HITECH Compliance Date is Here, but Without Associated Regulatory Guidance

OPGA offers Business Associate Template to comply with new requirements.

 

Feb. 17, 2010 marked the compliance date for significant new obligations under the Health Information Technology for Economic and Clinical Health (HITECH) Act, which is part of the American Recovery and Reinvestment Act of 2009, adopted one year ago. It appears the date has come and gone without the regulatory guidance that many HIPAA covered entities (virtually all O&P practices) and business associates expected to inform their compliance decisions.

Many of the new obligations require significant resources for implementation (e.g., amending business associate agreements, adopting new systems for limiting disclosures to health plans and providing copies in electronic formats that can be securely delivered). Yet, the HITECH provisions are unclear in many places. Thus, expending resources without clarifying guidance creates a Catch-22 for many covered entities and business associates subject to the new requirements (e.g., the definition of an Electronic Health Record is opaque, at best, with its dependence on the undefined term “clinician”).

New Requirements

Covered entities must now comply with most of the new privacy requirements introduced under HITECH including, among other requirements:

• additional requirements regarding “minimum necessary” uses and disclosures of protected health information (PHI);
• new limitations on uses and disclosures of PHI for marketing;
• new individual rights related to electronic access to PHI maintained in an electronic health record; and
• new individual rights allowing individuals the right to restrict their providers from sending PHI to the individuals’ health plan if the individuals pay in full for the product or service at issue.

Business associates also now face substantial new compliance obligations under HITECH. Prior to HITECH, business associates were not directly subject to HIPAA and were subject only to the contractual obligations imposed on them by covered entities through business associate agreements (BAAs). HITECH changes the regulatory landscape by imposing a direct statutory obligation on business associates to comply with the new privacy and security requirements. These include such things as:

• compliance with the bulk of the HIPAA Security Rule requirements;
• compliance with the new HITECH data breach provisions; and
• compliance with the new individual rights provisions related to access to PHI and restrictions on certain disclosures of PHI.

 BAA Challenges

HITECH further requires that the new privacy and security requirements “shall be incorporated” into BAAs. The amendment of BAAs has been one of the most troublesome and challenging issues for both covered entities and business associates. While some have hoped that HITECH “by law” amends existing BAAs (an argument that may raise constitutional issues given that private contracts and assets are at stake), most, if not all, have struggled with the decision whether to amend existing BAAs prior to the February 17, 2010 compliance date or rely upon a “transition period” that has been hinted at by the Department of Health and Human Services (HHS) and was provided in the Privacy Rule when compliance was required in 2003.

New Enforcement Framework

In addition to the new compliance challenges faced by covered entities and business associates under HITECH, several notable changes to HIPAA enforcement were also introduced under HITECH. Although many of the new enforcement provisions were effective upon enactment of HITECH (e.g., enforcement by state attorneys general, increased civil monetary penalties), several other enforcement provisions are now effective, including:

• business associates are now subject to direct enforcement actions; and
• covered entities and business associates are now subject to mandatory, periodic audits by HHS.

Beginning February 22, 2010 HHS also will begin enforcement of the new HITECH data breach regulations issued in September 2009.

A suitable BAA template may be accessed here and additional information regarding BAA compliance here.  Providers who have additional questions or concerns may contact Mark at mark.higley@vgm.com or his direct line 888-224-1631.

PECOS DELAYED UNTIL 2011!

Announcement from CMS' James Bossenmeyer

Jim Bossenmeyer, director of CMS’ Division of Provider and Supplier Enrollment, announced on a recent  “Open Door Forum” that Medicare will delay implementation of CR6417 and CR6421 (the PECOS edits) to Jan. 3, 2011. 

CMS intends to expand the editing process for DMEPOS claims.  Its contractors will compare the NPIs of a claim’s ordering physician against a national list of Medicare-approved physician NPIs in a “PECOS” database. As a result, many O & P practices have been receiving warning messages on GenResponse reports.  Until the delay was announced today, these warnings would have turned to rejections beginning April 5, 2010.

Presumably, CMS has announced this further delay of the physician registration requirement to allow physicians and non-physician practitioners who order services or items for Medicare beneficiaries or who refer Medicare beneficiaries to other Medicare providers enough time to enroll in Medicare or to take the necessary actions to establish a current enrollment record in Medicare.

