Department of Health and Human Services 
OFFICE  OF 
INSPECTOR  GENERAL 
MARKETING  OF  INCONTINENCE 
SUPPLIES  OFFICE OF INSPECTOR GENERAL 
The  mission  of the  Office of Inspector  General  (OIG),  as mandated  by Public  Law 95-452, as 
amended,  is to protect  the  integrity  of the Department  of Health  and Human  Services (HHS) 
programs  as well as the  health  and welfare  of beneficiaries  served by those  programs.  This 
statutory  mission is carried  out  through  a nationwide  network  of audits,  investigations,  and 
inspections  conducted  by three  OIG  operating  components:  the  Office of Audit  Services,  the 
Office of Investigations,  and the  Office of Evaluation  and Inspections.  The  OIG  also informs 
the Secretary  of HHS  of program  and management  problems  and recommends  courses  to 
correct  them. 
OFFICE OF AUDIT  SERVICES 
The  OIGS  Office of Audit  Services  (OAS)  provides  all auditing  services for HHS,  either  by 
conducting  audits with its own audit  resources  or by overseeing  audit work done  by others. 
Audits  examine  the  performance  of HHS  programs  and/or  its grantees  and contractors  in 
carrying out  their  respective  responsibilities  and are intended  to provide  independent 
assessments  of HHS  programs  and operations  in order  to reduce  waste,  abuse,  and 
mismanagement  and to promote  economy  and efficiency throughout  the  Department. 
OFFICE OF INVESTIGATIONS 
The  OIGS  Office of Investigations  (01)  conducts  criminal,  civil, and administrative 
investigations  of allegations  of wrongdoing  in HHS  programs  or to HHS  beneficiaries  and of 
unjust  enrichment  by providers.  The  investigative  efforts  of 01  lead to criminal  convictions, 
administrative  sanctions,  or civil money penalties.  The  01  also oversees  State  Medicaid  fraud 
control  units which investigate  and prosecute  fraud  and patient  abuse  in the  Medicaid  program. 
OFFICE OF EVALUATION  AND  INSPECITONS 
The  010s  Office of Evaluation  and Inspections  (OEI)  conducts  short-term  management  and 
program  evaluations  (called  inspections)  that  focus on issues of concern  to the  Department, 
the  Congress,  and the  public.  The  findings  and recommendations  contained  in these  inspection 
reports  generate  rapid,  accurate,  and up-to-date  information  on the  efilciency,  vulnerability, 
and effectiveness  of departmental  programs.  This report  was prepared  in the  Philadelphia 
Regional  Office, under  the  direction  of Joy Quill, Regional  Inspector  General  and Robert  A. 
Vito,  Deputy  Regional  Inspector  General.  Project  staff included: 
PHILADELPHIA  REGION  HEADQuARTERs 
Robert  A. Katz, R-eject Leader
 Thomas  I% Noplock,  F70gram Specialist 
Linda  M. Ragone,  Progam Analyst
 Richard  P. Lyons, 0jj7ce of Audit  Services 
Robert  A. Baiocco, Rogram  Analyst
 Linda  M. Moscoe,  Technical Suppoti  Staf 
Cynthia  Hansford,  Administrative  Staff
 Brian  P. Ritchie,  Technical Suppoti  Stafl 
Barbara  Tedesco,  Technical Suppoti  Staff 
To obtain a copy of this repor$ please cd  the Philadelphia  Regional Office at (MM)531-9562  Department  of Health and Human Services 
OFFICE  OF 
INSPECTOR  GENERAL 
MARKETING  OF  INCONTINENCE 
SUPPLIES  EXECUTIVE  SUMMARY 
PURPOSE 
This  report  describes  supplier  and  nursing  home  practices  that  can lead  to 
inappropriate  payments  for incontinence  supplies,  and  examines  issues  concerning 
Medicare  beneficiaries  use of incontinence  supplies. 
BACKGROUND 
Medicare  Part  B expenditures  for incontinence  supplies  have  more  than  doubled  tlom

1990 to  1993.  In  1993, these  expenditures  totaled  $230 million,  up from  $88 million  in

1990.

