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I am a huge fan of attorney Knicole Emanuel’s blog and her most recent post is directly relevant to the field of wound care.

Check out what she has to say about the anticipated increase in Medicare audit activity around pneumonic compression devices (PCDs). In the 2023 “Improper payments” report, PCD’s have the second highest error rate behind oral cancer drugs at 78.9%! Ms. Emanuel anticipates that with an error rate that high, PCD’s will be a focal point of audits.

She also points out that the auditing of surgical dressings continues. The DME suppliers have really been hit hard with audits and denials around surgical dressings. The 2021 Medicare fee for service supplemental improper payment report (covering claims from July 1st, 2019, through June 30th 2020) listed surgical dressings as having the highest improper payment rate at 69.7%. Despite efforts to improve the documentation that the DMEs need, the 2023 Improper Payment Report (covering claims submitted between July 1st, 2021, and June 30th, 2022), shows the improper payment rate for surgical dressings is still at 62.1%. Insufficient documentation accounted for 82.4% of improper payments for surgical dressings. Other types of errors for surgical dressings were no documentation at 1.9%, medical necessity at 1.7%, incorrect coding at 1.9% and other at 12.2%. The take home message is that we have got to do a better job of documentation if DMEs are going to be able to provide dressings for our patients.


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The opinions, comments, and content expressed or implied in my statements are solely my own and do not necessarily reflect the position or views of Intellicure or any of the boards on which I serve.