits that come through because we deal with an extremely high volume of eneral patients. And one of our denials that we received back from Med Review was needing a common reference number.

Basically linking us to the patient and to the supplies that we were billing for. And I don’t understand what they mean by the common reference number, I’ve never heard of that denial.

Mark Loney: Carol, go ahead if you want to but I’m guessing this is probably a deliver, proof of delivery type of thing.

Carol Bradley: Yes, it has to do with delivery. You know, you’re required to detail out what you’re sending. And a lot of times if you are sending to a nursing home for example you might be delivering to multiple patients. And so you would be required to detail out what is being sent for each beneficiary. And if you’re using a shipping service usually they lump everything together.

And so what you’re going to have to do is if you provide us a detailed list beneficiary by beneficiary of what is being sent. And you’ve got some kind of manifest or UPS tracking slip or something like that. Then you have to give us some kind of reference so that we can match the two pieces of paper together.

And what you choose to use is up to you. You could like use a PO Number or you could use a tracking number, you know, it’s your choice as to what to do. And you can type it in or you can hand write it in but we need some reference number that’s on both sheets of paper so that we can match things up. Does that make sense?

Amanda: Yes. I mean it makes sense. We do have the delivery ticket that shows, you know, 120 cans of the Jevity 1.28 ounce sent to the patient. And what we did was we - and I sent this along with my audit documentation.

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But what we did was we actually ordered the Jevity from McKesson which is the supplier. And McKesson delivered it to the patient’s home. So I’m looking at this slip that was sent over. And it shows where it was shipped to, who signed for it and exactly what was sent. You know, two cases of this and whatever.

So that’s what was kind of throwing me off because it is pretty detailed on the documentation that we did send.

Carol Bradley: Well, I mean, you know, obviously this isn’t really the place where I could look at say, oh, yes, you know, you’re right.

Amanda: Yes, I was just.

Carol Bradley: I can tell - I can explain to what - what we should be saying when you see that denial.

Amanda: Okay.

Carol Bradley: But as to, you know, whether it’s valid or not really isn’t, you know, something that I can do that.

Amanda: Well, I mean it could’ve been that maybe one of the pieces of documentation didn’t transmit over or something when I faxed it.

Carol Bradley: Yes.

Amanda: So I mean there could be, you know, a lot of things actually. So I could just try resending it.

Carol Bradley: But that’s what - that’s why we use it is to say, you know, you’ve got two pieces of paper but I can’t match them up.

Amanda: Yes, it’s just - this is the first time that I’ve heard common reference so - I had no clue what they were talking about. And you know, whenever I called over and I spoke with the, you know, they customer service rep they’re pretty much just reading what Med Review, you know, put in there and they, you know, they really didn’t know either so. Well, I’ll just resend that. So thank you for your help.

Carol Bradley: Okay. Sure.

Operator: Trish has our next question.

Trish: Hello?

Carol Bradley: Hi, (Trish); go ahead.

Trish: Can you hear me?

Mark Loney: We sure can. Go ahead.

Trish: Okay, my question is documentation. We keep getting denial saying we’re not sending in the proper documentation. And according to the Integra Guard List we are sending in

everything that they’re asking for and they’re still denying our claims.

Mark Loney: I’m going to have to answer your question in a very general basis. Integra Guard is part of the ZPIC process which while it’s certainly part of today’s topic we don’t have a lot of specific information about their process.

So you know, I would just remind you depending on the policy group that you’re billing at us to make sure that any and all medical necessity information is documented. That it’s diagnosis specific, that your documentation supports that. And then ultimately to remember that ZPIC or any audit agency decision is appealable if you so choose.

So if you don’t agree with that decision you can certainly request a redetermination.

Trish: Okay and then the next thing is that they take so long to get back to us once we submit a claim. Some of them we submitted like last year and they still have not given us an answer yet.

Mark Loney: Yes. And again unfortunately that’s a question that would have to be directed to the ZPIC contractors either SafeGuard Services or Integra Guard which is a contractor of theirs.

Trish: Okay, all right, thank you.

Mark Loney: Okay? Thank you.

Operator: Lynn has our next question. Please go ahead, Miss Mills.

Lynn Mills: Hi, can you hear me? Can you hear me? Hello?

Carol Bradley: Yes. We can hear you.

Mark Loney: Yes, go ahead.

Lynn Mills: Okay. I have a Medicare - it was an audit - a prepay audit on a CPAP machine. And it came back denied stating that the physician did not sign or date the documentation. But it is clearly electronically signed and actually even states that.

