Re: wrong stock & Bill

Re: wrong stock & Bill

Joe Sansone

1/22/2003

Ouch! I beg to differ. I feel strongly that the information I posted is
correct since I inserted direct published opinions from the OIG (Office
of the Inspector General) and healthcare attorneys from various trade
periodicals. If this information is wrong, then the OIG who is charged
by the Federal Government to asses these things is wrong. (Kind of like
saying the IRS is wrong about a tax issue.)

What specifically is wrong with the information I provided? The OIG has
set forth very specific guidelines for companies to follow for the
rental of space in a physician's office. A more comprehensive opinion
can be found at this link:
<URL Redacted>

By the way, I think we are in agreement. One of the articles I quoted
stated emphatically that it is the opinion of the OIG that no rent
should be paid to a physician's office for a stock and bill program. I
too suffer when unscrupulous vendors break the law in providing Stock
and Bill programs. I have lost several stock and bill programs when
unscrupulous competitors came in and offered over $5,000 per month for a
stock and bill program. By the way, the company that did this (a well
known distributor for a national knee brace company) was recently
visited by dozens of Federal Agents wearing bullet-proof vests and had
their employees interrogated and their files carted off. Jail time?

The fact is there, is no longer a grey area for Stock and Bill programs.
The OIG has given us the rules to live by.

Joe Sansone
C.E.O.
TMC Orthopedic
www.tmcortho.com


-----Original Message-----
From: Saunders, Jan CPO [mailto:<Email Address Redacted>]
Sent: Wednesday, January 22, 2003 5:07 AM
To: <Email Address Redacted>
Subject: [OANDP-L] wrong stock & Bill

Mr. Sansone with all due respect, your information is wrong, and
irresponsible to report to the server.
1- The rental space the stock and bill companies pay for the rental
space
cannot be one dollar more then the physician pays for the rest of his
office
space per Sq. Ft.(that is not cubic feet, it is floor space only,
usually
about 6sq ft.) The physician would be in violation of stark & anti
kickback
if the stock & bill co. pays more then that it is clearly A incentive
for
referral which is against CMS guidelines
2- Usually the stock & bill companies pay Admin. Fee for paper work
usually
about $ 1,000.00 per month unless this fee is usually kept by the DR's
office, this would also be considered A incentive for referral
3- L- Codes set up by CMS and other federal agencies include Product
and
services this means Product, eval., fitting, and follow up care for 90
days
and adjustments along with extensive documentation to be in compliance
with
the guidelines. When this is fitted in the DR's office there are 2 eval
fees
being paid. Just like Physical therapist fitting AFO's they charge PT
time &
L-code. Did you ever wonder why PT's are not fitting and billing as many
AFO's any more... I'll tell you, some of them got pinched by OIG.
If we as Prosthetist & Orthotist continue to support these companies
that
stock & bill we deserve the consequences we will pay.. It is supporting
your
competition!
It is my opinion we all need to get involved because it is already the
tail
wagging the dog..
Jan Saunders