For more information on the program, access to a “user-friendly” PECOS database, and template letters to physicians, please go to http://www.vgm.com/headlines/article.asp?ID=1466

POINT will provide additional commentary and analysis shortly.

Consignment Closet Rule Rescinded

A CMS official alerted regulatory stakeholders Monday night that the “consignment closet” rule, scheduled to take effect in March, has been rescinded to allow for further review and consideration.  The agency is considering rulemaking to address this issue in the future.   This means that the current rules governing consignment closets under Medicare are still in place.   

VGM Group’s Mark Higley, who sits on the AAHomecare regulatory council, attended a meeting in Washington this week.   Kimberly Brandt, CMS’ Program Integrity Group director, released an email that included “I just wanted to give you a heads up that instruction was given to the contractors this evening and the 'consignment closet' CR has been pulled-back to allow us to further review the issue and consider other implementation dates.  We are considering rulemaking to address this issue in the future, but no official decisions on that have been made at this time.”  

The consignment closet policy outlined by CMS in a transmittal issued in September 2009 would have essentially prohibited arrangements where an enrolled supplier of durable medical equipment, prosthetics and supplies (DMEPOS) maintains inventory at a practice location which is not owned by the enrolled DMEPOS supplier, but by the physician, non-physician practitioner or other healthcare professional. The rescinded rule would have required physicians (physician or non-physician practitioner) to take possession of DMEPOS items who then would have had to bill for the equipment using their own supplier billing number.  In addition to being impractical for physicians and Medicare beneficiaries, such an arrangement would have likely violated the physician ownership and referral statute--known as the Stark law.

Dennis Clark, CPO, president of OPGA, commented, “For those of you successfully managing consignment closets, this is great news.  We're happy to keep our membership informed on changes to consignment closet rules.”

The regulatory council worked closely with CMS officials over the past several months explaining why the rule would have created serious disruptions in services for Medicare beneficiaries

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(Portion of November Regulatory Council minutes)

Consignment Closets

Action Item: Regulatory Council to establish a workgroup to review consignment closet policy and make a recommendation to the Council on an alternative consignment closet proposal. Workgroup will develop a list of DME items to be included in consignment closet recommendation. Workgroup will include Mark Higley and Anthony LaCute as well as HME/RT Council members. Workgroup to consult with other interested parties to develop a compromise alternative to recommend to CMS.

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(Comments submitted to CMS officials)

AAHomecare is very concerned with the implications and application of a new policy regarding compliance standards for consignment closets and stock and bill arrangements, Change Request 6528/Transmittal 300, which is slated to be implemented on March 1, 2010, following a six-month delay in the effective date. The new policy would forbid any "stock and bill" arrangement where a DMEPOS supplier has inventory in a physician's office and where the physician furnishes these DMEPOS items to a patient while the supplier bills for it.  For purposes of this discussion, we will call these types of arrangements, "convenience closets." Convenience arrangements should be viewed differently than "consignment closet" where a physician has a contract with a manufacturer of DMEPOS, takes ownership of the DMEPOS item and bills for it using his or her own supplier number.

We recognize that the new policy is aimed at eliminating patient confusion, ensuring suppliers are accountable for inventory that they bill that is furnished through a convenience closet arrangement with a physician's office, and ensuring a greater measure of control so that the beneficiary knows who he/she should contact with any questions or problems with the DMEPOS item.

However, it is not practical to eliminate this policy in its entirety, and we believe that new DMEPOS requirements that have gone into effect since the original September 2009 effective date for the consignment closet policy mitigate the concerns that precipitated the policy change. Further, it is not practical to require all physicians to obtain a DMEPOS supplier number and bill for these items. Implementation of the new consignment closet policy will sever the continuity of care that currently exists between the patient, physician, and DMEPOS supplier under theses scenarios.

Accreditation is now mandatory, meaning that suppliers must comply with all of the DMEPOS quality standards, which hold suppliers to a higher level of accountability. These standards include providing proper instructions on use of the equipment as well as providing contact information and phone numbers for regular business hours and after-hours access, equipment repairs and emergency coverage. Accreditation requirements should be sufficient to ensure that DMEPOS suppliers are accountable for any item that they bill, and the accreditors should be able to monitor compliance with the quality standards. By virtue of the fact that all suppliers who bill Medicare are accredited, this means that they are in compliance with Medicare enrollment standards, supplier standards, quality standards and the surety bond requirement.  Medicare suppliers should properly fill out the Medicare supplier enrollment form (855s) and be only allowed to bill for items for which they are qualified to provide, and CMS is in the process of implementing edits to verify that suppliers are accredited to provide any DMEPOS items/services that they bill.