It says, “Electronically signed by Dr.” gives the doctor’s name, the time, the date, everything on there. Is there something - what are we doing wrong with that? Do we have to have the doctor’s actually physically sign it?

Mark Loney: No. And that’s probably a good - I guess quick discussion to have here about electronic documentation. Electronic documentation that is completely electronic can be electronically signed. And vice versa, paper documentation or non-electronic documentation can not be - it needs to be signed by hand.

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So I wouldn’t say there’s a requirement to hand sign electronic documentation that is otherwise already properly authenticated. So and again, without being able to look at that specific example I would advise you to appeal it because you don’t agree with that decision.

Lynn Mills: Okay. We’ve appealed it. It went to RiverTrust Solutions and the same thing. So we’ve got it with the Administrative Law Judge.

I mean it’s - to us and the doctor it’s very clearly because we had a discussion with the doctor and it’s like what more do they want? It’s signed, so I didn’t know if there was something...

Mark Loney: Yes, I wish I could - I wish I could be more helpful without the specific instance, you know, looking at it though. But if it’s gone to that level of appeal then it’s moved past us and they’ve continued to say the records are not valid.

Has there been any - any description I guess at the RiverTrust or the reconsideration level about why it’s not valid?

Lynn Mills: No, they just said that the forms where not signed by the physician. And I mean it’s - I don’t - everything there. Every set of dictation notes that are done. The sleep study, everything is certified and signed off by the physician electronically.

And we’ve, you know, we’ve gone through an Advanced Med audit and we had some that came back with that also. And they’re clearly electronically signed medical records.

Mark Loney: Yes. Bear with me here just a moment.

In - in this process at all have you spoken either with customer service or with our CERT coordinator about some of these records?

Lynn Mills: Yes.

Mark Loney: Okay, we’ll go ahead and follow up - follow up that way then so we have some specific items that we’re looking at to deal with other than speaking in generalities.

We’ll go ahead - we’ll go ahead and follow up that way then.

Lynn Mills: Okay. Thank you.

Operator: Moving on to Gary.

Gary: Hello, can you hear me.

Mark Loney: Yes.

Gary: Yes, okay thank you. This question also has to do with signature requirements. We recently failed a CERT audit on a nocturnal oxygen patient and what was indicated to us was that the nocturnal oximetry report which was clearly identified as a by a particular IDTF was not authenticated or was missing signature of the performing documenting provider, unquote.

Is it true, first of all, that all diagnostic tests including these clearly identified nocturnal oximetry reports have to be signed and if so by whom, the IDTF?

Mark Loney: In any situation, if we’re talking about an IDTF that’s doing overnight oximetry or if there is, you know, a take home PSE, Pap test that’s performed. The - a physician - whether it’s a prescribing physician or one who’s reading the test and, you know, documenting the results of it; will have to be authenticated at some point.

The IDTF can certainly provide the results of the test but at some point the physician before the order is written is going to need to see that and indicate their approval.

Gary: So with chart notes it indicates that the physician recognizes that this patient has nocturnal hypoxia due to the test and that chart note being signed - would that be adequate? Or do we need to make sure that every one of these nocturnal oximetry reports are actually, literally, signed by the physician himself?

Carol Bradley: If Medical Review was reviewing that we would not require a signature on an oximetry report. We would on a sleep study evaluation but we would not on an oximetry report. But you have to recognize that CERT may have a different view of that.

Gary: Okay, so it looks like they may be requiring it. We were just trying to figure out if this was error that we should appeal on there - you know, we should appeal this up through the CERT system. Or do we - because we haven’t been doing this had never been - never understood that we needed to.

Mark Loney: Yes. I would also - I would encourage you to appeal it. If you have that oximetry test read, if you will, and by the physician and agreement with it is noted and all of that. Again, the records are generated in so many different formats I can’t tell you that a specific piece of paper generated by the overnight oximetry machine has to be signed, it might not.

It might apply to the way the records are transferred. If that’s the only gray area - if it is referenced in chart note or medical note and all of that is good then absolutely I would tell you to appeal it if that’s <inaudible>.

Gary: All right, great.

Mark Loney: ...really the only reason that’s for the denial.

Gary: Okay, appreciate that.

Operator: Caller, please go ahead; your line is open. Caller, if you’re on a speakerphone, please depress your mute function or pick up your handset.

Hearing no response, I’ll move on to Kimberly.

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Kimberly: No, it’s not on mute. It’s on speaker and call but I said, “Kim,” I didn’t say, “Carlos.”

Mark Loney: Go ahead we can hear you.

Kimberly: Can you hear me?

Mark Loney: Yes. Absolutely, go ahead.

