4) Require Two Additional Random, Unannounced Site Visits for All New Providers
Two unannounced site visits should be conducted by NSC during the first year of operation for new HME providers.
5) Require a Six-Month Trial Period for New Providers
The NSC should issue a provisional, non-permanent supplier number to new suppliers for a six-month trial period. After six months of demonstrated compliance, the provider would receive a "regular" supplier number.
6) Establish an Anti-Fraud Office at Medicare
CMS should establish an office with the sole mandate of coordinating detection and deterrence of fraud and improper payments across the Medicare and Medicaid programs.
7) Ensure Proper Federal Funding for Fraud Prevention
Increase federal funding to ensure that NSC completes site inspection and other anti-fraud measures.
8) Require Post-Payment Audit Reviews for All New Providers
Medicare's program safeguard contractors should conduct post-payment sample reviews for six months worth of claims submitted to Medicare by new providers.
9) Conduct Real-Time Claims Analysis and a Refocus on Audit Resources
Medicare must analyze billings of new and existing providers in real time to identify aberrant billing patterns more quickly.
10) Ensure All Providers Are Qualified to Offer the Services They Bill
A cross-check system within Medicare databases should ensure that homecare providers are qualified and accredited for the specific equipment and services for which they are billing.
11) Establish Due Process Pr
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