The Latest Development in Medicare Audits: Supplemental Medical Review Contractor (“SMRC”) Audits

Jessica Gustafson, Esq. and Abby Pendleton, Esq., co-chairs of the firm’s Medicare and RAC department authored an ABA Health eSource article titled “The Latest Development in Medicare Audits: Supplemental MEdical Review Contractor (“SMRC”) Audits.” To view this article click here.

The article discusses the Center for Medicare and Medicaid Services’s (“CMS’s”) recent addition of Supplemental Medical Review Contractor (“SMRC”) audits to an already robust Medicare auditing environment. The SMRC audits, which will be conducted by StrategicHealthSolutions, LLC, are intended to lower improper payment rates and increase the efficiency of the medical review functions of the Medicare and Medicaid programs. SMRC audits are already underway with many providers and suppliers having received additional data requests from StrategicHealthSolutions, LLC. Currently, audits are focused on the following areas of review, among others:

• Power Mobility Devices (focused on claims from those states not included in the Prior Authorization Demonstration program for power mobility devices (i.e., reviews will not focus on suppliers in CA, IL, MI, NY, NC, FL and TX));8 • E/M services (focused on codes 99214 and 99215);9 • Hyperbaric Oxygen Therapy services;
• Inpatient Rehabilitation Facility (“IRF”) services;
• Male Vacuum Erection Devices; and • Transforaminal Epidural Injections.

SMRC audits have the potential to add to the administrative burden of already overburdened providers and suppliers due to the lack of reimbursement for duplication and mailing of medical records as well as an apparent lack of limits on additional documentation.

The article concludes that providers and suppliers should add the SMRC website to their list of resources to monitor, and should continue to maintain their focus on compliance in order to ensure that services provided are medical necessary and appropriately documented pursuant to Medicare guidelines.

Any questions can be directed to Abby Pendleton, Esq. or Jessica Gustafson, Esq.

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