Kimberly: Okay. We have a question regarding replacements if you have any protocol because we’re getting review denials for initial notes and research notes for oxygen. And we’re also getting denials for CPAPs for interpreting physician board certification.

Mark Loney: Okay and both of those questions are specific to replacement devices?

Kimberly: Correct.

Mark Loney: All right. Well I’ll address them both individually.

With oxygen there are pretty clear rules that are laid out for replacement of oxygen. And what kind of testing and CMM needs to be preformed for replacement oxygen. I’m assuming this is a replacement due to five year reasonable useful lifetime where usage has been on ongoing basis and continues.

So there’s a pretty clear guideline for that. You do need to obtain a new CMN. There’s not a requirement for testing within 30-days but you would want to report the most recent test on that CMN.

Kimberly: Right. And we do have valid testing. We do have a brand new CMN.

Mark Loney: Good.

Kimberly: But we are getting current denials stating that we don’t have notes within 30-days prior to the new initial. And we don’t have 90-day notes prior to the research.

Mark Loney: And those are CERT denials, correct?

Kimberly: No. These are prepayment.

Mark Loney: Do you know which contractor’s performing those?

Kimberly: CGS.

Mark Loney: Okay. Well I can tell you what’s in the policy. And again, maybe I sound like a broken record with the appeals process.

Carol Bradley: Mark, can I step in? Because we are changing this - I mean this is like in the next couple of days changing, so.

In the past, we have - and I’m talking about Medical Review - we were - the expectation was that suppliers would have to provide the documentation for the original equipment in terms

of showing us that it met medical necessity. So we weren’t looking for an evaluation within 30-days of the new initial but for the previous initial.

We actually had a FAQ that we published in the summer, this summer that had a list of all of the documentation that we were looking for - in terms of the original equipment. And what we were looking for in terms of the replacement equipment.

That FAQ has been updated. It should be posted. I just approved it. So it should be posted online later this afternoon.

So basically now all we’re looking for is new initial and those things; but anyway you can go out - you should be able to go out tomorrow to our Website and look up the summer 2011 FAQs and I believe its’ question number seven.

If you look at the answer, it will tell you what we’ll be looking for now on in terms of documentation for replacement.

Kimberly: Thank you. Okay. And is that also for the CPAPs that were updated or any replacement?

Mark Loney: Well, the CPAPs have different rules. It’s coming out of a different LCD but those are also I think fairly clearly stated in the existing FAQs that talk about what’s required in a situation where Medicare paid for the previous one. And the patient has had continuous use.

You know, the CMNs are in that policy obviously but, you know, there’s that compliance and data portion is absent but they do need to go and see their physician and can be documented that they continue to use and benefit from the item from that standpoint.

Kimberly: Yes. And we do have a new face-to-face in. They’re continuing and benefitting from the equipment. What we’re getting denials on is let’s say a sleep study from 1997 stating that certifications for the interpreting physician were not included. And that wasn’t required until January of 2010.

Mark Loney: Correct. Well, on take home it was before that but yes. For most tests going forward it was January of 2010. And again I would agree with that standpoint. On a continuous patient that had the test qualified for Medicare previously that we don’t have to have the test. That requirement was not in place say in 2007.

Kimberly: Okay. So should those just go to appeal stating that it’s not required?

Mark Loney: Absolutely.

Kimberly: Okay, thank you.

Operator: Moving on to Karen. Karen, if you’re on a speakerphone, please depress your mute function or pick up your handset.

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Hearing no response, I’ll move on to Kerri. Kerri, your line is open. If you’re on a speakerphone, please depress your mute function or pick up your handset.

We’ll move on to Beth.

Beth: Yes, ma’am. I need to know - we have had some that our proof of delivery has denied because it’s been like the week before during a holiday. If that falls during a holiday because they don’t deliver for Christmas and they don’t deliver on the New Year. Why is that not covered as a proof of delivery.

Mark Loney: Let me just clarify your question. The proof of delivery was denied because it was - when it was delivered is different from your date of service?

Beth: Yes. It’s like a week before. We supplied a nursing home.

Mark Loney: Right.

Beth: And it’s like the week - the week before, say if we need to deliver for the first part of the month. Instead of being delivered on January 1st we may deliver that last week of December because there’s no delivery.

Mark Loney: But you’re still billing in January?

Beth: Right. We have to deliver...

Mark Loney: Yes. That’s - that’s going to deny every time. The date of service has to be the date of shipment in a mail order situation or date of delivery in other delivery, you know, retail locations that kind of thing.

There is an allotment for early shipping on supplies like that to allow for that kind of thing. But if you have a date of service that does not match your date of shipping that’s going to 100% deny, expect that.

