Review of Epogen Internal Control Procedures at Fresenius Massachusetts Providers for Calendar Year 1999

EXECUTIVE SUMMARY:

The objective of this review was to determine if Massachusetts Fresenius providers have established adequate internal controls and procedures to ensure that claims for EPOGEN (EPO) are supported and billed in accordance with Medicare rules and regulations.  Based on a random sample of 200 claims valued at $249,528, we did identify portions of 23 claims totaling $3,585 not eligible for Medicare reimbursement.  In addition, we addressed our concerns with respect to the use of EPO protocols as standing physician orders and with physicians not signing off EPO dosage changes.  We recommended that Fresenius (1) strengthen their internal controls and procedures to ensure that the claims submitted for EPO are supported and billed in accordance with Medicare rules and regulations, and (2) resolve with the Centers for Medicare and Medicaid Services and the Associated Hospital Service as to what physician documentation is required when using a protocol containing an algorithm as a standing physician order for a nurse to administer EPO. 

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