In the first half of 2007, three of every five power wheelchair claims failed to meet documentation requirements established by the Centers for Medicare & Medicaid Services (CMS), according to a December report by the HHS Office of the Inspector General.
Because the claims were paid anyway, the OIG report said $112 million in improper Medicare payments were made.
For all power chairs combined, the most commonly flagged documentation errors regarded providing supporting documentation and a detailed product description. Of the claims studied for the OIG report, 40 percent had errors in at least one of those two areas.
The report said “supporting documentation” included “physician’s notes or test results from the beneficiaries’ medical records.” In nearly all cases, the supplier did provide some supporting documentation, but in 38 percent of the claims, that documentation was considered incomplete by the OIG.
“For example, the supporting documentation for 20 percent of claims did not include the physician’s notes from the beneficiaries’ medical records,” the report noted. “Instead, these claims were improperly supported by either physician-completed forms or letters of attestation.”
In nine percent of claims, suppliers didn’t receive documentation before the delivery date, the report added.
Forty percent of claims didn’t include a complete, detailed product description. “The detailed product description is the supplier’s recommendation of the specific power wheelchair and accessories that are appropriate for the beneficiary,” the report said. In some cases, the detailed product description was missing completely, but in 26 percent of the flagged claims, the descriptions were judged to fall short of Medicare’s requirements. Errors cited in the report included descriptions that didn’t include all items being billed, or didn’t include the date on which the supplier received documentation from the prescribing physician.
Other errors noted on power chair claims, both standard and complex rehab, involved prescriptions missing or incomplete (32 percent), home assessment reports (18 percent) and proof of delivery (1 percent).
Thirty percent of complex rehab power chair claims were missing or provided an inadequate specialty evaluation report – i.e., the patient assessment by a health-care professional with complex rehab power chair expertise. And overall, perhaps because of the additional documentation required, claims involving complex rehab chairs had higher error rates in all categories versus standard power chair claims.
For example, 61 percent of complex rehab claims were missing or included inadequate supporting documentation and/or detailed product descriptions. And 58 percent of complex rehab claims were flagged for missing or inadequate prescription information.
The OIG report recommended that CMS work to improve compliance by, among other actions, conducting additional reviews of power chair claims, recovering overpayments from suppliers who don’t meet documentation requirements, offering additional education to suppliers and prescribing physicians, and taking action against the sample claims that contained errors.
Tyler Wilson, president of the American Association for Homecare (AAHomecare), said the sheer number of incorrect claims pointed out how difficult it is for suppliers to comply with documentation requirements that AAHomecare called confusing and onerous.
“The OIG study does not illustrate a problem with provider compliance, but rather it reflects the obstacles providers face with Medicare documentation and its paperwork requirements,” Wilson said in a statement to the press. “The paperwork requirements are confusing, shifting and inconsistent.”
Those inconsistencies – which AAHomecare said happened as CMS was making changes to power mobility HCPCS codes and fee schedules in late 2006 and early 2007 – negatively affected the claims that were examined by the OIG for this report, the organization said.
Wilson also pointed out that reimbursement for power chairs has dropped 35 percent in five years thanks in part to a series of cuts tied to the Medicare Improvements for Patients and Providers Act (MIPPA) and new coding and fee schedules.
To download a copy of the OIG report, click HERE.