OIG Work Plan: Off-The-Shelf Orthotic Devices

In January the OIG added off-the-shelf LSO's L0648 and L0650 and KO L1833 to the work plan. According to the publication claims for these services have grown by 97% since 2014 and allowed charges have grown by 116% reaching 349 million by 2016. Improper payment rates of 79% and higher have been identified for all three codes. A DME MAC has identified concerns of insufficient documentation supporting medical necessity existing in patient records.

What does this mean for providers? Well, with certainty it means that the OIG will investigate the appropriateness of payment and trends but most likely it will mean that we should be expecting audits for these devices.

The best defense against a recoupment is sound documentation. Ensuring that your practice obtains and retains appropriate medical necessity documentation will help provide security in the defense of an audit. Minimum documentation should include: a dispensing prescription, a detailed written order, delivery acknowledgement, product information and PDAC verification (when available), physician medical records supporting medical necessity, and clinician medical records documenting all evaluations, measurements and fittings. Protect your practice with sound documentation collection practices and you won't have to sweat the ever-changing audits.

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