In addition to CMS performing numerous program audits thus far in 2021, recent memos have denoted that CMS is moving forward with several self-audits for plans to consider. In April, CMS released a memo regarding the appropriate use of nebulizer products with Medicare covered durable medical equipment (DME). The purpose of this audit is to confirm appropriate billing of the nebulizer drug under Part B or Part D depending on the source of reimbursement for the DME. In May, CMS released an additional memo regarding the appropriate billing of drugs and biologicals for End State Renal Disease (ESRD) members. The purpose of this audit is to identify potential duplicate payments under Part D as well as the ESRD bundle payment. In June, CMS released a memo regarding review of payment for immunosuppressant drugs. The purpose of this audit is to identify Medicare Part D payments for immunosuppressant drugs that should have been covered as a benefit under Medicare Part B. Lastly, plans have also started to receive self-audits for specific medications. The purpose of these audits is typically to ensure the medication is being used appropriately to treat Food and Drug Administration (FDA) or compendia supported diagnosis.
With the number of audits currently in play, contact BluePeak Advisors for assistance in navigating the self-audit waters as well as updating your annual risk assessment.