Beth: So there’s no way - I mean even we send to reconsideration and we explain why we did it. They’re still not going to approve that?

Mark Loney: I would imagine no. That’s a pretty - that’s a pretty hard and fast delivery statute that we can’t - that we can’t get around.

Instead of making your actual delivery and date of service, use an earlier date of service with the same explanation as to why you delivered it when you did. Take into account the new delivery guidelines. I say new, they’re about a month old.

That gives you ten days prior to the expected end of the current supply.

Beth: So there’s a ten day leeway there?

Mark Loney: There is.

Beth: Okay, let me ask you another quick question. If we have a patient - like I said we supply nursing homes. And we have a patient that we deliver supplies to. They don’t use them all. They go in the hospital and they keep inventory there and we don’t order any more for the rest of the month.

As far as that proof of delivery goes should that still be good for the whole month?

Mark Loney: Yes. And this is a situation that is unique to enteral nutrition in that once the supplies are open we can’t take them back. I don’t think - I don’t think pharmacy laws in most states will allow you to take them back and redeliver them to somebody else.

So once they’re delivered for that patient and used for that patient if they have to go a skilled nursing - or excuse, to a hospital or something like that. And they can’t use them. There’s really not a way to transition them, if you will, to somebody else or what not.

You can certainly document that they have that many supplies left. They come back to the nursing facility and pay it forward, if you will. And deliver less of an amount the next month

Beth: Okay, thank you.

Operator: Casey has the next question.

Casey: We had a quick question on the doctors. What if they absolutely refuse to give us medical records? I know you said that’s against the Federal requirement. What if they absolutely refuse to do is there anything we can do to make them cooperate with us?

Mark Loney: Past providing them the requirements that we’ve mentioned with the letter that’s in the Social Security Act. At that point it really just becomes a business decision about whether to continue to take referrals from them.

You know, obviously you want to serve your patients as best as possible and we understand that. But if a particular physician is going to put you in a situation where you can’t get paid for those items then it becomes a business decision whether to continue to provide that service or not.

Casey: Okay because we’ve had several that do that and I mean they say, well, just have Medicare call me. And I’m like okay.

Mark Loney: Yes. That’s probably not going to happen. I would, you know, that’s - and again I understand that’s a tough situation to be in. It’s a referral source that you’re trying to maintain a relationship with. But if they simply won’t provide anything despite being shown why they need to, then you just have to make that decision about whether it’s worth continuing to accept those referrals.

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Casey: Okay, thank you.

Operator: We’ll now hear from Miranda.

Miranda: Yes, ma’am. I had a question about a patient we have, they have. And it’s kind of a general question as well. If we have a patient that has oxygen and we already have an initial and a recert CMN on file. What happens if after the fact, the doctor tests them, they now have a portable added to that CMN.

My question is, is it okay to do initial revised, recert CMN? We’ve been told by Medicare reps when we call in that that is the case; that our billing agency is disagreeing with us. And my concern is that if this eventually gets audited, you know; a year or two down the road.

Then we’ll have to go back and get something corrected. We want to do it right going from the beginning.

Mark Loney: Yes. Certainly, and I don’t have - I guess I should’ve brought my computer with me so I could read it exactly. But I - almost - Carol, you’re going to have to help me out here. I’m almost 100% certain that with a - adding a portable to an existing stationary system is a revised CMN.

Carol Bradley: Correct.

Mark Loney: Thank you.

Miranda: Right but in this instance we have - we already have an initial and recert on file.

Mark Loney: That’s fine.

Miranda: So would it be correct to send in an initial revised recert?

Mark Loney: Well, let me - okay let me - if we’re looking at the CMN, there are three spaces up top.

Miranda: Right.

Mark Loney: You might already have the initial and the recertification filled because you’ve - you’ve already gone through that process.

Miranda: Right.

Mark Loney: Adding a revised now with a current date, yes, you would have all three spaces on CMN filled up. And that’s correct it’s a revised CMN with those old initial and recert dates on it. So you would send it - if you essentially looking at the piece of paper, potentially would have all three dates filled up.

Miranda: And would that being said, once a year rolls around do we need to get another recert for that CMN? I mean it’s already been recert.

Mark Loney: No, because it’s already been recertified.

Miranda: Not, <inaudible>.

Mark Loney: Submission of the revision doesn’t change the recert schedule so if it’s already been recertified we can just add that portable to it.

Miranda: Okay, thank you Mark. I appreciate y’alls answers.

Mark Loney: Sure.

Operator: Ann has the next question.

Ann: Yes, thank you for taking my question. I want to go back to the question that (Amanda) asked regarding the comments reference - the common reference number denials that they’re getting.

