08/04/2014    Paul Kesselman, DPM

Is This Sign Sufficient for DME Purposes? (George Jacobson, DPM)

Hours by appointment only are only allowed to
certain supplier categories. Physicians are exempt
from the thirty hour rule but not the requirement
of posting certain hours. I don't see why it would
be a problem for you to post open hours and by
appointment hours so long as you do post those
hours you are definitely open. I have forwarded
that issue to the NSC for further comment.

The rationale behind this specific requirement
escapes me and needs an immediate response to the
NSC from the entire medical community. I see this
as a top priority.

However, we also must respect and be sensitive as
to why the NSC is being so strict.
There are too many fraudulent suppliers and there
is too much fraud and abuse in DME. I have not
seen many OIG busts of physician suppliers
providing DME to their own patients, involved in
criminal DME fraud.

Therefore, to excessively punish an honest
provider and sanction them with exclusion because
an office staff of one was in the rest room, did
not hear the buzzer, went downstairs to get the
mail when the inspector rang, or a whole host of
every day real scenarios for why one person may
have not heard the buzzer is a punishment system
that itself has gone out if control.

Supporting the exclusion of criminals and other
nefarious entities from becoming or continuing as
DMEPOS providers is one thing . Excessive
punishment of honest individuals and protecting
our patients’ access to care needs to be
respected. It's time to modify a set of rules with
unintended consequences which addresses real life
scenarios for the urban and rural provider.

Paul Kesselman, DPM, Woodside, NY,
drkesselmandpm1@hotmail.com

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