Supporting Statement for Paperwork Reduction Act Submissions
CMS enrolls durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) suppliers into the Medicare program via a uniform application, the CMS 855S. Implementation of enhanced procedures for verifying the enrollment information has improved the enrollment process as well as identified and prevented fraudulent DMEPOS suppliers from entering the Medicare program. As part of this process, verification of compliance with supplier standards is necessary. The site investigation form has been used in the past to aid the Medicare contractor (the National Supplier Clearinghouse (NSC) and/or its subcontractors) in verifying compliance with the required supplier standards found in 42 CFR § 424.57(c). The primary function of the site investigation form is to provide a standardized, uniform tool to gather information from a DMEPOS supplier that tells us whether it meets certain qualifications to be a DMEPOS supplier (as found in 42 CFR § 424.57(c)) and where it practices or renders its services.
JUSTIFICATION
Need and Legal Basis
42 CFR § 424.57 outlines special payment rules for items furnished by DMEPOS suppliers and issuance of DMEPOS supplier Medicare billing numbers. Section 424.57 states that Medicare does not issue a billing number to a supplier unless it meets all 25 standards outlined in that subpart. The site inspection verifies that the standards are met by the supplier. The site inspection form allows inspectors to verify the information in a concise, uniform manner.
Sections 1814(a) and 1833(e) of the Act require the submission of information necessary to determine the amounts due to a provider or other person. To fulfill this requirement, CMS must collect information on any DMEPOS supplier who submits a claim to Medicare or who applies for a Medicare billing number before allowing the supplier to enroll. This information must, minimally, clearly identify the provider and its' place of business as required by the Budget Reconciliation Act of 1985 (P.L. 99-272) [42 U.S.C. § 9202(g)] and provide all necessary documentation to show they are qualified to perform the services for which they are billing. The site inspection form allows inspectors to verify the information using a standardized information collection methodology.
Section 1834(j) of the Act states that no payment may be made for items furnished by a supplier of durable medical equipment, prosthetics, and supplies (DMEPOS) unless that supplier obtains, and renews at such intervals as we may require, a billing number. In order to issue or renew a billing number, we need to verify, via a site inspection, the information collected from the supplier on the initial application for enrollment and the application for reenrollment.
Information Users
This form is used by the NSC and its subcontractor on site visits to verify compliance with required DMEPOS supplier standards. The subcontractor collects the information from the supplier through an interview and forwards it to the NSC for evaluation.
Use of Information Technology
This form does not lend itself to the use of improved information technology, as all the site inspections must be individually performed.
Duplication of Efforts
The site visit form is intended to validate the information provided by a DMEPOS supplier on the CMS 855S application.
Small Businesses
This form will affect small businesses; however, DMEPOS suppliers have always been required to provide CMS with documentation to verify information collected on the CMS 855S application as a condition of enrollment. Accordingly, the impact is minimal – CMS carries the burden of the cost; the supplier must allocate a small amount of time to this effort.
Less Frequent Collection
This information is collected only as needed. It is necessary for verification of enrollment information. It will be collected upon initial enrollment, re-enrollment (currently every three years) and when the NSC conducts unannounced site visits. Were collected less frequently, CMS would not be able to determine the legitimacy of the suppliers enrolling and reenrolling in the Medicare program.
Special Circumstances
There are no special circumstances associated with this collection.
Federal Register Notice/Outside Consultation
The 60-day Federal Register notice published on April 11, 2008.
Payments/Gifts to Respondents
There are no payments or gifts to respondents.
Confidentiality
CMS will comply with all Privacy Act, Freedom of Information laws and regulations that apply to this collection. Privileged or confidential commercial or financial information is protected from public disclosure by Federal law 5 U.S.C. 522(b)(4) and Executive Order 12600.
Sensitive Questions
There are no questions of a sensitive nature associated with these requirements.
Burden Estimates (Hours & Wages)
The total annual hour burden for DMEPOS suppliers is 15,000 hours. This is based on an estimate of 30 minutes to complete the interview for the approximately 30,000 DMEPOS suppliers visited per year.
There is no monetary cost to the suppliers, as the NSC or its subcontractor completes the form.
Capital Costs
There are no capital costs to the respondents.
Cost to Federal Government
There is no additional cost to the Federal government. Site investigations will be completed in the normal course of Federal duties.
Changes to Burden
This notification increases the current burden from 10,000 hours to 15,000 hours annually. This is due to the increased number of site visits performed by the NSC.
Publication/Tabulation Dates
There are no plans to publish or tabulate the information collected.
Expiration Date
We will not display the expiration date.