If implemented, the new consignment closet policy will jeopardize beneficiary access to medically necessary DMEPOS items that are furnished to a patient in a physician's office for the convenience of the patient to ease their transition to the home setting. Patients will be forced to travel to a separate location that could be across the street or miles away to fill the physician's order for home medical equipment or may be forced to wait even longer to coordinate delivery of the DMEPOS item to the beneficiary's residence. It seems senseless change the current policy and force patients to travel to obtain home medical equipment or delay access to items and services.

Additionally, physician practices generally cannot bill for DMEPOS items provided to their patients under the physician self-referral law (Stark Law). Physicians are permitted to bill for only a limited number of DMEPOS items under the in-office ancillary services exception to Stark Law. CMS has determined that the Stark Law exceptions for DMEPOS items are canes, walkers, crutches, folding manual wheelchairs, and blood glucose monitors. DMEPOS suppliers currently stock inventory in "convenience closet" arrangements in physician offices that cannot be billed by a physician including: portable oxygen tanks, nebulizers, CPAP devices, and TENS units. These are all items that exist in physicians offices to promote timely treatment of patients. Patient access to care would be jeopardized under the new consignment closet compliance standards because these items could no longer be provided to a patient in the physician's office without Stark Law violations occurring.

AAHomecare recommends that CMS immediately withdraw new policy regarding compliance standards for consignment closets and stock and bill arrangements because it will create patient access problems and because several policies have gone into effect that alleviate the Agency's concerns with "convenience closet" arrangements.

If CMS does not withdraw the policy completely, we request that the policy be rescinded and that the Agency utilize the full rulemaking process to allow for an appropriate public comment period and consideration of comments by all affected parties before any policy is finalized. We feel that the process for releasing the policy changes was inappropriate. The new policy is a drastic change from the existing policy, yet it was released in a Change Request rather than through rulemaking, and DMEPOS suppliers and physician practices were given less than a month to comply before the effective date of the policy.

Even with the six month delay in the effective date, there has not been enough proper education of physician practices, and we believe that many are unaware that they may need to obtain a DMEPOS supplier number, accreditation, and meet other requirements to continue providing DMEPOS items to their patients. Due to the short timeframe and challenges with Stark (which we believe the OIG is looking into this year.) we further believe that CMS must appropriately review the various types of arrangements between physician practices and DMEPOS suppliers that stock inventory through arrangements with physician practices and consider the effect on each type before any change in policy is effective.

Again, we believe that CMS' new policies with mandatory accreditation, quality standards, supplier standards enforcement of the 855S form and allowing suppliers to only bill for those items for which they are accredited and surety bond requirements will provide the protection CMS desires to ensure quality DMEPOS items are provided to Medicare beneficiaries.

We thank you for your consideration of these comments. We would welcome a conversation with your staff to further discuss our viewpoints.

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If you have further questions or request clarification, please contact Mark at mark.higley@vgm.com or at 800.642.6065

New PECOS Edits May Result in O&P Claim Rejections

CMS is expanding the claims editing process for DME MACs to include a new defense against claims containing missing, improper or fraudulent physician orders. The new edits require the verification of a referral source’s Medicare enrollment and were designed to ensure that medical equipment is ordered only by those individuals authorized to do so. However, as an unintended consequence, P&P practices now risk having legitimate claims rejected if their referral sources are not properly registered with the Provider Enrollment Chain and Ownership System (PECOS).

The expanded editing process is supposed to allow the DME MACs to verify whether a claim’s ordering physician/practitioner is actively enrolled in the Medicare program by comparing the NPI on your claim to a national list of NPIs in the PECOS database. However, the process is deeply flawed, as registration in PECOS has only recently become a requirement and the database is incomplete.

As you might expect, physicians are required to enroll with their A/B MAC or Local Carrier to submit their own claims for patient encounters, just like O&P practices have to enroll with the National Supplier Clearinghouse. Traditionally, this meant the practitioner submitted a paper 855-I or 855-R application package. That is, until 2008 when the PECOS system was developed as a way for physicians to enroll online and update their applications via the internet. The online system was first made available to individual practitioners in December, 2008 and was opened to group practices /organizational providers in April, 2009. (Eventually, PECOS will be expanded to allow all DMEPOS suppliers to update their 855-S applications via the internet as well. However, this is not expected to happen anytime soon.).