Incontinence  is the  inability  of the  body  to control  urinary  and  bowel  functions.  Under

the  Medicare  Part  B program,  the  Health  Care  Financing  Administration  (HCFA)  will

reimburse  suppliers  that  provide  incontinence  supplies  to aid individuals  whose

incontinence  condition  ...is of long and  indefinite  duration.  Such  reimbursement  is

provided  as part  of Medicares  coverage  for prosthetic  devices  such  as catheters  and

external  urinary  collection  devices.  The  HCFA  will also reimburse  for accessories  such

as irrigation  syringes  and  sterile  saline  solutions  that  aid in the  effective  and

therapeutic  use  of these  devices.  Claims  for incontinence  supplies  are  now processed

by four  Durable  Medical  Equipment  Regional  Carriers  (DMERCS).

We  collected  data  from  both  nursing  homes  and  Medicare  beneficiaries  for this report.

We  selected  a random  sample  of 180 nursing  homes  from  HCFAS Online  Survey

Certification  and  Reporting  system  and  a stratified  sample  of 400 beneficiaries  who

received  Medicare-reimbursed  incontinence  supplies  in 1993.

FINDINGS 
Inforrnution  jhm  musinghomes indicatesthatsupplienengagein qu.estikrblk  rnak%btg 
practices. 
Twenty-four  percent  of nursing  homes  reported  that  supplier  representatives  decide 
the  number  of supplies  to be  delivered  in a given month  to beneficiaries.  In addition, 
nursing  homes  reported  other  questionable  practices  by suppliers,  such  as routine 
waiving  of beneficiary  coinsurance  payments  and  offers  of inducements  in exchange  for 
allowing  suppliers  to prowde incontinence  supplies  to patients. 
Beneficiizritmx uy be receivingunnecessaryor non-coveredsupplies. 
Beneficiary  responses  indicate  that  their  incontinence  problems  did not  always meet 
Medicare  coverage  guidelines.  Beneficiaries  also report  that  they  do not  utilize  all of 
the  incontinence  supplies  that  are  reimbursed  by Medicare.  Of the  beneficiaries  who  received  these  supplies,  almost  30 percent  said they did not  use all the  supplies  paid 
for by Medicare. 
Numhg  homes reprt thatsome supplienprresentthem withfake or rni$kwhg 
infomlatim 
Twenty-two  percent  of nursing  homes  received  false  information  from  suppliers  stating 
that  Medicare  is introducing  new broader  coverage  for incontinence  supplies.  one 
out  of ten  nursing  homes  has been  incorrectly  told by a supplier  that  Medicare  will 
cover  other  routine  incontinence  supplies  such as absorbent  undergarments  if syringes, 
sterile  solutions,  and  lubricants  are  purchased. 
Many nursinghomes do not trackMedicare-reimbumesduppliks  to the  spec@  b~ 
for whichtheywerebilled 
More  than  two-thirds  of nursing  homes  (68 percent)  store  supplies  in a general  store 
room  without  patient  labels  or identification.  In addition,  almost  one-third  of nursing 
homes  (32 percent)  using Medicare-reimbursed  incontinence  supplies  stored  excess 
supplies  and  then  used  them  as needed  for all patients.  Medicare  and  individual 
beneficiaries  may be  paying  month  after  month  for unnecessary  supplies  which  maybe 
used  for other  patients. 
NExT  STEPS 
IncontinenceSupplies 
In response  to the  information  presented  in this report  and  a companion  report,  the 
Office  of Inspector  General  plans  to: 
o	 initiate  an audit  review  to examine  in more  detail  payments  made  for 
incontinence  supplies  in order  to determine  if any overpayments  are 
involved  in this area;  and 
o	 launch  a national  investigation  in this area,  examining  potentially 
fraudulent  practices  by specific  suppliers  of incontinence  supplies. 
We  also support  ongoing  activity in HCFA  and  the  DMERCS  to develop  more  specific 
coverage  guidelines  and  educate  providers  and  suppliers  about  proper  billing  for such 
supplies.  We  hope  the  information  contained  in this report  is helpful  as they  complete 
this  activity. 
OIG Studiesof OtherNumingHome Semces 
The  OIG  will continue  studies  and  audits  related  to its major  initiative  examining 
services  and  supplies  provided  to Medicare  beneficiaries  residing  in nursing  facilities. 
As this report  and  other  OIG  work  has  reflected,  the  fragmentation  of billing  for 
ii  services  and  supplies  provided  to residents  of nursing  homes  has  created  a host  of 
improper  incentives  for billers  to the  Medicare  program. 
Bundh%gof Sewi&r 
We  continue  to support  HCFAS efforts  to pursue  a systematic  solution  to these  kinds 
of problems  through  a requirement  for bundling of services  in nursing  home  settings. 
Under  such  an approach,  the  nursing  home  would  be  responsible  for providing 
commonly  needed  services  to residents  of that  facility, rather  than  allowing  for 
separate  billing by suppliers.  Such a solution  would  eliminate  the  incentives  suppliers 
now have  to aggressively  seek  out  patients  in nursing  homes  and  market  their  products 
inappropriately  in those  settings.  It would  also ensure  that  nursing  homes  take  on 
appropriate  responsibilities  for services  and  supplies  delivered  to residents  in their 
facilities. 
... 
111  TABLE  OF  CONTENTS