Certification Statement
There are no exceptions to the certification statement.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
N/A
Supporting Statement for Paperwork Reduction Act Submissions
ATTACHMENT A
Below
is an abbreviated version of the supplier standards every Medicare
DMEPOS supplier must meet in order to obtain and retain billing
privileges. These standards, in their entirety, are listed in 42
C.F.R. 424.57(c).
1. A
supplier must be in compliance with all applicable Federal and State
licensure and regulatory requirements.
2. A supplier must
provide complete and accurate information on the DMEPOS supplier
application. Any changes to this information must be reported to the
National Supplier Clearinghouse within 30 days.
3. An
authorized individual (one whose signature is binding) must sign the
application for billing privileges.
4. A supplier must
fill orders from its own inventory, or must contract with other
companies for the purchase of items necessary to fill the order. A
supplier may not contract with any entity that is currently excluded
from the Medicare program, any State health care programs, or from
any other Federal procurement or non-procurement programs.
5.
A supplier must advise beneficiaries that they may rent or purchase
inexpensive or routinely purchased durable medical equipment, and of
the purchase option for capped rental equipment.
6. A
supplier must notify beneficiaries of warranty coverage and honor all
warranties under applicable State law, and repair or replace free of
charge Medicare covered items that are under warranty.
7.
A supplier must maintain a physical facility on an appropriate site.
8. A supplier must permit CMS, or its agents to conduct
on-site inspections to ascertain the supplier’s compliance with
these standards. The supplier location must be accessible to
beneficiaries during reasonable business hours, and must maintain a
visible sign and posted hours of operation.
9. A supplier
must maintain a primary business telephone listed under the name of
the business in a local directory or a toll free number available
through directory assistance. The exclusive use of a beeper,
answering machine or cell phone is prohibited.
10. A supplier must have comprehensive liability insurance in the amount of at least $300,000 that covers both the supplier’s place of business and all customers and employees of the supplier. If the supplier manufactures its own items, this insurance must also cover product liability and completed operations.
Supporting Statement for Paperwork Reduction Act Submissions
ATTACHMENT A (continued)
11.
A supplier must agree not to initiate telephone contact with
beneficiaries, with a few exceptions allowed. This standard prohibits
suppliers from calling beneficiaries in order to solicit new
business.
12. A supplier is responsible for delivery and
must instruct beneficiaries on use of Medicare covered items, and
maintain proof of delivery.
13. A supplier must answer
questions and respond to complaints of beneficiaries, and maintain
documentation of such contacts.
14. A supplier must
maintain and replace at no charge or repair directly, or through a
service contract with another company, Medicare-covered items it has
rented to beneficiaries.
15. A supplier must accept
returns of substandard (less than full quality for the particular
item) or unsuitable items (inappropriate for the beneficiary at the
time it was fitted and rented or sold) from beneficiaries.
16.
A supplier must disclose these supplier standards to each beneficiary
to whom it supplies a Medicare-covered item.
17. A
supplier must disclose to the government any person having ownership,
financial, or control interest in the supplier.
18. A
supplier must not convey or reassign a supplier number; i.e., the
supplier may not sell or allow another entity to use its Medicare
billing number.
19. A supplier must have a complaint
resolution protocol established to address beneficiary complaints
that relate to these standards. A record of these complaints must be
maintained at the physical facility.
20. Complaint records must include: the name, address, telephone number and health insurance claim number of the beneficiary, a summary of the complaint, and any actions taken to resolve it.
21. A supplier must agree to furnish CMS any information required by the Medicare statute and implementing regulations.
22. All suppliers of DMEPOS and other items and services must be accredited by a CMS-approved accreditation organization in order to receive and retain a supplier billing number. The accreditation must indicate the specific products and services, for which the supplier is accredited in order for the supplier to receive payment for those specific products and services.
Supporting Statement for Paperwork Reduction Act Submissions
ATTACHMENT A (continued)
23. All DMEPOS suppliers must notify their accreditation organization when a new DMEPOS location is opened. The accreditation organization may accredit the new supplier location for three months after it is operational without requiring a new site visit.
24. All DMEPOS supplier locations, whether owned or subcontracted, must meet the DMEPOS quality standards and be separately accredited in order to bill Medicare. An accredited supplier may be denied enrollment or their enrollment may be revoked, if CMS determines that they are not in compliance with the DMEPOS quality standards.
25. All DMEPOS suppliers must disclose upon enrollment all products and services, including the addition of new product lines for which they are seeking accreditation. If a new product line is added after enrollment, the DMEPOS supplier will be responsible for notifying the accrediting body of the new product so that the DMEPOS supplier can be re-surveyed and accredited for these new products.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | HCFA Software Control |
| Last Modified By | CMS |
| File Modified | 2008-08-14 |
| File Created | 2008-05-06 |