 Until recently, this internet based approach has been voluntary, and many physicians never setup an online PECOS account. The PECOS database feeds into, but is separate from, the carrier maintained file of approved physicians. The local Medicare contractors have been internally updating the PECOS database when paper applications were received with physician enrollments and changes.  But even that process only goes back to November 2003. That means physicians who have been enrolled in the Medicare program in excess of five years and who haven’t made recent updates or changes to their enrollment are not likely to be in the PECOS system. Notwithstanding, CMS has instructed CEDI and the MACs to use this developmental, online database to determine if claims should be processed.

 The new editing process is being implemented in two phases.

 Phase I:

Effective October 5, 2009, PECOS began providing CEDI and CMS with a list of all Medicare approved physicians/practitioners who are eligible to order and refer beneficiary services as reported in the PECOS database. This list is updated on a daily basis.

During Phase I, claims are being reviewed for the requirement of a Medicare enrolled physician/practitioner by comparing the ordering physician’s NPI on the claim to the list of physician/practitioner’s NPIs in the PECOS database. If a valid NPI number is found, further verification will be made by comparing the first letter of the physician’s first name and the first four characters of the physician’s last name (and these characters must be capital letters to pass the editing process).

Initially, if a name or NPI is found to be invalid, the claim will still be processed and the provider will receive a warning message on their GenResponse report (for electronic claims).

Phase II:

Effective January 4, 2010, claims will be rejected if the ordering physician/practitioner’s NPI is not provided on the claim, not found in the PECOS list, or found to be inactive.  Also effective January 4, 2010, providers will no longer be permitted to utilize their own NPI in place of an ordering physician/practitioner’s NPI.

Rejection Messages:

If a claim is flagged for a warning message or eventually rejected, providers will receive a C200, C201 or C202 error code with a “Referring Provider Not Authorized” rejection message on their GenResponse report (for electronic claims) or Remittance Advice (for paper claims).

Many O&P practices are already receiving these error codes on their GenResponse reports, but don’t know what to do with them. Currently, claims with these errors are still being processed; however, they will begin rejecting on January 4, 2010.

 Preventing Rejections:

The first step to preventing rejections is to ensure that you are monitoring your GenResponse Reports and capturing all instances where referral sources are rejecting as not registered in the PECOS system.

 To help providers quickly identify which physicians need to register or update their information in PECOS, OPGA/POINT recommends ClaraVista, LLC, a software billing company that has developed a free and simple tool known as the PECOS Warning Extractor (available for download at http://www.starkvistagroup.com.)  The PECOS Warning Extractor takes the complexity out of filtering through technical GenResponse reports by finding the Phase I rejection warnings on your report and identifying which physician NPIs are related to those warnings.  Once you have this list of NPIs you can quickly notify those physicians that need to begin the PECOS process.

Unfortunately, the PECOS database is not accessible to O&P practices in a downloadable format at this time, but the PECOS database is used to populate the “Find A Physician” search tool on the www.medicare.gov website. However, there are several steps you can take:

1. Identify all physicians with NPIs resulting in warning messages (visit http://www.starkvistagroup.com to download a free tool to help parse out this data).
2. Make sure the physician information contained in your billing software reflects the same NPI and spelling of the physician’s name as reported on the publicly available NPPES system: https://nppes.cms.hhs.gov/NPPES/NPIRegistrySearch.do?subAction=reset&searchType=ind. Claims must be billed using the physician’s legal name (i.e. Robert, instead of Bob) and individual billing number, not the NPI for the group practice, and must be reported in all CAPS.
3. Once your software record is verified to be accurate, contact those physicians and practitioners for which you are receiving rejection warnings, and:

a. Refer them to MedLearn Matters publication SE0194 (page 3) for insight on how to enroll in PECOS and the documentation needed to get started. (http://www.cms.hhs.gov/MLNMattersArticles/downloads/SE0914.pdf.)

b. Provide them with contact information for the CMS External User Services (EUS) Help Desk for general questions about accessing and using the PECOS enrollment system. The Help Desk’s toll-free number is 1-866-484-8049 and their e-mail address is eussupport@cgi.com.

c. Ask them to enroll in PECOS at: https://pecos.cms.hhs.gov/pecos/login.do using the same user ID and password established with NPPES (the NPI contractor).

d. Provide the NPI Enumerator’s phone number and e-mail address for questions about their NPPES user ID and password. The NPI Enumerator may be reached, at 1-800-465-3203 or via email at: customerservice@npienumerator.com.

