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Audit (A-07-11-05016)

Pos-T-Vac Medical Did Not Meet Medicare Documentation Requirements for Over Half of Sampled Claims for Male Vacuum Erection Systems

Executive Summary

Of the 100 sampled claims for vacuum erection systems that were submitted by Pos-T-Vac Medical (Pos-T-Vac), a Medicare durable medical equipment (DME) supplier, and that we reviewed, 51 claims did not comply with Medicare DME documentation requirements. Based on the results of our sample, we estimated that unsupported Pos-T-Vac paid claims for vacuum erection systems resulted in overpayments totaling $4.2 million during the period January 1, 2008, through December 31, 2009.

For 50 claims, Pos-T-Vac did not maintain proof of delivery in its files; for 2 claims, Pos-T-Vac did not maintain sufficient documentation of the patients' medical condition to substantiate the necessity for the items ordered; and for 1 claim, the physician's written order lacked the signature of the treating physician (2 claims were missing more than 1 piece of required documentation). Pos-T-Vac submitted unsupported claims because it lacked adequate internal controls to ensure that it collected and maintained the required documentation.

We recommended that Pos-T-Vac (1) refund $4.2 million to the Federal Government and (2) develop and implement policies and procedures to help ensure that it collects and maintains the required documentation. Pos-T-Vac did not concur with our finding regarding proof of delivery but concurred with our other findings.

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