Independent Audit Report of a Dialysis Provider’s Contract Pricing and Billing Compliance

To meet the healthcare needs of eligible veterans, VA contracts with community providers for dialysis. These contracted community providers must accurately price dialysis procedures when submitting claims for payment.
In October 2013, VA awarded a contract to a dialysis provider. When that contract expired in March 2019, the VA Office of Inspector General (OIG) was asked to assist in determining whether money was owed by either party. The OIG provided a report to VA with its finding and recommendation. During that audit, the OIG identified concerns related to pricing accuracy and local billings for both the expired contract and a new contract. As a result, the OIG conducted this attestation examination to determine whether the contractor complied with each contract’s billing terms and conditions.
In the OIG’s opinion, except for instances of incorrect billings to local VA facilities, the contractor’s assertion that it billed in accordance with the terms and conditions of its old and new contracts is fairly stated in all material respects. The OIG found fewer pricing errors in the new contract than the old. But the OIG also found the contractor incorrectly billed 1,212 claims to local VA facilities and received almost $6.4 million from these facilities. For some of these claims, the contractor billed both the Financial Services Center and a local VA facility, thereby receiving payments from both for the same claim. The contractor asserted that incorrect billings have stopped and that it had begun providing refunds. The OIG contacted eight VA facilities for confirmation of these refunds. Some of the eight facilities confirmed refunds, while others did not. Accordingly, the OIG made two recommendations to the contracting officers, requesting that the contractor perform a self-audit of local VA claims and verify that the contractor has completed the process of refunding local VA claims.