by Tracey Berkowitz on November 29, 2023
In the dynamic field of healthcare, adaptability is not only valued, but essential. With CMS' 2019 emphasis on joint replacement revisions, notably total knee and total hip orthopedic procedures, health systems are entering a new era of accountability and precision. This shift was born from CMS’s intent to alleviate procedure costs for Medicare and Medicaid, spotlighting warranties and ask providers to explore cost-effective alternatives like no-charge replacements or securing credits.
OIG Grace Period Won't Last Forever
What happens when certain orthopedic procedures aren’t covered by warranties?
This is where meticulous tracking becomes not just crucial, but mandatory. The Office of Inspector General (OIG) has provided a grace period, a breather for facilities to set robust systems in place. However, as time draws closer, OIG will expect concrete evidence that hospitals have been actively pursuing cost reductions with vendors. Without this proof of engagement, the assumption might lean towards a scenario where full reimbursements were available. This could mean that CMS may have inadvertently overpaid hospitals for certain procedures, leading to substantial financial ramifications, including potential fines.
Steps to Remain Compliant and Avoid Penalties
For health systems to remain compliant and avoid penalties they must:
- Identify all qualifying procedures involving explanted devices in the HCPCS list.
- Provide documentation that the vendor was engaged, and a credit was requested and pursued.
- Show the vendors disposition of the request, whether rejected or approved.
- Provide evidence that the 50% rule calculations were performed for any credits received and applied to the correct recipient.
Given the interconnectedness of medical operations, the challenges of accurately managing these procedures compound, especially when facilities rely on manual methods. Consider the myriad departments involved in the warranty claims process--billing compliance, revenue cycle, supply chain, accounts payable, and clinical departments--each touchpoint becomes a potential area for errors, delays, or oversights. The problem arises when a facility is unable to show documentation that they have attempted to recover every warranty claim and show the audited explant was not covered.
Meticulous Tracking of Orthopedic Devices
There is a silver lining. Collaborative innovation with our customers has paved the way for a solution in explant management. WarrantyTracker™ v2.5 is the result of these efforts. Its integration with manufacturers ensures the automation of pursuing, tracking, and passing on medical device credits to Medicare. The addition of orthopedic devices in version 2.5 heralds a new era where tracking joint replacement revisions becomes streamlined and efficient. In the realm of explant management, where precision, accountability and efficiency are paramount, tools like WarrantyTracker are not just operational assets but allies in ensuring facilities are always audit-ready and primed for optimal patient care.
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