The last installment of this column presented some issues with the inspection process during either your initial or revalidation process with Medicare as a DME supplier. Since composing that column, the quarterly meeting of the DME Council’s subcommittee on enrollment took place with the two National Provider Enrollment Contractors (NPE). Having attended this meeting, some serious concerns about inspections were discussed.
During this meeting, a popular issue was raised by this columnist, suggesting that it was perfectly legitimate to have two hours of operation. One for you as the DME supplier, which would be designated as “By Appointment Only” and the second with actual office hours for you as a physician. As after all, physicians were entitled to By Appointment.
While both NPE directors thought it might be acceptable to them, they both acknowledged it would be ripe for rejection by the inspectors, who would be confused by this conflict. They also commented that the inspectors are no longer either able to provide you with educational tips at the time of inspection, nor be accepting of any educational bulletins put out by them on this matter. They further remarked, what has been repeated here before, the inspectors work for a different entity not under the NPE contractor’s jurisdiction.
Keeping it simple s… (KISS) is the acronym one should live by. So, if takes a hundred dollars or so to convert your signage to By Appointment Only, as opposed to failing inspection(s) and spending thousand dollars or more on a Corrective Action Plan, why is this still such a tough pill to swallow? If one fails an inspection due to signage resulting having to purchase new signs anyway and potentially lose thousands of dollars of income on DME by potential dismissal from the program, why balk in the first place?
Physicians (MD DO DPM) are all excused from the thirty-hour requirement and entitled to the By Appointment Only scenario. Physicians are also entitled to sharing space with other physicians who may also be suppliers, whereas non-physician suppliers are for the most part required to have their businesses operational for thirty plus hours per week and cannot share space.
The gift of both being allowed to share space with other suppliers, who are physicians and not being locked into a thirty-hour work week is a gift in so many ways. So again, why are you looking a gift horse in the mouth?