At this point many referral sources have obtained an NPI (through the NPPES system), but they may or may not have registered with the PECOS system.  To make matters worse, many physicians remain unaware of the recent requirement to enroll in PECOS, as their claims are not likely to be affected by these new DMEPOS specific edits. This enrollment process appears to go more quickly for individual practitioners, but can be a lengthy process taking up to 60 days for organizational/group practices.  In addition to ensuring claims for DMEPOS will be processed, physicians should also know that the PECOS database is used to populate the www.medicare.gov website. If they are not currently in the PECOS database, patients that search for a provider on the www.medicare.gov website will not be able to find them.  By taking an aggressive, proactive approach to educating your referral sources you can lessen the impact of possible rejections at the first of the year.

CMS Delays New DMEPOS Consignment Closet Limitations

On September 1, the Centers for Medicare & Medicaid Services (CMS) announced that it was revising Change Request (CR) 6528 in order to delay by six months the effective date for imposing limits on vendors of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) that sell items at offices of health care providers. The new effective date for CR 6528 is March 1, 2010. This delay should allow suppliers additional time to decide whether restructuring existing consignment closet or “stock and bill” arrangements is necessary, and also allow physicians and non-physician practitioners time to obtain supplier numbers from the National Supplier Clearinghouse (NSC).

 

 

CR 6528 instructs the NSC that use of consignment closets and/or stock and bill arrangements must be in compliance with current Medicare supplier standards. In addition, the CR defines additional specific compliance standards for NSC validation for consignment closets and stock and bill arrangements added to the Medicare Program Integrity Manual (PIM), chapter 10, section 21.8. According to the CR, Medicare allows Medicare-enrolled DMEPOS suppliers to maintain inventory at a practice location owned by a physician or non-physician practitioner for the purpose of DMEPOS distribution when the following conditions are met by the DMEPOS supplier and verified by the NSC-MAC:

 

 

• The title to the DMEPOS shall be transferred to the enrolled physician or non-physician practitioner’s practice at the time the DMEPOS is furnished to the beneficiary.

 

• The physician or non-physician practitioner’s practice shall bill for the DMEPOS supplies and services using their own enrolled DMEPOS billing number.

 

• All services provided to a Medicare beneficiary concerning fitting or use of the DMEPOS shall be performed by individuals being paid by the physician or non-physician practitioner’s practice, not by any other DMEPOS supplier.

 

• The beneficiary shall be advised that, if they have a problem or questions with the DMEPOS, they should contact the physician or non-physician practitioner’s practice, not the DMEPOS supplier who placed the DMEPOS at the physician or non-physician practitioner’s practice.

 

 

The CR also states that the NSC-MAC shall verify that no more than one enrolled DMEPOS supplier shall be enrolled and/or located at the same practice location. (However, this prohibition does not exist for one or more physicians enrolled as DMEPOS suppliers at the same physical location.) The CR further requires that a practice location must have a separate entrance and separate post office address, recognized by the United States Postal Service.

 

Suppliers and physicians will have to revisit their contractual arrangements surrounding consignment closets prior to March 1, 2010 in order to determine whether their existing arrangements meet the requirements to be added to the Medicare Program Integrity Manual.

Sebelius: New fraud prevention team will turn up heat

On May 20, Attorney General Eric Holder and HHS Secretary Kathleen Sebelius announced the government's latest tool in the fight against healthcare fraud and abuse—The Health Care Fraud Prevention and Enforcement Action Team (HEAT).

 

With what appears to be an intended pun, Sebelius said in an HHS press release, "Today, we are turning up the heat on perpetrators who steal from the taxpayers and threaten the future of Medicare and Medicaid."

 

The HEAT team will consist of senior Department of Justice and HHS employees. Their task will be to strengthen existing fraud prevention tools and investigate new ways to root out and prevent fraud, which, according to Office of Inspector General Chief Counsel Lewis Morris, accounts for about 3%—or more than $60 billion—of the government's annual healthcare investment.

