To: The Commissioner
From: Inspector General
Subject: Disability Determination Services' Use of Volume Consultative Examination Providers (A-07-02-12049)
The attached final Management Advisory Report presents the results of our review. Our objectives were to determine why only a small number of State Disability Determination Services receive discounts on consultative examinations purchased from volume medical providers and whether the potential exists to increase discounts from volume medical providers.
Please comment within 60 days from the date of this memorandum on corrective action taken or planned on each recommendation. If you wish to discuss the final report, please call me or have your staff contact Steven L. Schaeffer, Assistant Inspector General for Audit, at (410) 965-9700.
James G. Huse, Jr.
THE INSPECTOR GENERAL
SOCIAL SECURITY ADMINISTRATION
USE OF VOLUME CONSULTATIVE
MANAGEMENT ADVISORY REPORT
We improve SSA programs and operations and protect them against fraud, waste, and abuse by conducting independent and objective audits, evaluations, and investigations. We provide timely, useful, and reliable information and advice to Administration officials, the Congress, and the public.
The Inspector General Act created independent audit and investigative units, called the Office of Inspector General (OIG). The mission of the OIG, as spelled out in the Act, is to:
Conduct and supervise independent and objective audits and investigations
relating to agency programs and operations.
Promote economy, effectiveness, and efficiency within the agency.
Prevent and detect fraud, waste, and abuse in agency programs and operations.
Review and make recommendations regarding existing and proposed legislation and regulations relating to agency programs and operations.
Keep the agency head and the Congress fully and currently informed of problems in agency programs and operations.
To ensure objectivity, the IG Act empowers the IG with:
Independence to determine what reviews to perform.
Access to all information necessary for the reviews.
Authority to publish findings and recommendations based on the reviews.
By conducting independent and objective audits, investigations, and evaluations,
we are agents of positive change striving for continuous improvement in the
Social Security Administration's programs, operations, and management and in
our own office.
Our objectives were to determine (1) why only a small number of State Disability Determination Services (DDS) receive discounts on consultative examinations (CE) purchased from volume medical providers (VMP) and (2) whether the potential exists to increase CE discounts from VMPs.
In making disability determinations for the Social Security Administration (SSA), the DDSs are responsible for obtaining sufficient medical evidence from treating sources (medical sources who have or have had an ongoing treatment relationship with the claimant) to determine whether the claimant is disabled under the law. However, when medical evidence is not available or is insufficient, DDSs purchase CEs, to include medical and psychological examinations, x-rays, and laboratory tests. SSA procedures define a VMP as one specializing in performing CEs for State agencies. Usually, a VMP is a provider with estimated CE billings of $100,000 or more, annually.
RESULTS OF REVIEW
Our review disclosed that 38 of the 54 DDSs purchased CEs from VMPs during Fiscal Year 2001. The other 16 DDSs stated that small CE workloads did not attract VMPs. However, only 5 of the 38 DDSs that purchased CEs from VMPs received CE discounts. The remaining 33 DDSs that purchased CEs from VMPs offered various reasons for not receiving discounts, with low CE rates cited as the primary reason. Specifically, some of the DDSs stated their CE fees were lower than Medicare rates. We confirmed that four of the five DDSs that received discounts from VMPs in Fiscal Year 2001 had CE rates lower than Medicare's rates.
We believe the potential exists to increase CE discounts at some DDSs, especially those that have established relationships with VMPs. Furthermore, SSA needs to assist the DDSs in expanding the use of negotiated discounts with VMPs as a means of reducing medical costs and should concentrate on those DDSs where such an approach would be cost beneficial to the Agency. We also identified best practices that may improve the DDSs ability to procure discounts from VMPs.
RECOMMENDATIONS AND AGENCY COMMENTS
We recommend that SSA (1) identify the methods and processes used by the New
York, Florida, and Oregon DDSs to obtain discounts from multiple VMPs and disseminate
the information to other DDSs and (2) provide guidance to the DDSs for recruiting
VMPs and negotiating discounted CE fees. SSA agreed with our recommendations.
See Appendix E for the full text of SSA's comments.
