Assessing “Appropriateness” of  Diabetes Services

The OlG Work Plan sets forth various Federal government projects to be addressed during the fiscal year by the Office of Audit Services, Office of Evaluation and Inspections, Office of Investigations, and Office of Counsel to the Inspector General.

The Work Plan includes projects planned in each of the Department's major entities: the Centers for Medicare & Medicaid Services; the public health agencies; and the Administrations for Children, Families, and Aging. Information is also provided on projects related to issues that cut across departmental programs, including State and local government use of Federal funds, as well as the functional areas of the Office of the Secretary. Some of the projects described in the Work Plan are statutorily required, such as the audit of the Department's financial statements, which is mandated by the Government Management Reform Act.

The OlG does not provide additional details on jobs to be undertaken or information on the status of jobs contained in its Work Plan. Additionally, because of changing workloads, the OIG is not able to provide an estimated issue date for a specific report.

Here’s one scheduled for 2009 that caught my eye entitled Medicare Part B Payments for Home Blood-Glucose-Testing Supplies

“We(OIG) will review Medicare Part B payments made for home blood glucose test strips and lancet supplies. The Social Security Act, § 1862(a)(1)(A), provides that Medicare will not pay for items or services that are “not reasonable and necessary for the diagnosis and treatment of illness or injury or to improve the functioning of a malformed body member.” The Local Medical Review Policies (LMRP) or local coverage determinations, whichever are applicable, issued by the four DME MACs require that the physician’s order for each item billed to Medicare include certain elements and be retained by the supplier to support billing for those services. Further, the LMRP require that suppliers add a modifier to identify when the patient is insulin-treated or noninsulin-treated. The amount of supplies allowable for Medicare reimbursement differs depending on the applicable modifier. We will determine the appropriateness of Medicare Part B payments to DME suppliers for home blood glucose test strips and lancet supplies. “

(OAS; W-00-08-35407; expected issue date: FY 2009; work in progress)

According to CMS, approximately one of every ten dollars is spent on diabetes related supplies and with first round mail-order competitive bidding savings surpassing 42%, “appropriateness” of the current allowables is now in question.

It may take years but OIG reports can affect the profitability of your DMEPOS business, including but not limited to diabetes testing supplies. It’s “good business” for pharmacists selling DMEPOS to become familiar with the yearly OIG work plan.

To download the latest rendition visit :

http://oig.hhs.gov/publications/docs/workplan/2009/WorkPlanFY2009.pdf