HME News

JUN 2016

HME News is the monthly business newspaper for home medical equipment providers. This controlled circulation publication reaches 17,100 home medical equipment services providers, including traditional HME dealers & suppliers, hospital- and pharmacy-o

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Smart Talk hme news / june 2016 / www.hmenews.com 11 overpAyments humAn resources Find adaptable drivers By MeLissa seitz Q. i have delivery experience. Am i hired? A. We hear that phrase all too often. A person seeking employment will simply see "driving experience or delivery experience" and think, I can do that, I can drive and I know the area. But our medical equipment tech- nicians, or "METs" as we call them, are responsible for not only deliver- ing equipment to homes or facili- ties. They are also responsible for set up, education and troubleshoot- ing. Being able to deliver a product is not nearly enough for us to hire an MET. Candidates must be able to adapt easily. Our METs deal with a multitude of unknowns, such as unpredictable weather and road conditions, as well as last-minute changes to a delivery. They need to be able to accept those changes and continue with their deliveries. METs are usually the only person who interacts face to face with our patients. Their responsibility doesn't end there, but continues with servicing the family, listening to them, being able to answer their questions and educating them on how their equip- ment works. We look for candidates who have a desire for learning, and a compassion for those who need help. A MET's knowledge and understanding of what the patient and family is dealing with is vital to being successful in the role. It is not necessarily important for an MET to have industry knowl- edge or experience; that comes with training in a classroom and from being on the job. Most importantly, we look for transferrable skills, such as professionalism in their ability to communicate with patients and families, as well as in their appear- ance and great customer service skills. hme Melissa Seitz is an HR generalist at Medical Service Company. Reach her at mseitz@medicalserviceco.com. exercise reasonable diligence By Josh skoRa Q. What do i need to know about the 60-day rule? A. The Affordable Care Act requires a person who has received an over- payment to report and return the overpayment to the government. For HME providers, overpay- ments must be reported and returned within 60 days after the date on which the overpayment was identifed. This led to many unan- swered questions. What does "iden- tifed" mean? If a provider uncovers one overpaid claim, is it required to investigate all related claims? When does the 60-day clock start? How far back must the provider look? The answers to these questions are critical, because failure to report and return overpayments within the allotted time risks potential lia- bility under the reverse false claims provisions of the False Claims Act. Fortunately, CMS published a final rule clarifying the "60-day rule." The rule defines "identifi- cation" as when a person "has, or should have through the exercise of reasonable diligence" determined and quantifed the amount of the overpayment. Therefore, the 60-day clock does not start until the pro- vider has had the opportunity to investigate the scope of the over- payment and quantify the amount of the overpayment. Providers must exercise "rea- sonable diligence," which requires (1) implementing proactive com- pliance activities to monitor for the receipt of overpayments and (2) undertake investigations "in a timely manner" after receipt of credible information of a potential overpayment. In the preamble to the rule, CMS states that it con- siders a timely investigation to be "at most six months from receipt of the credible information, except in extraordinary circumstances." Therefore, if an investigation takes the full six months to quantify the overpayment, a provider would have eight months to report and return the overpayment. Over the next few months, we will explore ancillary issues related to the 60-day rule. hme Josh Skora is an attorney with Brown & Fortunato. Reach him at jskora@bf-law. com.

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