COMPLIANCE CORNER
By MALISA ROGAN
Supplier Standard Compliance Tips Know the 30 Supplier Standards—and how to prevent errors when billing
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 39. 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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The National Supplier Clearinghouse (NSC) is the single organizational entity responsible for issuing or revoking Medicare supplier billing privileges for suppliers of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS). NSC was recently asked to share with the O&P community some common errors and mistakes that we encounter on a regular basis. By sharing this information, we hope to help prevent some of these errors from happening in the future, in turn saving time for everyone. Please note that the information provided in this article is current as of November 2019.
Surety Bonds
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JANUARY 2020 | O&P ALMANAC
Bonds are required to obtain and maintain Medicare billing privileges, per a CMS directive published on Dec. 29, 2008. So, what are DMEPOS surety bonds? A DMEPOS surety bond is a bond issued by an entity (the surety) guaranteeing that a DMEPOS supplier will fulfill an obligation or series of obligations to a third party (the Medicare program). If the obligation is not met, the third party will recover its losses via the bond. Surety bonds are required whether the DMEPOS supplier is a nonparticipating or participating provider. Note, however, that certain suppliers may qualify for exemption. The exemption requirement can be found in its entirety in 42 CFR 424.57(d)(15). Here are some applicable exemptions for suppliers that deal with orthotics and prosthetics: “State-licensed orthotic and prosthetic personnel in private practice making custom-made orthotics and
prosthetics are exempted from the surety bond requirement if: (1) the business is solely owned and operated by the orthotic and prosthetic personnel, and (2) the business is only billing for orthotics, prosthetics, and supplies.”
Licensing
Supplier Standard 1 mandates that “if a state requires licensure to furnish certain items or services, a DMEPOS supplier must be licensed to provide the item or service.” NSC provides a Licensure Directory to assist suppliers with changes and updates (available at https://www.palmettogba.com/licensure/ licdirec.nsf/NSCLicensureMap_N). Note, however, that the directory is meant only as a guide. It is the responsibility of the supplier to ensure compliance with state licensure requirements. Additionally, suppliers can conveniently utilize the NSC Web Form submission option to submit licenses.