Review of Internal Control Procedures at Dialysis Clinic, Inc. Facilities Located at Boston and Somerville, Massachusetts for the Administration of Epogen for Calendar Year 1999

EXECUTIVE SUMMARY:

The objective of this review was to determine whether Dialysis Clinic, Inc. (DCI) facilities have established adequate internal controls and procedures to ensure claims submitted for Epogen (EPO) are supported and billed in accordance with Medicare rules and regulations.  We reviewed the billing and medical records for 224 claims to determine whether EPO services billed and reimbursed were supported. In a significant number of claims we found reconciliation inconsistencies between the number of units of EPO prescribed in the written physician order, administered by the facility to the patient, and billed to the Medicare program. We recommended that DCI strengthen its procedures to ensure that the claims submitted for EPO are supported and billed in accordance with Medicare rules and regulations.

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