Positive Airway Pressure Device Supplies' Supplier Compliance with Documentation Requirements for Frequency and Medical Necessity

Beneficiaries receiving continuous positive airway pressure or respiratory assist device therapy (PAP) require replacement of the device's supplies (e.g. mask, tubing, headgear, and filters) when they wear out or are exhausted. Medicare payments for these supplies in 2014 and 2015 were approximately $953 million. Prior OIG work found that suppliers automatically shipped PAP device supplies when no physician orders for refills were in effect. For supplies and accessories used periodically, orders or certificates of medical necessity must specify the type of supplies needed and the frequency with which they must be replaced, used, or consumed (Centers for Medicare & Medicaid Services Medicare Program Integrity Manual, Pub. 100-08, Ch. 5, §§ 5.2.3 and 5.9). Beneficiaries or their caregivers must specifically request refills of repetitive services and/or supplies before suppliers dispense them (Centers for Medicare & Medicaid Services Medicare Claims Processing Manual, Pub. 100-04, Ch. 20, § 200). We will review claims for frequently replaced PAP device supplies to determine whether documentation requirements for medical necessity, frequency of replacement, and other Medicare requirements are met.

Announced or Revised	Agency	Title	Component	Report Number(s)	Expected Issue Date (FY)
Completed	Centers for Medicare & Medicaid Services	Positive Airway Pressure Device Supplies' Supplier Compliance with Documentation Requirements for Frequency and Medical Necessity	Office of Audit Services	A-04-17-04056; W-00-17-35787	2020