Table of Contents
RESULTS OF REVIEW 4
DDSs Receiving Discounts from VMPs 4
DDSs Not Receiving Discounts from VMPs 6
Comparison of DDS and Medicare Fees 8
Potential Impact of VMP Discounts 8
Best Practices for Obtaining Discounts 8
CONCLUSIONS AND RECOMMENDATIONS 10
APPENDIX A - Disability Determination Services' Reasons For Not Using Volume Medical Providers in Fiscal Year 2001
APPENDIX B - Reasons Disability Determination Services Did Not Secure Discounts on Consultative Examinations from Existing Volume Medical Providers in Fiscal Year 2001
APPENDIX C - Hypothetical Discounts at 33 Disability Determination Services That Did Not Receive Discounts from Volume Medical Providers
APPENDIX D - Comparison of Disability Determination Services' Rates for Consultative Examinations to Medicare's Rates
APPENDIX E - Agency Comments
APPENDIX F - OIG Contacts and Staff Acknowledgments
CE Consultative Examination
CPT Current Procedural Terminology
DDS Disability Determination Services
DI Disability Insurance
FY Fiscal Year
OD Office of Disability
OIG Office of the Inspector General
POMS Program Operations Manual System
SSA Social Security Administration
SSI Supplemental Security Income
VMP Volume Medical Provider
Our objectives were to determine (1) why only a small number of State Disability Determination Services (DDS) receive discounts on consultative examinations (CE) purchased from volume medical providers (VMP) and (2) whether the potential exists to increase discounts from VMPs.
The Disability Insurance (DI) program, established in 1954 under title II of the Social Security Act, provides benefits to disabled wage earners and their families. In 1972, Congress enacted title XVI, the Supplemental Security Income (SSI) program. Title XVI provides a nationally uniform program of income and disability coverage to financially needy individuals who are aged, blind or disabled.
Disability determinations under the DI and SSI programs are made by the DDSs in each State or other responsible jurisdiction in accordance with Federal regulations. The DDS is responsible for obtaining evidence sufficient to determine whether the claimant is disabled under the law. In making disability determinations, the DDSs obtain medical evidence from the claimants' treating sources. However, when this medical evidence is not available or is insufficient to make a disability determination, the DDS can purchase CEs. Each State is responsible for determining the rate of payment used by its DDS to purchase CEs. Accordingly, CE rates of payment vary among the DDSs.
Concerned about rising DDS medical costs, the Social Security Administration (SSA) encouraged the DDSs to contain medical spending. In response, the DDSs decreased the average national medical cost per case slightly from $110 per case in Fiscal Year (FY) 1999 to $107 per case in FY 2001. However, medical costs remain a concern at the national level and for particular DDSs. Nationally, in the first 6 months of FY 2002, the medical cost per case averaged $119, which is $8 per case over the projected $111 cost per case. From FY 1999 to FY 2001, the medical cost per case increased for some DDSs. For example, the Texas DDS' medical cost per case increased $11.76 to a total of $127.02, and the Georgia DDS had an increase of $21.19, raising the total to $142.31 per case.
Agency procedures define a VMP as a medical provider that specializes in performing CEs for State agencies. Usually, a VMP is a provider with estimated billings of $100,000 or more annually for CEs.
SCOPE AND METHODOLOGY
We developed a questionnaire to collect information from the DDSs on CEs purchased from VMPs during FY 2001. In January 2002, SSA's Office of Disability (OD) sent our questionnaire to all 54 DDSs, asking them to provide responses to OD. In March 2002, we received the DDS' responses from OD.
Our analysis of the questionnaires and subsequent discussions with the DDS' staff identified five DDSs (New York, Florida, Oregon, Michigan, and Nevada) that received discounts on CEs purchased from VMPs during FY 2001, and we selected these DDSs for our review. We also selected five additional DDSs (California, Georgia, Illinois, Ohio, and Texas) to determine why they had not obtained discounts on CEs from VMPs. These DDSs were selected because they had CE expenditures of $10 million or more during FY 2001, which would indicate a greater possibility of discounts from VMPs because of larger CE workloads.
For the 10 DDSs included in our review, we did the following.
We interviewed DDS staff to obtain information on their CE processes, including experiences with VMPs.
We obtained the CEs comprising 50 percent or more of FY 2001 CE expenditures and asked the DDSs for assistance in crosswalking their CE codes to the 2001 Medicare current procedural terminology (CPT) codes. We did not verify information received from the DDSs in terms of types, numbers or dollar amounts of CEs. We then compared DDS' rates of payment for the CEs to Medicare's rates of payment for the same or similar medical service to determine the variances between Medicare and DDS rates of payment.
We performed our field work between March and July 2002 in Kansas City, Missouri.
The audited entities were DDSs under the Deputy Commissioner for Disability
and Income Security Programs.
Results of Review
Our review disclosed that 38 of the 54 DDSs purchased CEs from VMPs during FY 2001. The remaining 16 DDSs stated that small CE workloads did not attract VMPs (Appendix A). However, only 5 of the 38 DDSs that purchased CEs from VMPs received CE discounts (New York, Florida, Oregon, Nevada, and Michigan). Of these, the New York, Florida, and Oregon DDSs reported more success in obtaining discounts from multiple VMPs than the Michigan and Nevada DDSs.