 

The team will build on demonstration projects created by the HHS Inspector General and the CMS that focus on the vulnerable durable medical equipment (DMEPOS) industry. This includes:

 

·          Increasing site visits to potential suppliers to prevent imposters from posing as legitimate DMEPOS providers

·          Increasing training for providers on Medicare compliance, and offering providers the resources and the knowledge they need to help identify and prevent fraud

·          Improving data sharing between CMS and law enforcement to identify patterns that lead to fraud

·          Strengthening program integrity activities to monitor and ensure Medicare Parts C (Medicare Advantage plans) and D (prescription drug programs) compliance and enforcement

·           

Holder and Sebelius also announced the expansion of the Medicare Fraud Strike Forces. Since their inception in 2007, the Medicare Fraud Strike Forces have recovered more than $240 million in fraud and abuse cases in South Florida and Los Angeles. The targets for the latest expansion are Detroit and Houston.

 

The creation of the HEAT team, the expansion of the Medicare Fraud Strike Forces, and the creation of a new healthcare fraud hotline (www.hhs.gov/stopmedicarefraud or 1-800-HHS-TIPS) continue President Barack Obama's push for greater healthcare fraud enforcement. Obama has made strengthening the integrity of the Medicare and Medicaid programs a priority for 2010, allotting $311 million of the $3.4 trillion budget on healthcare fraud and abuse prevention.

 

Five percent 2009 Fee Schedule Update Following Enactment of MIPPA

On July 15, 2008, the House and Senate overrode President Bush’s veto of H.R. 6331, the “Medicare Improvements for Patients and Providers Act of 2008” (“MIPPA”). Among many other things, MIPPA delayed and reformed CMS’ controversial competitive bidding program for ten categories of durable medical equipment, which had already gone into effect in 10 geographic areas on July 1, 2008.

The delayed program did not include any off-the-shelf orthotics (and cannot include them until at least 2011). Prosthetics and custom-made orthotics are already not included in competitive bidding by statute.

MIPPA terminated the contracts awarded under “round one” and now requires CMS to rebid those areas in 2009. Bidding for round two is also delayed until 2011.

Durable medical equipment stakeholders negotiated the bidding delay via an agreement to finance the estimated $1 billion in program savings by cutting the fee schedule payments for the round one items by 9.5 percent nationwide beginning January 1, 2009.

However, the legislation allowed for the resumption of inflation updates in 2009 and for several years thereafter for all covered DMEPOS codes (other than those included within round one of the bidding program). The amount of the update is equal to the percentage increase in the consumer price index for all urban consumers (“CPI-U”) for the 12-month period ending with June 2008.

The CPI-U for this period is 5.0%.

For 2010 through 2013, DMEPOS fee schedules will be increased annually to reflect the CPI-U increase. (In areas where competitive bidding is implemented, the bid contract pricing will apply). In 2014 there will be one additional CPI-U update, as well as an additional 2 percent to those items included in round one and subject to the 9.5 percent cut in 2009.

As an example, assume the 2008 reimbursement floor for an L1970 AFO is $575. The 2009 DME fee schedule (see link below) indicates an updated floor of $602.44, a 5% increase. And, unless mitigating legislation or rulemaking occurs, future reimbursement levels are estimated as follows (assume 4% annual CPI-U):

2010 $626.54
2011 $651.60
2012 $677.66
2013 $704.77
2014 $732.96

MIPPA also added a series of procedural improvements to the bidding process. Should round one (and future rounds) be rebid, CMS is now required to notify bidders in the case of certain missing financial documentation. MIPPA addressed quality issues by, among other things: requiring subcontractor accreditation; excluding complex rehabilitation wheelchairs and negative pressure wound therapy from bidding; exempting certain rural and low-population areas from bidding; and requiring CMS to issue regulations before using its authority to adjust prices in non-bid areas.

Other key provisions of MIPPA include CMS-generated reports that analyze the impact of the program on small businesses, an analysis of the impact on utilization of different items and services paid within the same HCPCS code, costs to CMS including payments made to contractors for administering the program (compared with administration of the fee schedule and the relative savings of the program), and impact on access, Medicare spending, and beneficiary spending.

For all HCPC codes affected by the MIPPA legislation, click here.

For the complete 2009 DMEPOS fee schedule (which reflects adjustments noted above), click here and click on the ZIP file.

For more information please contact Mark Higley at 1.800.642.6065 or mark.higley@vgm.com