Federal Authorities are Targeting Continuous Glucose Monitoring (CGM) Device Reimbursement Claims Nationwide

The Centers for Medicare and Medicaid Services (CMS) expanded Medicare coverage for continuous glucose monitoring (CGM) devices in 2018. This led to a substantial increase in Medicare reimbursement requests for these devices—which in turn led to enhanced scrutiny of the health care providers, pharmacies, and other entities submitting these reimbursement claims. One particular area of concern which is proving problematic for many Medicare participants in 2021 is the classification of CGM devices as durable medical equipment (DME).

“There are several potential stumbling blocks for Medicare participants when it comes to billing for CGM—including issues with regard to the classification of CGM as DME. CGM billing compliance is currently a nationwide enforcement priority, and entities that fail to establish and maintain compliance can face substantial liability in the event of an audit or investigation.” – Dr. Nick Oberheiden, Founding Attorney of Oberheiden P.C.

Establish Clear Lines of Communication and a Chain of Command

All internal personnel should be instructed not to communicate with auditors or agents directly. There should be a clear chain of command, and all communications with federal authorities should be routed through the practice’s or company’s defense counsel. Read more