The remaining 33 DDSs offered various reasons for not receiving discounts, with low CE rates of payment cited as the primary reason (Appendix B). Specifically, some of the DDSs stated that their CE fees were lower than Medicare rates of payment, which are considered low rates of payment by some in the medical community. However, we confirmed that four of the five DDSs that received discounts from VMPs in FY 2001 were able to obtain discounts even though their CE rates were lower than Medicare's rates of payment.
DDSs RECEIVING DISCOUNTS FROM VMPs
In FY 2001, the New York, Florida, Oregon, Nevada, and Michigan DDSs received discounts on CEs purchased from VMPs. The New York, Florida, and Oregon DDSs reported more success in recruiting multiple VMPs and negotiating discounts than the Nevada and Michigan DDSs. The VMP experiences of these five DDSs are discussed below.
New York DDS
Since 1986, the New York DDS has used competitive bidding to obtain CEs from VMPs. Initially, the DDS concentrated its competitive bidding efforts in the most densely populated areas of the State where large medical communities existed. Later, the DDS expanded competitive bidding to other, less populated areas of the State. The New York DDS staff stated that securing VMPs had not been a problem. However, they informed us that competitive bidding works best in areas where the minimum population is 300,000 to 400,000.
In FY 2001, VMPs received about 94 percent of the $25 million expended by the New York DDS for CEs. During this period, the DDS purchased CEs from 11 VMPs, of which 5 were secured through competitive bidding. Securing VMPs by competitive bidding has reduced the New York DDS' medical costs. The DDS could not provide us a dollar savings, but estimated cost savings from VMPs ranged from 9 to 45 percent.
Since the early 1980s, the Florida DDS has been successful at informally negotiating CE discounts with its VMPs. The DDS staff attributed the success to (1) large urban areas with large numbers of medical providers to compete for CEs, (2) professional relations staff who are aggressive in recruiting VMPs and negotiating CE discounts, and (3) management that supports recruitment of VMPs and discount negotiation efforts.
In FY 2001, the Florida DDS spent about $13.6 million to purchase CEs. About 18 percent of this payment went to 15 VMPs at discounted fees. The DDS was unable to provide us cost savings that resulted from discounted fees from VMPs because data were not readily accessible.
Since 1984, the Oregon DDS has used competitive bidding to obtain CEs from VMPs at discounted fees. DDS staff stated that competitive bidding began as one method of controlling medical costs. The DDS reported no problems in recruiting VMPs.
In FY 2001, the DDS spent about $4.1 million on CEs. The Oregon DDS paid 19 percent of the total to its three VMPs who discounted fees. The DDS reported savings of $51,594 in FY 2001. However, the savings represented only 6.7 percent of the CE costs incurred for VMPs and related to a fee schedule that was significantly higher than Medicare fees paid for comparable services.
In FY 2001, the Nevada DDS had one VMP who formerly worked for the Illinois DDS and retired to Nevada. The medical provider agreed to perform comprehensive physical examinations for the Nevada DDS at a substantial discount. DDS staff estimated the DDS saved about $59,000 in FY 2001. About 13 percent of the DDS' FY 2001 total CE expenditures of $1.5 million went to this VMP.
The Nevada DDS has been unsuccessful in recruiting additional VMPs. Nevada DDS staff stated that recruiting VMPs was a problem because medical providers complain the CE fees are too low. The DDS further attributed its lack of success in securing VMPs to the State's sparse population. There are only two major urban areas in Nevada: Reno/Carson City and Las Vegas. Most claimants in rural areas must travel to one of the two urban areas for a CE.
In FY 2001, the Michigan DDS spent about $7.2 million purchasing CEs, and about 59 percent of the total was paid to eight VMPs. Michigan reported little success in securing VMPs to perform CEs at discounted fees. In FY 2001, only one of Michigan's eight VMPs offered a discounted fee, and the discount was only $1 per CE.
According to DDS staff, VMPs considered the DDS' CE fees too low, and competitive bidding was not successful. The Michigan DDS' unsuccessful attempt at competitive bidding began a decade ago in Wayne County, the most densely populated county, which includes Detroit. Few medical providers met the requirements to competitively bid. Three clinics were awarded 3-year contracts. One clinic withdrew its bid, and the other two clinics experienced start-up problems, such as volume distribution and scheduling. After 3 years, instead of starting over, the DDS extended the contracts for another term. After this term expired, the DDS had problems rebidding the contracts. Only two clinics met the qualifications, but one clinic was $40 above the DDS' fee schedule. The other provider gave the DDS a $1 discount on each CE. In FY 2002, this provider would not renew the contract, and the DDS put competitive bidding on hold.
DDSs NOT RECEIVING DISCOUNTS FROM VMPs
We also selected five large CE volume DDSs for our review to determine why they did not obtain discounts on CEs from their VMPs (California, Georgia, Illinois, Ohio, and Texas). These DDSs were selected based on having annual CE expenditures of $10 million or more, accounting for 34 percent of all CE expenditures in the United States during FY 2001.