PAGE 
EXECUTIVESUMMARY  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..Qi

INTRODUCTION  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...1

FINDINGS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...5


Questionable  marketing  practices  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...5

.Beneficiaries  receiving  unnecessary  supp]ies  . . . . . . . . . . . . . . . . . . . . . . . . . . . .  6


Suppliers  present  misleading  information  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  7

 of Medicare  supplies  in ntu-singhomes  . . . . . . . . . . . . . . . . . . . . . .  9

NO  tracking 
IW3XT STEPS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..  O. . . . ...10

APPENDICES

A  Nursing  Facility  Survey  Instrument  and  Response  Rates  . . . . . . . . . . . . . . . .  A-1

B:  Beneficiary  Survey  Instrument  and  Response  Rates  . . . . . . . . . . . . . . . . . . . .  B-1
 INTRODUCTION

PURPOSE 
This  report  describes  supplier  and  nursing  home  practices  that  can  lead  to 
inappropriate  payments  for incontinence  supplies,  and  examines  issues  concerning 
Medicare  beneficiaries  use of incontinence  supplies. 
BACKGROUND 
Medicare  Part  B expenditures  for incontinence  supplies  have  more  than  doubled  from 
1990 to  1993.  In  1993, these  expenditures  totaled  $230 million,  up  from  $88 million  in 
1990. 
MedicareCoverageof IncontinenceSupplies 
Incontinence  is the  inability  of the  body  to control  urinary  and  bowel  functions. 
Reimbursement  for incontinence  supplies  are  included  as part  of Medicares  coverage 
for prosthetic  devices.  According  to Medicare  Carriers  Manual  (MCM)  section  2130, 
prosthetic  devices  (other  than  dental)  which  replace  all or part  of an internal  body 
organ  (including  contiguous  tissue),  or replace  all or part  of the  function  of a 
permanently  inoperative  or malfunctioning  internal  body  organ  are  covered  when 
furnished  on a physicians  order. 
Under  Medicare  Part  B, the  Health  Care  Financing  Administration  (HCFA)  will 
reimburse  suppliers  that  provide  incontinence  supplies  to aid individuals  whose 
incontinence  condition  ...is of long and  indefinite  duration.  Certain  items,  such  as 
absorbent  undergarments  or diapers,  are  specifically  excluded  from  coverage. 
Incontinence  supplies  include  prosthetic  devices  such  as catheters  and  external  urinary 
collection  devices  such  as pouches  or cups.  Catheters  are  flexible,  tubular  instruments 
used  to control  urinary  flow. The  HCFA  will  also  reimburse  for  supplies  that  aid  in 
the  effective  and  therapeutic  use  of these  devices.  These  supplies  include  items  such 
as drainage  bags,  irrigation  syringes,  sterile  saline  solutions,  and  lubricants. 
Carrier%xzssing  of IncontinenceSupplyClaims 
In June  1992, HCFA  issued  a final rule  that  designated  four  Durable  Medical 
Equipment  Regional  Carriers  (DMERCS)  to process  all durable  medical  equipment, 
prosthetic,  orthotic,  and  supply  claims.  Effective  October  1, 1993, the  DMERCS 
replaced  more  than  50 area  carriers  which had  previously  processed  DME  claims. 
The  geographical  areas  formerly  serviced  by the  carriers  were  phased  in under  the 
DMERCS  on a staggered  basis.  The  DMERCS  are  responsible  for  assuring  that 
claims  submitted  by suppliers  meet  all applicable  coverage  and  medical  necessity 
requirements  prior  to Medicare  reimbursement.  Each  DMERC  issued  its own 
1  coverage  and  reimbursement  policies  that  implement  Medicare  guidelines.  These

guidelines  included  appropriate  monthly  utilization  standards  for  certain  supplies  like

catheters.