I just need to make sure I understand. And here’s the situation. We have a request for information on an enteral patient. We provide the progress notes that show we have contacted the beneficiary prior to the refill. We’ve asked the appropriate questions of what items need to be refilled.

That is then matched with a delivery ticket that is specific to that beneficiary’s address for those items that were requested. It may be noted on that delivery ticket that it is being shipped via UPS or shipped via FedEx. And then we have the accompanying shipping document that has the UPS verification of the shipped delivery date or FedEx shipped delivery date that has the beneficiary’s name and address again.

So are we then to understand that the delivery ticket has to have that FedEx or UPS tracking number on it as well?

Mark Loney: Carol, I think you addressed the question previously do you want to comment again?

Carol Bradley: I mean, you know, it’s very difficult to answer a question about whether your documentation is good or not without seeing your documentation.

You know, in general terms there is information that we need in order to verify coverage and coding and delivery. In the case of enteral nutrition we need to know specifically what you are providing to that beneficiary. The date that you either delivered it or shipped and the confirmation that it was delivered which can be, you know, tracking information, it can be an actual signature.

Now in the case of suppliers that bill to nursing homes, what we are finding in many instances the information is not on one sheet of paper. It’s on multiple sheets of paper.

So if the information that we need in order to confirm delivery is on multiple sheets of paper. We need a common reference number on all those sheets of paper whether it’s two or ten in order to piece it all together.

If you have one document that has everything we need on it,

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we don’t need a common reference number.

Ann: I do appreciate your response. However I do know that these situations are not nursing home situations. They’re individual patient deliveries that are going to the beneficiary’s home. So if they’re being denied for a common reference number on both pieces of paper. Again, my question is I have the beneficiary’s name and address and the items that we sent with a date.

Carol Bradley: Well, if you have that information - if you’ve got a couple of examples if you send those to Mark, he’ll pass those on to me. And I’ll look them up. And if it’s something that we see that, you know, nurses to be educated on then we certainly will, you know, address that with the staff and if I see something on your end that’s a problem, I’ll let you know. Will that work?

Ann: Oh, that would be excellent. We just want to make sure that we’re doing it correct and that we understand...

Carol Bradley: I understand - I understand.

Ann: ...what it is you’re requiring.

Carol Bradley: And we want to make sure we’re doing it correct too. But, you know, I’m going to have actually look at the documentation in order to really help you with it.

Ann: So we fax that to Mark’s attention?

Mark Loney: You mind giving me an email address so we can get a hold of you?

Ann: That would be ebirch, B-I-R-C-H, at americaiv.com and that’s <inaudible> on the end.

Male: What’s the first letter?

Mark Loney: Let me repeat it back to you see if we got it right. B as in boy, birch at America iv.com?

Ann: D as in dog, birch and birch is B-I-R-C-H at America iv.com

Mark Loney: Okay.

Ann: And then I’ll work with (Amanda) to get you those examples.

Mark Loney: Okay, thank you.

Ann: Thank you.

Operator: Miss Upchurch, I do believe that’s all the time we have for questions, is that correct? Or did you want to take a few more callers?

Zita Upchurch: We were scheduled until 3 pm, Central Time.

Operator: Do you want to take more questions?

Zita Upchurch: Yes, how many...

Mark Loney: How many do we have in queue, can I ask?

Operator: Right now you’re at three.

Mark Loney: Yes, we’ll go ahead and take three more.

Operator: Okay, will do. Dan, please go ahead.

Mark Loney: Thank you.

Operator: You’re welcome.

Dan: I’m sorry about that. Our situation is with a customer in a new power chair. And we had sent in all of the documentation to ADMC and they determined that the beneficiary did meet the medical necessity requirements.

So we delivered the equipment and sent in the claim and got a letter from the ZPIC that they needed to do an audit on it. And there’s nothing in here other than an address where you can communicate with it - with them in regards to that.

Is there any other way to contact the ZPICs?

Mark Loney: Which zone was it from, ma’am? What state was the <inaudible>?

Dan: It’s - we’re in Colorado and it’s Health Integrity out of Dallas. Yes.

Mark Loney: Okay. The only contact we’ve had from the ZPICs is from SafeGuard Services. We do not have any other contact numbers for Health Integrity or Advance Meds.

Dan: Okay.

Mark Loney: The - unfortunately the address they provide on there that’s where you’re going to want to send all communication.

Dan: That’s it, okay.

Mark Loney: Yes, ma’am.

Dan: So what - and it doesn’t say in their letter do they have a timeframe in order to respond to us?

