Review of Medicare Payments to DaVita, Incorporated for Epogen Services Provided at Franklin Dialysis Center, Philadelphia, Pennsylvania

EXECUTIVE SUMMARY:

The objective of this audit was to determine if DaVita established adequate internal controls and procedures to ensure that claims for Epogen were supported and billed in accordance with Medicare requirements.  We found that 44 of the 143 claims reviewed did not meet Medicare payment requirements for Epogen.  We identified inconsistencies between the number of units of Epogen prescribed in the written physician order, administered by the facility, and billed to Medicare.  Independent dialysis facilities were required to maintain complete medical records and furnish sufficient information to support the payment.  During the period when the services included in our review were provided, DaVita had controls in place for submitting claims that included Epogen.  Based on our review, DaVita personnel did not always follow those procedures.  In addition, medical records supporting services provided were not always consistently archived.  As a result, DaVita received payments of $15,096 for Epogen services that did not meet Medicare requirements.  DaVita personnel could not locate medical records that supported 12 claims.  They believed that lack of storage space, purging of records, and staff changes lead to inconsistent archiving of medical records.  As a result, we were unable to review those claims to determine if $15,984 in payments for Epogen met Medicare requirements.