Seeking Bankruptcy Protection Against Overpayment

May 1, 2017
AMARILLO, TX – When it comes to the collection of overpayments by CMS, DME suppliers are caught in an Orwellian time warp. Here is what I mean: • The CMS contractor audits the supplier and determines that an overpayment exists. Too o

Keep Compliant and Bill On

April 10, 2017
AMARILLO, TX – Let’s be honest. Nobody really likes surprises unless it’s your birthday. And even then, some of us would rather know what to expect. So, when the surprise is an unannounced site visit from the National Supplier Clearinghouse

Switching Suppliers – New Physician Order Not Required

April 3, 2017
 AMARILLO, TX – Up to now, the Medicare Program Integrity Manual (“MPIM”), Chapter 5, § 5.2.7 has required a new physician order “when there is a change in the supplier.” This requirement resulted in hardship to Medicare benef

Loan Closets – Delivery of Product

March 27, 2017
AMARILLO, TX – Recently, the following question arose: Under a consignment arrangement (commonly referred to as a “loan closet” or a “stock and bill” arrangement) between a DME supplier and a hospital, does Medicare require that a DME s

HHS Won’t Meet Claims Backlog Deadline

March 27, 2017
WASHINGTON, DC – A March 7 Law360 article by Dani Kass confirms that the Department of Health and Human Services (HHS) will not be able to meet a court-imposed deadline to clear a backlog of Medicare billing appeals “unless it settles the cla

The Anti-Kickback Statute and Arrangements Between Commonly-Owned Companies

March 6, 2017
AMARILLO, TX – The Medicare anti-kickback statute (“AKS”) makes it a felony to knowingly and willfully offer, pay, solicit, or receive any remuneration to induce or reward referrals of items or services reimbursable by a federal health care