We would expect these DDSs to have success at negotiating discounts on CEs given the large volume of CEs purchased. However, staff from these five DDSs attributed low CE rates of payment as the foremost reason for not securing discounts from their VMPs.
During FY 2001, VMPs received about 63 percent of the California DDS' total CE payments (see Appendix C). DDS staff stated that recruiting VMPs is not a problem in urban areas. However, the DDS staff stated it had not attempted to negotiate discounted CE fees with the VMPs because its CE fee schedule is too low to expect discounts. DDS staff also stated that it has avoided attempting to secure discounts through competitive bidding because it would be administratively burdensome. For example, each of the DDS' 12 branch offices would have separate contracts for VMPs in their respective areas, and the branch offices do not have sufficient staff to monitor the contracts.
VMPs received about 24 percent of the Georgia DDS' total CE payments in
FY 2001 (see Appendix C). The Georgia DDS staff stated that recruiting VMPs is a problem, and securing discounts from VMPs is difficult because of the DDS' low CE fee schedule. DDS staff said the fee schedule is rarely changed because the process is lengthy. To raise a fee, the DDS must conduct an impact study and obtain approval from the executive management team and the parent agency. According to the staff, the Georgia DDS tried competitive bidding several years ago, but no bidders responded, probably because the DDS' CE fees were below Medicare rates.
In FY 2001, VMPs received about 32 percent of the Illinois DDS' total CE payments (see Appendix C). The staff stated that recruiting VMPs is not difficult, but the DDS does not use contracting or competitive bidding. In fact, staff reported there is an abundance of VMPs interested in performing CEs for the DDS. However, the staff stated that discounts were not negotiated with VMPs because the VMPs complain about the low rates of payment and the low volume of CE referrals. The staff said the DDS fee schedule essentially has not changed for 10 years, but the costs of doing business have increased for VMPs.
In FY 2001, VMPs received about 52 percent of the Ohio DDS' total CE payments (see Appendix C). Recruiting VMPs is not a problem, but the DDS staff said that none of the VMPs are happy with the CE rates of payment. The Ohio DDS was considering competitive bidding to reduce medical costs and visited the New York DDS to learn more about contracting. There was some hesitation to pursue competitive bidding because of potential obstacles, including (1) DDS staff have to expend resources on administrative tasks related to contracting, (2) low CE fees prevented VMPs from bidding for CEs, and (3) potential problems canceling contracts because of poor VMP performance.
In FY 2001, VMPs received about 32 percent of the Texas DDS' total CE payments (see Appendix C). According to Texas DDS staff, Texas State law prohibits the DDS from using a competitive bidding process, but the DDS is allowed to negotiate rates of payment for CEs. Recruiting VMPs is not a problem for the Texas DDS. However, the staff stated that VMPs complained about its low CE fees. The staff also said the DDS paid VMPs the lower of the provider's billed amount or the DDS fee schedule. Discounts were not negotiated with VMPs because the DDS considers its fee schedule already heavily discounted.
COMPARISON OF DDS AND MEDICARE FEES
The five DDSs in our review that did not obtain discounts from VMPs cited already low CE fees as the common reason discounts were not obtained. To determine whether the CE fees at these five DDSs varied significantly from the CE fees at the five DDSs that obtained discounts from VMPs, we compared the CE fee schedule amounts to Medicare fees for the same or similar service. This comparison was performed for each of the 10 DDSs for the CEs that comprised 50 percent or more of their total FY 2001 CE expenditures (see Appendix D for comparison examples).
Our comparison disclosed that most CE fees for 9 of the 10 DDSs (5 DDSs without discounts and 4 DDSs with discounts) were less than the 2001 Medicare fees. Our review of the experiences of four of the nine DDSs (Florida, Michigan, Nevada and New York) shows that low CE fees did not prevent VMPs from providing discounts.
POTENTIAL IMPACT OF VMP DISCOUNTS
Of the 38 DDSs that purchased CEs from VMPs, 33 did not receive discounts. In FY 2001, the 33 DDSs expended about $69.4 million to purchase CEs from VMPs. If these DDSs received even minimal CE discounts from VMPs, SSA could realize significant savings.
Discount Percentage Potential Annual Savings in CE Costs
5 $ 3.47
10 $ 6.94
For the details, see Appendix C.
BEST PRACTICES FOR OBTAINING DISCOUNTS
In our communications with DDS staffs, we identified several factors that improved DDS success in obtaining discounts from VMPs. The factors include the following.
A professional relations staff trained in aggressive VMP recruiting and discount negotiation.
Large urban populations, numbers of medical providers, and large CE workloads attract VMP competition.
Medical providers see timely DDS payments as an incentive.