Mark Loney: You know, as we heard earlier in the call. It can take longer. I just speak for CGS we have very specific 60-day timeframes for that. But from the ZPIC we’ve heard it taking 60-days to several months, ma’am.

So no I do not have an exact number for the ZPIC on that about what they’re timeframe is for that prepayment review.

Dan: Okay and is it typical that you get - I wouldn’t call it a predetermination - but where you’ve already sent in all of the documentation. And they’ve said yes that the patient does qualify and then to have ZPIC audit on top of that?

Mark Loney: They’re two separate contractors with ABMC is through us, you’re dealing with that contractor at CGS. So we

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went through all of our process. I would certainly send in the information you received from ADMC. But they’re all separate contractors.

So it just happened to be where you’ve done your duty with ADMC for us and then ZPIC had audited that claim. So yes ma’am it can happen, it’s all separate contractors.

Dan: Okay. We just never had one before, so I just wanted to ask.

Mark Loney: Okay.

Dan: Okay, thank you very much.

Mark Loney: You’re welcome.

Operator: And we’ll now hear from Savannah.

Savannah: Hello?

Operator: Yes, please go ahead.

Savannah: Okay. My question is we placed the L0637 in the office. And we keep getting denial after denial after denial. And we’re trying to figure out what are they looking for so we can stop these denials.

Mark Loney: Now you said you placed in the office, are you still billing the correct place of service which is where the patient lives or are you billing an office place of service?

Savannah: The patient’s home.

Mark Loney: You’re billing, so you’re billing place of service 12. Okay, that would’ve - that would’ve been the first thing I guess that jumped into mind. Bear with me here just a moment.

Let me ask maybe one clarifying question is - excuse me - are you getting mostly medical necessity denials on these?

Savannah: Medical necessity - every - everything. And it’s like we keep - I’m going back asking for more documentation. Sending them what they want. I mean we’ve cleaned up everything and they’re still denying.

Mark Loney: I do know just in the conversation here around the table real quick that there are medical deny - excuse me - medical necessity denials for that specific item we do see simply because often times the chart notes or the documentation isn’t there to sufficiently detail the need for it.

Savannah: Well what documentation are they looking for? Hello?

Mark Loney: Hold on. Bear with us here just a moment.

Savannah: Okay.

Mark Loney: I guess - and again, we’re trying to, you know, work in generalities here and come up with some reasons why

this often happens. Number one of the frequent denials that we see is where the medical record will show that the brace was placed prior to a surgery which rule out its need as well.

I can’t tell you specifically what pieces of documentation are needed. It’s going to change for each patient. And that’s true for all policy groups. Each patient’s condition is going to be unique.

So just make sure that the...

Savannah: So should it not be placed before?

Mark Loney: ...LCD requirement... I’m sorry?

Savannah: Should it not be placed before surgery?

Mark Loney: No I believe it’s something that needs to be placed after surgery.

Carol Bradley: Is this a brace that they - that you are using for that beneficiary after a surgical procedure has been done?

Savannah: Exactly, yes.

Carol Bradley: If it is a brace that is placed on the beneficiary prior to the surgical procedure to be worn after the surgical procedure. It needs to be billed to the hospital procedures or to the hospital and be paid that way.

Savannah: So what are you - what are you...

Carol Bradley: It will - it will almost always deny - there’s going to have to be a major timeframe that is prior to...

Savannah: Okay, we place it like a week before surgery.

Carol Bradley: No, ma’am. It will deny.

Savannah: Okay.

Carol Bradley: Because - because they know that it’s being placed so that it can be placed at the hospital or at the time of discharge. If you are going to do that what needs to be done if that is the reason that the physician wants the brace.

Then the brace needs to be given to the beneficiary no sooner than two days prior to the date of discharge and billed upon the date of discharge.

Savannah: Okay.

Carol Bradley: You can fit it. You can get it ready. You can do whatever you choose to do but it can not be provided to that beneficiary prior to two days to the date of discharge and cannot be billed until the date...

Savannah: So that means somebody in our office would have to go to the hospital and place it on the patient?

Carol Bradley: Yes, ma’am. That’s exactly right.

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Savannah: But I thought we couldn’t do that and charge for the fitting and stuff in the office; the placement in the office.

Carol Bradley: There again, you’ve your fitting you’ve got that two day prior to the date of discharge. There again, remember you have to have proper documentation showing that it’s being taken in to fit and so forth and so on so that they will have it on the date of discharge.

Savannah: Okay.

Carol Bradley: Now, if that item is used while they are in the facility, in the hospital. Then you will not be paid for it through the DME. It will be paid for through the hospital.

