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Reimbursement Page

Navigating the VA Contracting Maze
By Daniel Gurley, AOPA Government Affairs Department

Though Veterans’ Affairs Medical Centers (VAMCs) have their own prosthetic facilities, they can be a source of work for outside O&P practices as well. It is Veterans’ Affairs (VA) national policy to permit all amputees (other than new non-service amputees) to have a choice of prosthetists, including outside contract practitioners.

AOPA has received several questions about how providers get started with the contracting process and how to sign up for e-mail notification of when the VA is soliciting for bids. This month’s “Reimbursement Page” gives you a step-by-step explanation of both.

How to find bids
Each VAMC contracts for O&P services using its own individual bidding system while following certain national directives.  The best source of information regarding local contracting opportunities would be the contracting officer of your local VAMC.

However, if you’d like to find bids yourself, visit the Federal Business Opportunities Web site at www.fbo.gov. Scroll down the home page and click on the button labeled “FedBizOpps—Vendors.”

The next page displayed allows you to open a drop-down list and select “VA.” This displays the “Posting for VA by Office” that lists all the vendor opportunities for  items and services within the VA by the local offices. To narrow your search, scroll down to find your local office and click on “Class Code.”

On the next page, click on “65,” which will be at the top of the screen. This is the code for medical, dental and veterinary equipment and supplies. If there is nothing listed, then that VAMC is not currently soliciting for bids. However, you can still contact that office to find out when they might be soliciting bids.

If there are items listed, select a particular item to read the synopsis and solicitation information. This is where you will find the directions for submitting a bid, along with the contact information for the contracting officer.

GAO Report May Spur More Medicare O&P Reviews
According to a Mar. 6, 2007 report by the Government Accounting Office (GAO), the fiscal watchdog of the federal government, Medicare made about $700 million in improper payments for durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) from Apr. 1, 2005 – Mar. 31, 2006. Unfortunately, some of that fraud was specifically attributed to O&P. As a result, AOPA believes that Medicare will increase its review of O&P claims for fraud and abuse.  

The Centers for Medicare and Medicaid Services (CMS) requested that the GAO audit the Program Safeguard Contractors (PSCs) and the four carriers that process Medicare claims (DME MACs). CMS contracts with these organizations to minimize improper payments, and it wanted to see if their actions were working.

The GAO not only found a disturbing amount of fraud but also mentioned O&P specifically in some of its examples. For example, between October 2002 to March 2005, Medicare paid $2 million for orthoses after paying for prostheses for the same limb. The GAO report also cited multiple prosthetic devices for the same body part billed for the same beneficiary during one year.

Since the GAO expressly cited these examples within the report, AOPA feels that Medicare may increase its review of O&P billings. Currently, the PSCs and DME MACs review claims by using computer software to test them for medical necessity and appropriate expenditure amounts. These software programs are commonly referred to as “controls” or “edits.”

However, the report also found three problems with these controls:

•Contractors did not have automated controls in place;
•Some automated controls did not review unlikely prescribed items; and
•Contractors did not share information with each other.

CMS is implementing an annual performance evaluation process that will determine whether to renew a PSC’s contract and whether a PSC can earn a performance reward.  This may increase the amount of controls implemented by contractors.  

AOPA will keep you updated on any further developments. To help ensure that your facility is submitting prudent, medically necessary claims, make sure your billing staff is well-trained in Medicare and other payer billing requirements, and that your practitioners support all claims with appropriate documentation. 



AOPA members can always contact AOPA’s billing and coding experts, Joe McTernan (jmcternan@AOPAnet.org, (571)431-0811) and Sean Peterson, (speterson@AOPAnet.org, (571) 431-0859). AOPA also holds coding & billing and documentation seminars across the country. To register, visit www.AOPAnet.org.

For questions on the GAO report, contact Daniel Gurley at dgurley@AOPAnet.org or (571) 431-0812.


Sign up for e-mail notification
The Web site also offers an e-mail notification system that sends out procurement announcements, or announcements that the VA is looking for contracts.

To sign up for these notices, follow the instructions above to go to the “Posting for VA by Office” page. Under the subheading “Vendor Links” on the right side of the page, there is a hyperlink entitled “Vendor Notification Service.”

This link opens a new page where you can click on “Register to receive all notices from select organizations and product service classifications.” Doing so will open up another page, where you should enter your e-mail address. Then, under “Select procurement classification code,” choose “65–Medical, Dental, and Veterinary Equipment and Supplies.”

There are a few tricks to getting the most relevant announcements. Leave the “NAICS” and “Set aside type” fields at “All.” Do not fill in the next field, called “POP_Zip.” If you do, you will narrow your search and may miss some announcements.

In the next field, select “Department of Veteran Affairs” and click on “Show offices for the selected agency.” Now scroll back down to the bottom of the page and choose your local VAMC.

Once you click on the “Submit” button, you should receive a confirmation e-mail notifying you that you will receive all future procurement announcements.

If you currently have a contract, you should know that the VA is no longer required to contact current vendors regarding renewals. Consequently, current vendors must keep track of their contract terms and expiration dates.

AOPA recommends that you contact the contracting officer for your local VAMC to discuss renewal five to six months prior to your contract expiration date.

Daniel Gurley is manager of regulatory affairs for AOPA’s Government Affairs department. Questions? Contact him at (571) 431-0812 or dgurley@AOPAnet.org.

If you’d like to sign up for AOPA In Advance, send the e-mail addresses you wish to receive the newsletter, along with your AOPA member ID and street address, to Corrinn Mullins at cmullins@AOPAnet.org.

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