Re-Starting the 36-Month Oxygen Rental Period

July 29, 2022

A new 36-month rental period can begin only in the following situations: After the five year reasonable useful lifetime (“RUL”) of the oxygen equipment has expired, if the beneficiary elects to obtain new oxygen equipment.

Baird: Latest On Loan Closets

July 23, 2022

AMARILLO, TX - A “loan closet” is also known as a “stock and bill”...which is also known as a “consignment closet.” A DME supplier can set up a loan closet arrangement at a hospital, clinic, or physician’s office (“Facility”). 

Interest-Free Financing: OIG Advisory Opinion

July 8, 2022

AMARILLO, TX - The federal anti-kickback statute (“AKS”) is very broad. The AKS makes it a criminal offense to knowingly and willfully offer, pay, solicit, or receive any remuneration...

Compensating Marketing Reps of Affiliated Companies

June 25, 2022

AMARILLO, TX - One of the safe harbors is the “Employee Safe Harbor.” It states that if a person is a bona fide employee (full-time or part-time) of a provider/supplier, the compensation paid to the employee does not violate the AKS.

Negotiating Managed Care Contracts

June 10, 2022

AMARILLO, TX - Historically, DME suppliers have taken care of Medicare patients and have billed CMS directly. This is known as “Medicare fee-for-service” (Medicare FFS). Also, historically, suppliers have taken care of state Medicaid patients.

Personal Services and Management Contracts Safe Harbor: OIG Guidance

June 6, 2022

AMARILLO, TX - All health care providers, including DME suppliers, should be aware of the federal anti-kickback statute (“AKS”).