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Proposed Act Would Reform Medicare DMEPOS Audits

September 2014

Proposed Act Would Reform Medicare DMEPOS Audits

By Brian McCurdy, Senior Editor

A recently introduced House act seeks to reform the process for Medicare to audit Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) claims.    

The Medicare DMEPOS Audit Improvement and Reform (AIR) Act of 2014, HR 5083, has the support of the American Podiatric Medical Association (APMA). The act would boost the transparency of Medicare Administrative Contractors (MACs) and Recovery Audit Contractors (RACs) that identify and recover improper payments to healthcare providers under Medicare plans, according to the APMA. As part of the act, the APMA notes DMEPOS suppliers with error rates of less than 15 percent would only have one random audit for the year in a specific category. The APMA also says look-back periods would be limited to three years rather than five years for MACs and four years for RACs, and MACs and RACs would have to provide quarterly training on avoiding frequent payment errors, including giving notice of all new audit procedures and education to avoid clerical errors.    

Noting the reforms’ intent is “admirable,” Anthony Poggio, DPM, says most claim denials are not based upon medical necessity issues but many are due to illegible signatures, missing dates of service or some minor error on the prescription. Even in the face of good documentation, he says one of these clerical issues can result in claim denial. A qualified medical reviewer would pick this up but poorly trained reviewers who strictly follow an audit algorithm will not do this, says Dr. Poggio, a California Podiatric Medicine Association Liaison to Noridian GBA J1 MAC and a medical consultant to several national health insurance and review organizations.    

Doug Richie Jr., DPM, FACFAS, supports the act. As he explains, one of the biggest problems has been the lack of training of Medicare auditors in evaluating clinical notes and understanding codes assigned to relevant lower extremity pathologies. While auditors request volumes of medical records, he notes the reviewer often does not take the time to read the notes to see that the DPM is both the prescriber and the supplier of the DME device. Unlike orthotists and pedorthists, who require an outside physician prescription before dispensing an ankle foot orthotic (AFO) device, Dr. Richie says podiatric physicians write their own prescriptions and then act as the supplier.    

“Up until now, auditors have not seen this unique role of the podiatric physician. Also, they do not understand clinical notes that use terms like ‘posterior tibial tendon dysfunction,’ which is a common indication for AFO treatment,” says Dr. Richie, an Adjunct Associate Professor in the Department of Applied Biomechanics at the California School of Podiatric Medicine at Samuel Merritt University. “Hopefully with this act, better training and guidelines will eliminate a lot of the errors made in the past on the part of auditors.”    

Dr. Poggio adds that DMEPOS reforms should take the financial incentive out of the review process. “When auditors get paid based upon the amount they recoup, there is an incentive to nitpick at these clerical errors and not really get into the real issue of delivering a DME item to deserving patients to get the care/treatment they need,” says Dr. Poggio.

Does Amniotic Membrane Heal DFUs Faster Than Other Advanced Modalities?

By Brian McCurdy, Senior Editor

Human amnion/chorion membrane allograft can facilitate healing in various types of wounds. A recent study in Managed Care says EpiFix (MiMedx) can help rapidly heal diabetic foot wounds in comparison with other advanced wound products.    

The study consisted of a retrospective analysis of data collected and reported in published randomized controlled trials, physician product prescribing information, and premarket approval summary documents from the U.S. Food and Drug Administration (FDA). Ninety-two percent of 64 patients with EpiFix experienced wound closure in 12 weeks in comparison with 56 percent of 112 patients with Apligraf (Organogenesis) and 30 percent of 163 patients using Dermagraft (Organogenesis), according to the study. The authors note that EpiFix also has the lowest rate of ulcer recurrence and shortest time to healing of the three products.    

Ronald Belczyk, DPM, routinely uses advanced wound healing technologies. Although he has not compared EpiFix with Dermagraft or Apligraf in his patient population, he notes it is challenging to cross compare efficacy of products when study designs are highly varied and results of comparisons are often misleading.    

Dr. Belczyk cites several benefits with EpiFix. Using this product avoids problems with bovine allergies, patients tolerate it well and one can use it for multiple wound etiologies, sizes and locations, according to Dr. Belczyk, the Associate Medical Director at the Amputation Prevention Center at Sherman Oaks Hospital in Sherman Oaks, Calif. He would not use EpiFix in avascular or infected wounds.

Retrospective Study Assesses Diabetic Therapeutic Shoes

By Brian McCurdy, Senior Editor

Therapeutic shoes can have a positive impact in decreasing diabetic ulcers and amputations, according to a recent study abstract.    

The abstract, presented at the American Podiatric Medical Association Annual Scientific Meeting, focused on retrospective data on 26,437 patients who wore diabetic shoes. The review period was 2.5 years, starting six months before patients started wearing therapeutic shoes and ending two years after shoe wear began, according to the study. The average age of the participants was 68.7. By the second year, foot ulcerations had decreased from 11.2 to 9.9 percent in patients while lower limb amputation had decreased from 1.7 to 1.4 percent. However, lower extremity diabetic complications such as pre-ulcerative callus and polyneuropathy had increased, according to the study, which was funded by DJO Global.    

Diabetic shoes are beneficial as properly fit shoes and necessary accommodations can help prevent irritation and enhance the offloading of sites of potential ulceration, notes Andrew Rice, DPM. He says therapeutic shoes can also reduce the risk of ulcer recurrence, relieve ulcerative sites that are predisposed to hammertoe and relieve submetatarsal ulceration sites.   

“I do believe as a result of offloading that the diabetic shoe plays a role in amputation reduction,” says Dr. Rice, an Assistant Clinical Professor in the Department of Orthopaedics and Rehabilitation at the Yale University School of Medicine.    

In regard to shoe brands, Dr. Rice cites DavMar as effective but says there are other good companies for diabetic footwear as well.