Elimination of unnecessary paperwork makes a medical provider more willing to perform CEs for the DDS.
The DDS' administrative burden can be lightened with access to State contracting and legal departments to assist in the competitive bidding process, contract development and contract monitoring.
DDS management must be willing to provide the resources necessary for recruiting VMPs.
Experimentation with competitive bidding and/or contracting in a limited geographical area with a limited number of medical providers will help the DDSs to gain experience and resolve start-up problems before expanding the process to other areas of the State.
Medical providers who are newly licensed or starting a new practice may be more likely to perform CEs at discounted fees.
Conclusions and Recommendations
We recognize that all DDSs may not be able to secure discounts from VMPs because of such factors as size and varying workloads. However, the DDSs should aggressively attempt to recruit VMPs that perform CEs at discounted fees before concluding that such discounts are not possible. In FY 2001, the New York, Florida, and Nevada DDSs showed that some VMPs would provide CE discounts even when DDS rates of payment already are considered low by some in the medical community.
SSA and the DDSs should explore discounts from VMPs as a way of reducing rising medical costs. These efforts should include experimenting with competitive bidding and/or informal negotiations to obtain discounts on CEs from VMPs. We believe that SSA needs to assist the DDSs in expanding the use of negotiated discounts with VMPs as a means of reducing medical costs and should concentrate on those DDSs where such an approach would be cost beneficial to the Agency.
We are recommending that SSA:
1. Identify the methods and processes used by the New York, Florida, and Oregon DDSs to obtain discounts from multiple VMPs and disseminate the information to other DDSs.
2. Provide guidance to the DDSs on recruiting VMPs and negotiating discounted CE fees.
SSA agreed with our recommendations. Specifically, SSA will request the New York, Florida, and Oregon DDSs to share their expertise in obtaining discounts from VMPs and will send a memorandum of "best practices" to all DDSs. (See Appendix E for the full text of SSA's comments.)
Disability Determination Services' Reasons for Not Using Volume Medical Providers in Fiscal Year 2001
REASONS FOR NO VOLUME MEDICAL PROVIDERS
Delaware Numbers of consultative examinations (CEs) insufficient to produce a $100,000 provider.
Guam Disability Determination Services purchased $16,000 in CEs for FY 2001-small workload.
Hawaii Has "volume vendors," but none fit the $100,000 criterion.
Idaho Has "volume vendors," but none fit the $100,000 criterion.
Iowa Has "volume vendors," but none fit the $100,000 criterion; dispersed population,
difficult to have volume medical providers (VMP).
Maine Small population does not permit high volume of CEs in any one area or specialty.
Montana Does not have the workload in any one area to support VMPs.
New Hampshire Numbers of CEs in given area or specialty are insufficient to produce a VMP.
North Dakota Small population, annual workload of 5,400 claims.
Puerto Rico Has one VMP, but did not reach the $100,000 criterion.
Rhode Island Small population-VMPs are not practical.
South Dakota Small population, annual workload of 8,000 claims, does not fit the $100,000 criterion.
Utah Small population, do not have the demand for VMPs.
Vermont Number of claimants cannot support a VMP.
Virgin Islands Too small for volume.
Wyoming Small population; has no provider with $100,000 worth of services.
Reasons Disability Determination Services Did Not Secure Discounts on Consultative Examinations from Existing Volume Medical Providers in Fiscal Year 2001
Disability Determination Services REASONS FOR NO DISCOUNTS VMPs have made special accommodations
Volume Provider Quality of exams and reports may suffer DDS uses fee schedule rates of payment set by the parent agency Fee schedule reflects low or noncompetitive payment rates Noncompetitive fees cause difficulty in recruiting, maintaining CE panel DDS cannot guarantee the volume of exams
Other Reasons or Notes
Alabama 4 4
Alaska 4 Parent agency requires payment for CEs at the medical provider's usual and customary charges.
Arizona 4 4 4 VMPs receive an additional fee for traveling to remote areas.
California 4 4 4
Colorado 4 Parent agency requires DDS to competitively bid some CEs. Fees to VMPs are based on contract agreements.
Connecticut 4 4 4
District of Columbia 4 4
Georgia 4 4 4
Illinois 4 4 4
Indiana 4 4
Kansas 4 4
Kentucky 4 4 4 4
Louisiana 4 4
Maryland 4 4 4 4 Vendor rotation system required by parent agency.
Massachusetts 4 4
Minnesota 4 4 4
Mississippi 4 4 4
Nebraska 4 4 4
New Jersey 4 4 4 Wants flexibility in scheduling CEs.
New Mexico 4 4 4
North Carolina 4 4 4 4
Ohio 4 4
Oklahoma 4 4 4
Pennsylvania 4 Wants to preserve relations by using community-based providers.