Savannah: The hospital. So then my last question is this, when we go there - what place of service will we still use 12?

Carol Bradley: If you’re doing it and providing at the date of discharge, it will be 12.

Savannah: Okay. Okay. Thank you.

Operator: We will now hear from (Carolyn).

Carolyn: Hi. Thanks for allowing us a little bit over to take the questions. My question also has to do with electronic prescriptions and what the DME will not accept.

We are seeing across the country where physicians are being to use a software program wherein they can electronically sign either a CMN or a prescription using a pin pad of sorts. Similar to what you might sign for when signing for a UPS package. It’s an actual digital signature.

It shows the physician’s digital signature. It looks just like their pen signature when they do it using a pen. The only difference is that the document itself is completed electronically and dated electronically.

So the signature is hand written, the date is typed using the soft - whatever’s available through the software vendor’s program. Will the DME MAC accept the electronically signed using an electronic signature pad but typed date on say a CMN or a prescription. And if so does it have to be indicated as electronically signed by and dated by the physician?

Mark Loney: Yes. I have a very - I guess - long answer for that question. We are still absent specific guidelines.

Carolyn: So are we.

Mark Loney: About what constitutes a valid electronic signature or not. We’re working under the general rule that electronic documents can be electronically signed. I’ve seen a variety of ones. Ones exactly like you’re talking about where there’s a - there’s a digitized actual handwritten signature. They’re signing an electronic device.

That’s an electronic record that’s been electronically signed. We also see them where it’s simply printed electronically signed by. Just make sure I guess that when you’re looking at it that it is very easy for you to tell who signed it.

If there’s only that digitized hand signature and it can’t be read. If it can’t be understood because it’s sloppy just like a handwritten signature then you could see some rejections based on that.

So it is best - it’s needed somewhere to still meet the signature requirements to say this is who signed this piece paper even if it was - excuse me - this is who signed this record even if it was done so electronically.

Carolyn: Right. So in most cases - and in fact in every case I’ve seen it’s identical to what you would see on a paper prescription wherein the physician’s signature is typed either...

Mark Loney: Right.

Carolyn: ..In the CMN or on the actual prescription itself.

Mark Loney: Right.

Carolyn: And the signature is likely unreadable but, you know, not always.

Mark Loney: Sure.

Carolyn: It is the physician’s signature. There are instances where we obviously if the name was not typed we would need to get some sort of attestation from the physician. But where we’re struggling is the electronic - the whether or not we’re going to be able to submit these for acceptance as an electronic document or a valid signature.

If we can see the - the handwritten signature but then there’s a typed date. Is there an issue with that date being typed if everything else meets all the detailed - the requirements of a detailed written order.

Mark Loney: No. We’ve - I’ve seen those types of records. And they’ve been okay. We’re familiar with the systems that create that type of record. And I know there’s, you know, there’s ways that only the physician or somebody that’s authorized can get in to create and authenticate those records.

So we’re familiar with that and realize that it’s - even though it is - it looks like somebody wrote on it it’s been digitized. And it was electronic the entire time. And we would expect an automatic date stamped, if you will, or automatic input from the system with a date and sometimes we even see a time of day.

I don’t see that being an issue.

Carolyn: Okay. And if it does not say that electronically signed and dated right below that would you still accept it because

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it was an original signature. Or does it have to have that statement?

Mark Loney: It needs to have that statement or some other place where the physicians name is in there readable if that makes sense. It needs to be somewhere else where the physicians name is legible.

Carolyn: Yes.

Mark Loney: Now I will say that all of the ones that I’ve seen had the signature and it also says electronically signed or electronically verified by.

Carolyn: Okay.

Mark Loney: And that’s kind of the proof that only the correct person was in the system doing the work.

Carol Bradley: This is Carol. You know, I agree with Mark that most of those that I’ve seen said electronically signed or authenticated by which is helpful for another reason. Because sometimes if you don’t have that on there it looks a lot like a stamped signature and it’s - and which we can’t take.

Carolyn: Got it. So you’re recommendation would be to have that statement on there in addition to the signature and the dates - the date.

Carol Bradley: Yes. I mean, if you’ve got - if you’ve got electronic - electronic signature or something like that - that we can see that it was electronically generated, a typed date is fine.

Carolyn: Okay.

Carol Bradley: But if it doesn’t have that on there - to us it looks like a stamped signature with a typed date.

Carolyn: Okay. And is that something that all of the DME MACs would be consistent with across the board? Is that something you’ve discussed?

Mark Loney: I don’t know that it’s anything that we’ve - that we’ve discussed. I know that in speaking with our medical director here about the direction and what qualifies and not. They’re all under - in the same situation right now where we’re all absent the specific guidelines.

