Garfunkel Wild’s David Traskey, Partner and former Senior Counsel with the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) was quoted in the article, “OIG Urges Action on ‘Massive’ Increases in Skin Substitute Spending”, in the Report on Medicare Compliance (Volume 34, Number 33) published by the Health Care Compliance Association (HCCA). David gives an OIG insider’s perspective on the matter of skin substitutes.
“It’s good to see OIG acknowledge the critical role that CMS’s pricing methodology plays in the skyrocketing costs associated with skin substitute products,” said David Traskey, a former OIG senior counsel now with Garfunkel Wild. “Unfortunately, audits, investigations and claw backs have been the main strategy for addressing the spike in spending on wound care procedures with skin substitutes, but this only addresses one potential piece of the puzzle. If you want to stop billions of dollars going out the door, the first order of business is to fix the pricing. After that, make sure providers bill, document and code the way they’re supposed to.”
CMS is relying on various theories to deny claims and claw back money for skin substitutes. “Some of those theories are wrong,” Traskey said. For example, auditors may refer to the future LCD even though it hasn’t taken effect yet or they may cite an existing LCD that doesn’t apply in the provider’s jurisdiction. When there’s an applicable LCD, auditors may rely on it for the wrong purpose, such as denying a claim for a pressure ulcer based on an LCD that applies only to diabetic foot ulcers and venous leg ulcers, Traskey said.
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