In recent meetings with CMS, we have learned that while the date to begin medical review functions is August 3rd, there will likely be a delayed time frame before audit requests officially go out. CMS is currently working to develop instructions for contractors and intends to take a "toe in the water” approach, as opposed to opening up a flood gate of audits.
We also learned that TPE audits will not be part of this initial audit phase. This makes sense, as TPE audits are prepay reviews and, due to claim processing system limitations, there are less flexibilities to grant extensions for those suppliers that would need more time to respond. CMS has made it clear that during this pandemic they do not want to want to hold up payments for suppliers. As such, there is no time frame given for the restart of TPE.
So what does that mean? All audits resuming on August 3rd will be post-pay audits. The DME MACs will begin first and will be followed by RACs and lastly, the SMRC. Initially, COVID claims will not be part of the audit focus, and the reviews will instead be for dates of service prior to PHE.
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