South Carolina 4 4
Tennessee 4 4 4
Texas 4 4
Washington 4 4
West Virginia 4
Wisconsin 4 4 4
Hypothetical Discounts at 33 Disability Determination Services That Did Not Receive Discounts from Volume Medical Providers
A C T U A L P A Y M E N T S H Y P O T H E T I C A L D I S C O U N T S#
PYMT 5% OF
PAYMENT 10% OF
PAYMENT 15% OF
PAYMENT 20% OF
1 Alabama $ 7,063,218 $ 425,818 6.03% $ 21,291 $ 42,582 $ 63,873 $ 85,164
2 Alaska $ 1,038,784 $ 264,541 25.47% $ 13,227 $ 26,454 $ 39,681 $ 52,908
3 Arizona $ 3,457,643 $ 488,313 14.12% $ 24,416 $ 48,831 $ 73,247 $ 97,663
4 Arkansas $ 2,858,514 $ 216,037 7.56% $ 10,802 $ 21,604 $ 32,406 $ 43,207
5 California $ 34,700,904 $ 21,945,061 63.24% $ 1,097,253 $ 2,194,506 $ 3,291,759 $ 4,389,012
6 Colorado $ 3,134,854 $ 1,596,198 50.92% $ 79,810 $ 159,620 $ 239,430 $ 319,240
7 Connecticut $ 2,213,794 $ 157,025 7.09% $ 7,851 $ 15,703 $ 23,554 $ 31,405
8 District of
Columbia $ 971,811 $ 265,212 27.29% $ 13,261 $ 26,521 $ 39,782 $ 53,042
9 Georgia $ 12,751,358 $ 3,115,825 24.44% $ 155,791 $ 311,583 $ 467,374 $ 623,165
10 Illinois $ 10,505,026 $ 3,322,320 31.63% $ 166,116 $ 332,232 $ 498,348 $ 664,464
11 Indiana $ 5,340,158 $ 1,603,038 30.02% $ 80,152 $ 160,304 $ 240,456 $ 320,608
12 Kansas $ 2,104,846 $ 642,750 30.54% $ 32,138 $ 64,275 $ 96,413 $ 128,550
13 Kentucky $ 6,187,152 $ 2,626,827 42.46% $ 131,341 $ 262,683 $ 394,024 $ 525,365
14 Louisiana $ 7,644,523 $ 2,073,152 27.12% $ 103,658 $ 207,315 $ 310,973 $ 414,630
15 Maryland $ 3,431,600 $ 246,248 7.18% $ 12,312 $ 24,625 $ 36,937 $ 49,250
16 Massachusetts $ 1,071,926 $ 246,923 23.04% $ 12,346 $ 24,692 $ 37,038 $ 49,385
17 Minnesota $ 2,651,208 $ 963,132 36.33% $ 48,157 $ 96,313 $ 144,470 $ 192,626
18 Mississippi $ 3,428,921 $ 822,641 23.99% $ 41,132 $ 82,264 $ 123,396 $ 164,528
19 Missouri $ 4,271,236 $ 769,191 18.01% $ 38,460 $ 76,919 $ 115,379 $ 153,838
20 Nebraska $ 1,254,125 $ 193,147 15.40% $ 9,657 $ 19,315 $ 28,972 $ 38,629
21 New Jersey $ 7,029,138 $ 3,199,901 45.52% $ 159,995 $ 319,990 $ 479,985 $ 639,980
22 New Mexico $ 1,731,743 $ 165,228 9.54% $ 8,261 $ 16,523 $ 24,784 $ 33,046
23 North Carolina $ 9,790,655 $ 1,444,535 14.75% $ 72,227 $ 144,454 $ 216,680 $ 288,907
24 Ohio $ 14,146,179 $ 7,397,034 52.29% $ 369,852 $ 739,703 $ 1,109,555 $ 1,479,407
25 Oklahoma $ 3,644,084 $ 780,047 21.41% $ 39,002 $ 78,005 $ 117,007 $ 156,009
26 Pennsylvania $ 9,540,197 $ 241,554 2.53% $ 12,078 $ 24,155 $ 36,233 $ 48,311
27 South Carolina $ 5,575,261 $ 571,374 10.25% $ 28,569 $ 57,137 $ 85,706 $ 114,275
28 Tennessee $ 8,900,185 $ 2,083,387 23.41% $ 104,169 $ 208,339 $ 312,508 $ 416,677
29 Texas $ 21,831,456 $ 7,022,493 32.17% $ 351,125 $ 702,249 $ 1,053,374 $ 1,404,499
30 Virginia $ 3,787,188 $ 340,434 8.99% $ 17,022 $ 34,043 $ 51,065 $ 68,087
31 Washington $ 5,893,144 $ 1,609,000 27.30% $ 80,450 $ 160,900 $ 241,350 $ 321,800
32 West Virginia $ 3,360,598 $ 1,538,531 45.78% $ 76,927 $ 153,853 $ 230,780 $ 307,706
33 Wisconsin $ 3,684,032 $ 1,037,679 28.17% $ 51,884 $ 103,768 $ 155,652 $ 207,536
TOTALS $ 214,995,461 $ 69,414,596 $ 3,470,730 $ 6,941,460 $10,412,189 $13,882,919
Comparison of Disability Determination Services' Rates for Consultative Examinations to Medicare's Rates Three Examples of Disability Determination Services With Discounts
Of the five Disability Determination Services (DDS) with discounts, the Florida, New York, and Oregon DDSs reported more success securing discounts from volume medical providers (VMP). The Florida and New York DDSs had consultative examination (CE) fee schedule amounts that were less than 2001 Medicare fee schedule rates (except for x-rays in New York). On the other hand, the Oregon DDS obtained discounts from VMPs perhaps because of having considerably higher CE fee schedule amounts than the 2001 Medicare rates.
