melodie, Author at Brown & Fortunato

Federal E-Sign Act: What It Means For The HME Provider

(May 2012) The signature of the Medicare beneficiary is important. The HME provider needs the beneficiary’s signature on an AOB. Before an HME provider calls a prospective customer, the provider needs the beneficiary’s written permission. And the list goes on. Fortunately, technology and a federal statute have intervened to make it easier for the provider […] More...

Consignment Closets And Employee Liaisons: Good Marketing Tools So Long As Legal Guidelines Are Met

(March 2012) Consignment Closets A consignment closet is also known as a loan closet or a stock and bill arrangement. An HME company may place inventory in an office or facility that is a referral source such as a physician, hospital, or sleep lab (collectively referred to as a “facility”). The inventory must be for […] More...

Buying And Selling an HME Company: The “Devil Is In The Details”

(January 2012) There are many reasons behind the decision to buy or sell an HME company. An entrepreneur may have built a business up “from scratch” and is now ready to cash out and walk the beaches of Cancun. At the opposite end of the spectrum, the owner may be tired of the daily regulatory […] More...

Strategic Alliance: Working With Your Local Hospital

(May 2013) The DME industry justifiably feels like it is under siege. The industry, in its present form, has been around for about 35 years. Compare this to physicians, pharmacists and hospitals that have been around for thousands of years. The DME industry grew up unregulated. HCFA (now CMS) barely knew that we existed. The […] More...

Employee Liaisons

(September 2012) In a 2008 Advisory Opinion, the OIG addressed a proposed arrangement in which a DMEPOS company would have personnel on-site at hospitals to train and educate patients that had been prescribed a product and had selected the company as his or her supplier. [OIG Advisory Opinion No. 08-20.] The hospitals would provide a […] More...

Medicare Advantage And State Medicaid Patients: Do Federal Anti-Fraud Statutes And Supplier Standards Apply?

(August 2012) There are a number of federal statutes and regulations that govern HME suppliers. In particular, suppliers need to be aware of the “big four”: Medicare anti-kickback statute; telephone solicitation statute; beneficiary inducement statute; and the supplier standards. While these statutes and standards clearly apply to Medicare fee-for-service patients, the following question often arises: […] More...