CMS Alerts on Potential Fraud in DME Suppliers: Common Official Identified
Relevant to: PDP, Part D
Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.
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Introduction
The Centers for Medicare & Medicaid Services (CMS) has issued an alert detailing potential irregularities involving several durable medical equipment (DME) suppliers linked by a common authorized official, Emmanuel Buabeng. This alert is a critical notification for all Medicare Advantage Organizations (MAOs) and Prescription Drug Plan Sponsors (PDPs) regarding possible inappropriate billing activities across multiple states including Texas and New York. Plan sponsors are advised to remain vigilant and report any vetted complaints through the appropriate channels.
Key Dates and Deadlines
- Alert Date: March 21, 2025
- Enumeration Date for TYLER MEDICAL SERVICES LLC: January 2, 2025
- Enumeration Date for MIDWAY MEDICAL SERVICES LLC: November 5, 2024
- Enumeration Date for DYNARO SERVICES LLC: October 21, 2024
- Enumeration Date for FRANKLIN MEDICAL SERVICES LLC: December 25, 2024
Note: Additional enumeration dates for other DME suppliers are available in the document.
PACE Compliance
This memo is relevant to PACE programs because it highlights the need for vigilant compliance monitoring concerning durable medical equipment (DME) suppliers and potential fraudulent billing practices.
Plans must ensure that they have robust compliance programs in place to identify and monitor potentially inappropriate claims by DME suppliers, particularly those with common authorized officials that may indicate coordinated fraudulent activity.
To adhere to compliance standards, PACE organizations need to:
- Regularly consult the National Plan & Provider Enumeration System (NPPES) for updates on authorized officials of DME suppliers.
- Closely monitor billing practices from DME suppliers, especially those based in Texas as indicated in the alert.
- Report any suspicious activities or billing discrepancies to the Centers for Medicare & Medicaid Services (CMS) and the Investigations Medicare Drug Integrity Contractor (I-MEDIC) using the designated channels.
- Ensure that their compliance programs are aligned with Chapter 9 of the Prescription Drug Benefit Manual and Chapter 21 of the Medicare Managed Care Manual, which guide the monitoring of potentially inappropriate claims.
Non-compliance may result in administrative penalties or other actions, so it is crucial for PACE entities to remain proactive in their monitoring and reporting efforts.
Required Actions
This memo serves as an alert regarding possible inappropriate billing by certain DME suppliers associated with a common official, Emmanuel Buabeng. As a Medicare Advantage Organization or Prescription Drug Plan Sponsor, here are the actions you should consider:
1. Review the list of DME suppliers with a common authorized official in association with Emmanuel Buabeng, particularly those based in Texas, for any unusual billing patterns that could indicate inappropriate claims.
2. Utilize the Health Plan Management System (HPMS) Program Integrity portal to report any vetted complaints related to these suppliers to CMS and the I-MEDIC.
3. Ensure your compliance team is working in accordance with Chapter 9 of the Prescription Drug Benefit Manual and Chapter 21 of the Medicare Managed Care Manual to effectively monitor and manage compliance with these alerts.
FAQs
- “What is the role of an authorized official in DME supplier organizations?”
- “How does the National Plan & Provider Enumeration System (NPPES) relate to Medicare compliance?”
- “What should Medicare Advantage Organizations do upon receiving alerts about possible inappropriate billing?”
- “Why is reporting vetted complaints to CMS and I-MEDIC important?”
- “Which documents should plan sponsors refer to for compliance program guidelines?”