To compare DDS fee schedule amounts to the 2001 Medicare rates, we asked DDSs in this review to send us the types of CEs most frequently purchased by the DDS that account for at least 50 percent of its FY 2001 CE expenditures and the fee schedule amounts. We did not verify the information sent to us by the DDSs.
Florida DDS: Since the early 1980s, the Florida DDS has been securing discounts by having the staff negotiate with VMPs. The Florida DDS' fee schedule is based on 1991 Medicare rates, and the staff indicated that CEs were obtained at or below these rates in FY 2001. The DDS could not provide us with the amount of savings obtained through discounted CEs.
To compare the DDS' fees to the 2001 Medicare fees, the DDS provided us with two CE types that accounted for at least 50 percent of its FY 2001 CE expenditures. In the table below, the data indicate the DDS fee schedule amounts were lower than the crosswalked examinations in the 2001 Medicare fee schedule.
CODE DESCRIPTION DOLLAR
CODE DESCRIPTION DOLLAR
90630 * General Medical $ 123.79 99243 Office Consultation (Detailed) $ 139.64 $(15.85) (13)
A211 * Psychological $ 121.01 90801 Psychiatric Examination $ 171.60 $(50.59) (42)
* We performed the crosswalk to Medicare codes.
New York DDS: The New York DDS has used competitive bidding since 1986 to secure
discounts from VMPs. The DDS' fee schedule is based on State workers' compensation
fees. In FY 2001, the DDS claimed savings that varied from
9 to 45 percent, based on the contractor, location and amount of discount.
To compare the DDS' fee schedule amounts to the 2001 Medicare rates, the New York DDS provided us with four CE types that accounted for at least 50 percent of its FY 2001 CE expenditures. In the table below, data for New York DDS show that the fee schedule amounts of three of the four CEs are lower than the crosswalked examinations in the 2001 Medicare fee schedule (except for x-rays).
NEW YORK DDS
CODE DESCRIPTION DOLLAR
CODE DESCRIPTION DOLLAR AMOUNT Dollar
90003 * Complete Psychiatric Examination $ 95.00 90801 Psychiatric Diagnostic Interview Examination $ 191.42 $(96.42) (101)
90001 * Complete Specialist Examination $ 95.00 99243 Office Consultation (Detailed) $ 157.29 $(62.29) (66)
90002 * Complete Orthopedic Examination $ 95.00 99243 Office Consultation (Detailed) $ 157.29 $(62.29) (66)
72100** X-ray Spine, Lumbar, Sacral, Ap
And Lateral $ 88.00 72100 Radiological Exam, Spine, Lumbosacral; Ap and Lateral $ 56.47 $ 31.53 36
* We performed the crosswalk to Medicare codes. ** The DDS provided the Medicare code.
Oregon DDS: Since 1984, the Oregon DDS has used competitive bidding to secure discounts from VMPs. Like New York's fee schedule, Oregon DDS' fee schedule is based on State workers' compensation fees. In FY 2001, the DDS claimed a $51,594 savings from discounted CEs.
To compare the DDS' fee schedule amounts to the 2001 Medicare fees, Oregon DDS provided us with three CE types that accounted for at least 50 percent of the DDS' total CE expenditures in FY 2001. In the following table, data show that the DDS fee schedule amounts of the three CEs were higher than the crosswalked examinations in the 2001 Medicare fee schedule.
CODE DESCRIPTION DOLLAR
AMOUNT MEDICARE CODE DESCRIPTION DOLLAR
E114 * Psychodiagnostic $243.97 99244 Office Consultation (Comprehensive) $ 182.43 $ 61.54 25
E105 * Orthopedic $243.97 99244 Office Consultation (Comprehensive) $ 182.43 $ 61.54 25
E116 * Adult Neuropsychological $515.12 96117 Neuropsychological Testing Battery $ 239.31 $275.81 54
* The DDS performed the crosswalk to Medicare codes.
