Today at 1:00 PM EDT, Medicare will be having another teleconference regarding the implementation of the Competitive Bidding Program in DMEPOS. During the last Teleconference CMS spoke about Sub-contracting but was never asked the question:

How is Sub-contracting implemented in Competitive Bidding since it violates and is contradictory to 3 supplier standards?

There is also a new Policy released by the NSC on April 18th which activates "Auto-denial" to any company which does not have a state oxygen license.

How would a sub-contractor for oxygen be paid in this scenario if the bid winner does not have an oxygen license?

There are 8 unlicensed oxygen bid winners in the Miami MSA that will not be paid under this scenario.

CLICK HERE for the "Auto-Denial" Rule

CLICK HERE for MLN Matters Update

CLICK HERE for relevant Sub-contracting rules

Establish Pre-Payment Auto-denial Edit in Applicable States for DMEPOS Suppliers of Oxygen and Oxygen Equipment (DME MACs Only).

Policy:

The NSC will review its files and assign an oxygen specific code to all DMEPOS suppliers who have indicated on their Form CMS-855S their intention to supply and submit claims for oxygen and/or oxygen related equipment in those 38 states that require licensing and/or certification to supply oxygen and/or oxygen related equipment.

The update also includes: CMS regulations (see 42 CFR 424.57(c)) require all supppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) wishing to bill Medicare meet all supplier standards. The standard in 42 CFR 424.57 (c)(1) requires DMEPOS suppliers to operate their business and furnish Medicare-covered items in compliance with all applicablee Federal and State Licensure and regulatory requirements. This claims processing edit will ensure that DMEPOS suppliers in the (currently) 38 states are in complaince with this requirement.