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Medicare Dialysis Services Provider Compliance Audit: Dialysis Clinic, Inc.

Announced on  | Last Modified on  | Project Number: A-05-20-00010

OBJECTIVE

Medicare Part B covers outpatient dialysis services for beneficiaries diagnosed with end-stage renal disease (ESRD). Prior OIG work identified inappropriate Medicare payments for ESRD services. Specifically, OIG identified unallowable Medicare payments for treatments not furnished or documented, services for which there was insufficient documentation to support medical necessity, and services that were not ordered by a physician or ordered by a physician that was not treating the patient. (Social Security Act §§ 1862(a)(l)(A) and 1833(e), 42 CFR §§ 410.32(a) and (d), 42 CFR §§ 410.12(a)(3), 424.5(a)(6), and 424.10). Additionally, prior OIG reviews identified claims that did not comply with Medicare consolidated billing requirements (the Act § 1881(b)(14), Medicare Claims Processing Manual, Pub. No. 100-04, Ch. 8 and Medicare Benefit Policy Manual, Pub. No. 100-02, Ch. 11). We will review claims for Medicare Part B dialysis services provided to beneficiaries with ESRD to determine whether such services complied with Medicare requirements.

TIMELINE

REPORT PUBLISHED

22-A-05-111.01 to CMS - Open Unimplemented
Update expected on 04/20/2026
We recommend that Dialysis Clinic, Inc refund to the Federal Government the portion of the estimated $14,193,677 in improper payments for claims incorrectly billed to the Medicare program that are within the 4-year reopening period.

22-A-05-111.02 to CMS - Open Unimplemented
Update expected on 04/20/2026
We recommend that Dialysis Clinic, Inc. based on the results of this audit, exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule and identify any of those returned overpayments as having been made in accordance with this recommendation.

22-A-05-111.03 to CMS - Closed Implemented
Closed on 06/27/2023
We recommend that Dialysis Clinic, Inc. modify its medical record system to ensure that patient assessments and plans of care are completed and updated timely based on the completion date of the last assessment as required, to ensure all the required elements and signatures are included, and implement written policies and procedures to ensure staff availability during extended leave or vacancies.

22-A-05-111.04 to CMS - Closed Implemented
Closed on 06/27/2023
We recommend that Dialysis Clinic, Inc. modify its internal controls to ensure that weight measurements for home dialysis patients noted in beneficiaries' electronic health records are taken at the last documented dialysis treatment of the month.

22-A-05-111.05 to CMS - Closed Implemented
Closed on 06/27/2023
We recommend that Dialysis Clinic, Inc. reinforce, through staff and beneficiary training, its internal controls on how to maintain proper documentation of dialysis services in the medical record.

22-A-05-111.06 to CMS - Closed Implemented
Closed on 06/27/2023
We recommend that Dialysis Clinic, Inc. reinforce, through staff training, its internal controls for: (1) documenting the discontinuance of dialysis treatments and rescheduling any incomplete treatment, (2) ensuring that height and weight measurements are correctly recorded in the medical records before submitting Medicare claims, and (3) documenting physicians' monthly progress notes.

View in Recommendation Tracker

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