Re: OPINION- DELIVERING A CUSTOM PROSTHETIC TO A SNF PATIENT

Re: OPINION- DELIVERING A CUSTOM PROSTHETIC TO A SNF PATIENT

Tim Owens

4/15/2021

I just had to jump in here. Attempts to circumvent Medicare law, (note the word law and not rule) have been around forever. I'm in my 40th year of practice and there is nothing new here accept the people. Every new administrator looks at the law and thinks they have found a loop hole that no one else has ever been able to find. We as practitioners agreed to follow the guidelines when we stated that we wanted to see and bill Medicare patients. We have very specific, clear obligations that we must follow regardless of what a client may request. Now, the client or SNF in this circumstance has made a request of you that will make it possible for them to circumvent one of the obligations that they promised to fulfill when they agreed to see and bill Medicare patients. The enforcement side of Medicare will eventually recognize the pattern of SNF discharges patient, patients receives device, O&P bills Medicare for device, patient is readmitted to SNF. Doesn’t this just sound so wrong? Make no mistake about it, you are assisting that Medicare A provider in circumventing their DRG obligations. Medicare, rightfully will feel that this item was paid for twice. First, when they paid the SNF and then when they paid you. Probably, the place we see this violation most often is in acute care facilities where the Medicare patient, for example, is having back surgery. The hospital will ask you to provide the device, follow the 48 hour rule and then bill under part B after the patient is discharged. You may not do this. The patient can not use the device at all in the hospital and the patient may not wear the device home. Once again, If a Medicare A provider request this of you, you will be assisting them in circumventing their obligation to the patient and Medicare. This is illegal. There is only one way I have found to get around Medicare law. Don't see Medicare patients. Get on the phone and report that SNF, acute care facility and your competitor. These are not shrewd business practices, these are criminal acts.
Tim Owens, CO

-----Original Message-----
From: Orthotics and Prosthetics List < <Email Address Redacted> > On Behalf Of Lesleigh Sisson
Sent: Thursday, April 15, 2021 4:58 PM
To: <Email Address Redacted>
Subject: Re: [OANDP-L] OPINION- DELIVERING A CUSTOM PROSTHETIC TO A SNF PATIENT

This information is inaccurate.

*Lesleigh Sisson, CFom*
702-400-1661

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On Wed, Apr 14, 2021 at 2:09 PM Waldner, Glen E < <Email Address Redacted> > wrote:

> Had the same scenario in clinical practice. I explained to them that
> my license and certification was more important than billing for a
> prosthesis in a SNF and that they should consider their license more important also.
> The other facility that was providing service and ignoring the 2
> day rule was eventually busted by the feds. One loop hole that is
> available is for the facility to discharge the patient and readmit
> after delivery of the prosthesis. Of course this takes some work on
> the facility but it does make it legal.
>
> Glen Waldner, LPO, CPO
>
>
>
> From: Orthotics and Prosthetics List < <Email Address Redacted> > On Behalf
> Of Elizabeth Roof
> Sent: Wednesday, April 14, 2021 1:07 PM
> To: <Email Address Redacted>
> Subject: [EXTERNAL] [OANDP-L] OPINION- DELIVERING A CUSTOM PROSTHETIC
> TO A SNF PATIENT
>
> **** External Email - Use Caution ****
>
> Our office was referred by an orthopedic surgeon to fit a new amputee
> with a prosthesis and we have been working with the SNF facility that
> the patient is in currently to do so. It has come down to delivering
> out the item and we notified the facility that we are unable to
> deliver a prosthesis to a patient in a part A stay in a SNF bed and
> the facility is responsible for the cost of the item. We told them
> that we cannot give the patient the item until 2 days before he is
> discharged home and they don't understand this. They want to be able
> to bill for therapy minutes on gait training and teaching him how to
> properly don/doff the prosthesis. The PT called the office today and
> stated that another local O&P facility in the area has delivered items
> out to them before for patients to complete therapy still in the SNF
> part A stay and she doesn't understand why we don't do the same. I've
> sent her all the items regarding proper Medicare billing practices for
> SNF stay patients on the Noridian Medicare Portal, but I am curious if
> any other facility has run into this same issue and what you've done
> to help educate other medical professionals on the billing guidelines
> we are to follow to stay compliant with Medicare. We of course want to
> continue to see the patient regarding his prosthesis as we have
> finished all fabrication, but also want to avoid improper billing procedures set forth by the payer.
>
> Any tips or advice would be greatly appreciated!
>
> Thanks in advance!
>
> Liz Roof,
> Billing Supervisor & Office Manager
> 15418 West Center Road
> Omaha, NE 68144
>
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