So I know it’s a topic of discussion but it’s not something that we all have, you know, matched written policies on at this point.

Carolyn: Okay, well thank you so much.

Mark Loney: Okay, thank you.

Operator: And (Miranda), please go ahead with your question.

Miranda: Yes I have a question about the delivery within two days of discharge. If we for example deliver a piece of equipment while the patient was in the hospital on say September 2 and they discharge on the 3. Would it be okay for us to change our date of service to the 4th?

To try to - try to prevent it from denying so when the patient was in the hospital.

Mark Loney: No. The policy says to bill the date of discharge. So it does allow up to two days. But if you deliver on one day the patient is discharged the next you would bill the date of discharge.

Miranda: Date of discharge. And also I know - can you all clarify that within two days of discharge how you all count that? Because I know like Louisiana Medicaid they’ll do - they’ll count one to two, two to three and the third is within two days.

I just want to make sure the timeframe about the hours how y’all are counting that. Because sometimes when it comes down to oxygen, you know, that’s imperative that we have the O2 saturation within two days of discharge.

Mark Loney: Yes. And that’s very true. In an in-patient situation for oxygen the test has to be performed within that time. We’re not paying attention to hours in the day.

Miranda: Okay.

Mark Loney: It’s simply a - it’s simply a calendar day count. So if the test is done or you deliver on the 3rd, you can bill up to the 5th.

Miranda: Okay. So if the test is done on the 3rd we can bill up to the 5th. Okay.

Mark Loney: Right, you have two days.

Miranda: That’s what I wanted to know. Okay.

Mark Loney: Okay.

Miranda: Thank you.

Mark Loney: Thank you.

Operator: Julianna has our next question.

Mark Loney: Okay. And this will be the last question.

Julianna: Okay, hello? My question is in regards to the diabetic testing supplies. We’ve been experiencing and I know its’ a problem nationwide an increase in the number of denials because the patient is also signed up with different suppliers.

Is there a tool that we can use that can quickly tell us once a patient wants to get supplies from us or reorder it that the patient had received supplies from a different supplier other than having to call Medicare and speak to a customer service representative.

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Mark Loney: No that’s the only solution at this point is to find out what’s on file through that method.

Julianna: Do you have any advice for suppliers? Because both our new patients and renewal patient we ask the question - specifically ask if they’re receiving supplies from other suppliers so we have that in the recording. And they say no and then supply. And then sure enough we get a denial.

Is there anything else that we could do to decrease - to decrease the number of denials we’re getting because of that? Since we don’t have a tool that we can easily check that if what the patient is telling us is the truth.

Mark Loney: Yes. And I realize this is another situation that puts you in a tough spot. But what you already mentioned is exactly what I would’ve recommended. Is just, you know; ask all the questions possible of the beneficiary.

I’m not sure - I know within the diabetic supplies policy we released a list of - I want to say earlier this month or late last month. About how many beneficiaries have more than one supplier involved and it’s just an astronomical number.

We’re not sure what the reasons for all of that are...

Julianna: 300,000.

Mark Loney: .why a beneficiary would tell you they weren’t getting supplies when they were. But that’s really the only thing that I can recommend today is what you’re already doing is, ask as many questions as possible about, you know, what supplies they might already have or what they’ve received or else they’ve talked to recently.

Julianna: And is Medicare doing any type of patient education or even physician because I’m also amazed that a physician would sign ten different prescriptions for that same period of time for that same patient. So is there some educational thing happening so you can also raise awareness of physicians and patients on this issue?

Mark Loney: Yes, the AB MACs our Part B counterparts have this information as well in their - what I’ve seen the most part in their educational materials.

You know, what you said I think is exactly true. We’re very surprised that a physician would sign ten orders for the same thing within a couple of months. That certainly doesn’t seem to be quality. I didn’t go to med school but that doesn’t seem to be a quality way of doing a practice.

But that education is going on, the Medicare and You booklets that are sent to the beneficiaries do contain some very cursory kind of anti-fraud information as well as, you know, being aware of when they’re solicited by the telephone and things like that. So there is education that’s done to both of those groups.

Julianna: Okay, thank you so much.

Mark Loney: Thank you.

Operator: Miss Upchurch, no further questions.

Zita Upchurch: Thank you. Can you give me the final?

Mark Loney: Yes, we’ll go ahead and finish up. I don’t have a closing statement or anything like that so, if you want to go ahead and finish. And we’ll go back into the preconference mode.

Operator: Well, ladies and gentlemen, again, that does conclude our conference for today. We thank you all for your participation.

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