COMPLIANCE CORNER
By ELAINE HENSLEY
Entering Round 2021 Tips from the Competitive Bidding Implementation Contractor for complying with key contract terms
Editor’s Note: Readers of Compliance Corner are now eligible to earn two CE credits. After reading this column, simply scan the QR code or use the link on page 33 to take the Compliance Corner quiz. Receive a score of at least 80 percent, and AOPA will transmit the information to the certifying boards.
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S WE IMPLEMENT ROUND 2021 of the durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) Competitive Bidding Program (CBP), we want to congratulate all of the contract suppliers. We all share a common goal, which is to ensure Medicare beneficiaries receive the off-the-shelf (OTS) back and knee braces prescribed by their physicians and other treating practitioners in a timely manner. To achieve this goal, each contract supplier must comply with key contract terms under the competitive bidding contract to maintain good standing in the DMEPOS CBP.
Key Contract Terms and Compliance
By looking at each contract obligation closely, we will get a better understanding of the competitive bidding requirements. Maintain an active Provider Transaction Access Number and state licensing and accreditation requirements. What does this mean? As part of our monitoring program, we routinely review the Provider Enrollment, Chain, and Ownership System enrollment data to identify any contract suppliers that are not complying with program eligibility requirements, such as maintaining an active Medicare billing number, licensing, or accreditation. When an issue is identified, a competitive bidding liaison (CBL) will discuss the issue with the supplier to give them the opportunity to promptly correct the issue. Contract suppliers who are unable to resolve a Medicare supplier enrollment issue will be issued a notice of breach of contract. Accept assignment on all items under the contract. Medicare payments are based on the single payment amounts (SPAs). Does this mean you must change your participating
status? No, you are not required to change your participating/nonparticipating status. However, you must accept assignment on all CBP items under your contract. If you file a nonassigned claim, it is processed on an assigned basis and payment is based on the SPA. You cannot collect more than the SPA for the item(s) from the beneficiary. Complete the intake and assessment process, submit claims, coordinate care with the physician, deliver items and provide instruction to the beneficiary/caregiver(s), and ensure all services are performed in compliance with the physician’s order and Medicare rules and guidelines, including subcontracted services. Does this mean my subcontractor cannot work out arrangements with a doctor’s office or the beneficiary for a back brace? That is correct. A subcontractor cannot perform intake and assessment or coordinate care with the physician. Only the contract supplier can perform these tasks. Provide all contracted items throughout the competitive bidding area (CBA), and do not discriminate against Medicare beneficiaries. O&P ALMANAC | JANUARY 2021
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