Date: January 31, 2003
To: James G. Huse, Jr.
From: Larry Dye
Chief of Staff
Subject: Office of the Inspector General Draft Management Advisory Report, "Disability Determination Services' Use of Volume Consultative Examinations Providers" (A-07-02-12049)-INFORMATION
We appreciate OIG's efforts in conducting this review. Our comments and recommendations are attached.
Please let us know if we can be of further assistance. Staff questions can be referred to Janet Carbonara on extension 53568.
COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL (OIG) DRAFT MANAGEMENT ADVISORY REPORT, "DISABILITY DETERMINATION SERVICES' USE OF VOLUME CONSULTATIVE EXAMINATION PROVIDERS" (A-07-02-12049)
We thank you for the opportunity to review this draft management advisory report and appreciate your efforts. It is Agency policy to make every effort to ensure that purchases of consultative examinations (CE) by State Disability Determination Services (DDS) follow the appropriate regulatory guideline with regard to fee schedules.
We believe that it is part of the Agency oversight responsibility to continue to advocate that DDSs share their best practices to foster efficiency and low costs in the CE process. In Appendix C of this report, there is a list of potential savings if DDSs were able to negotiate discounts from Volume Medical Providers (VMPs). However, we believe even under the best circumstances these savings cannot be realized.
Identify the methods and processes used by the New York, Florida, and Oregon DDSs to obtain discounts from multiple VMPs and disseminate the information to other DDSs.
We will contact New York, Florida and Oregon by May 2003, to request that they share their expertise in obtaining discounts from VMPs. We will then prepare a memorandum to transmit their "best practices" to all the DDSs.
Provide guidance to the DDSs on recruiting VMPs and negotiating discounted CE fees.
We will contact New York, Florida and Oregon by May 2003, to request that they share their expertise in obtaining discounts from VMPs. We will then prepare a memorandum to transmit their "best practices" to all the DDSs.
OIG Contacts and Staff Acknowledgments
Mark D. Bailey, Director, (816) 936-5591
In addition to those named above:
Francis W. Fernandez, Director
Carol Cockrell, Program Analyst
Ronald Bussell, Lead Auditor
Kenneth Bennett, Lead Auditor
Kimberly Beauchamp, Writer-Editor
For additional copies of this report, please visit our web site at www.ssa.gov/oig
or contact the Office of the Inspector General's Public Affairs Specialist at
(410) 966-1375. Refer to Common Identification Number A-07-02-12049.
Overview of the Office of the Inspector General
Office of Audit
The Office of Audit (OA) conducts comprehensive financial and performance audits of the Social Security Administration's (SSA) programs and makes recommendations to ensure that program objectives are achieved effectively and efficiently. Financial audits, required by the Chief Financial Officers' Act of 1990, assess whether SSA's financial statements fairly present the Agency's financial position, results of operations and cash flow. Performance audits review the economy, efficiency and effectiveness of SSA's programs. OA also conducts short-term management and program evaluations focused on issues of concern to SSA, Congress and the general public. Evaluations often focus on identifying and recommending ways to prevent and minimize program fraud and inefficiency, rather than detecting problems after they occur.
Office of Executive Operations
The Office of Executive Operations (OEO) supports the Office of the Inspector General (OIG) by providing information resource management; systems security; and the coordination of budget, procurement, telecommunications, facilities and equipment, and human resources. In addition, this office is the focal point for the OIG's strategic planning function and the development and implementation of performance measures required by the Government Performance and Results Act. OEO is also responsible for performing internal reviews to ensure that OIG offices nationwide hold themselves to the same rigorous standards that we expect from SSA, as well as conducting investigations of OIG employees, when necessary. Finally, OEO administers OIG's public affairs, media, and interagency activities, coordinates responses to Congressional requests for information, and also communicates OIG's planned and current activities and their results to the Commissioner and Congress.
Office of Investigations
The Office of Investigations (OI) conducts and coordinates investigative activity related to fraud, waste, abuse, and mismanagement of SSA programs and operations. This includes wrongdoing by applicants, beneficiaries, contractors, physicians, interpreters, representative payees, third parties, and by SSA employees in the performance of their duties. OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.
Counsel to the Inspector General
The Counsel to the Inspector General provides legal advice and counsel to the Inspector General on various matters, including: 1) statutes, regulations, legislation, and policy directives governing the administration of SSA's programs; 2) investigative procedures and techniques; and 3) legal implications and conclusions to be drawn from audit and investigative material produced by the OIG. The Counsel's office also administers the civil monetary penalty program.