CMS to Release a Comparative Billing Report on PAP Devices and Accessories

On January 16, 2014, the Centers for Medicare & Medicaid Services (“CMS”) announced that it will release a national provider Comparative Billing Report (“CBR”) addressing Positive Airway Pressure (“PAP”) Devices and Accessories.

CMS is using CBRs as a tool to educate providers about applicable Medicare billing rules in furtherance of its goal to improve the level of care provided to Medicare patients.

The CBRs will be produced by eGlobalTech and will contain actual data-driven tables and graphs with an explanation of findings that compare providers’ billing and payment patterns to those of their peers location in the same state and across the country.

CBRs are not available to anyone but the provider who receives them. Additionally, the reports do not include patient or case-specific data, but rather only contain summary billing information as a method of ensuring privacy.

CMS has identified specific provider types to receive CBRs due to certain billing vulnerabilities. To date, these providers include: chiropractors, ambulances, hospices, podiatrists, physical therapists, evaluation and management services, sleep studies, home health services, and spinal orthotics.

CBR data analysis utilizes the same data-mining tools used by Medicare contractors to identify candidates for audit. Therefore, it is likely that any vulnerabilities identified in the CBR may eventually be identified by CMS contractors who select providers for audit.

It is imperative that providers who receive a CBR evaluate the information contained in the report and consider conducting an internal compliance audit to determine whether any differences in billing patterns are attributable to billing errors or other reasons (e.g., serving different patient populations). Additionally, providers should consider contacting a healthcare attorney to evaluate the CBR and develop an appropriate compliance program to reduce the risk of audit going forward.

For more information, or for questions related to compliance, please contact Adrienne Dresevic, Esq., or Clinton Mikel, Esq. at (248) 996-8510, or via email at or

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