To  achieve  uniformity  in incontinence  coverage,  the  DMERCS  issued  a draft  of a

single, national  policy concerning  urological  supplies  in October  1994.  The  draft  policy

redefines  and  clarifies  some  of the  standards  used  in processing  claims  for

incontinence  and  urological  supplies.  The  policy defines  what  products  meet  the

definition  of female  and  male  urinary  collection  devices.  It emphasizes  the  non-

coverage  of diapers  and  similar  absorptive  pads.  The  policy also reinforces  the

condition  of permanence  for coverage  purposes  and  stresses  that  incontinence

supplies  not  used  in conjunction  with covered  catheters  or external  urinary  collection

devices  are  not  covered.

MedicareFraudAlert 
In June  1994, a DMERC  issued  a Medicare  Fraud  Alert  describing  a supplier  scheme 
involving  the  marketing  of incontinence  kits to nursing  homes.  In this  case,  the 
supplier  advised  nursing  home  officials that  Medicare  was paying  for the  kits under  a 
pilot  program.  According  to the  alert,  supplier  representatives  exchange  kits 
containing  diapers  along with  supplies,  such as syringes,  saline,  and  lubricants,  to the 
nursing  homes  in exchange  for beneficiary  names  and  health  insurance  numbers.  The 
marketing  representatives  then  order  bulk  quantities  of supplies  billed  in the 
beneficiarys  name. 
The  alert  also indicated  that  the  suppliers  marketing  program  stated  that  the 
treatment  with this kit should  be  three  times  per  day for each  patient  in the  facility. 
This  resulted  in Medicare  being  billed  $1,800 per  month  per  beneficiary  in one  carrier 
jurisdiction. 
METHODOLOGY 
For  the  purposes  of this report,  we collected  data  from  both  nursing  homes  and 
Medicare  beneficiaries. 
NiusingHome Sample 
To  determine  how suppliers  market  incontinence  supplies  and  how nursing  homes 
handle  the  provision  of incontinence  supplies,  we selected  a random  sample  of 180 
skilled  nursing  facilities  and  nursing  homes  from  HCFAS Online  Survey  Certification 
and  Reporting  (OSCAR)  system.  The  system  contains  every nursing  home  that  is 
certified  to receive  Medicare  or Medicaid  funds. 
At the  time  our  sample  was generated  in September  1994, the  system  contained  data 
on  16,642 nursing  homes.  We  decided  to sample  nursing  homes  that  had  a total  size 
2
 of 60 beds  or more.  This  gave us a universe  of 12,879 nursing  homes  from  which we 
sampled  for the  180 nursing  homes. 
After  removing  four  facilities  which were  under  investigation  by the  Office  of 
Investigations  from  the  sample,  we sent  identical  questionnaires  to the  administrators 
of the  remaining  176 nursing  homes.  Surveys were  returned  by 140 nursing  homes 
giving us a response  rate  of 80 percent. 
We  chose  to project  responses  only to the  responding  universe  and  not  to the  total 
universe  of 12,879 nursing  homes.  Responses  from  the  140 nursing  homes  were 
projected  only to the  responding  universe  which would  be  80 percent  (rounded  from 
79.54545)  of the  12,879, or  10,245 nursing  homes. 
In order  to accurately  project  responses  to the  total  universe,  we would  have  had  to 
perform  an  analysis  of non-respondents  to  evaluate  the  characteristics  of nursing 
homes  who  chose  not  to respond.  Because  we knew very little  about  the  non-
responding  nursing  homes,  we decided  to use the  more  conservative  responding 
universe.  The  survey instrument,  nursing  home  responses,  and  an accompanying 
explanation  of the  survey results  appear  in Appendix  A. 
Bene@ary  Samp12 
To  collect  information  from  Medicare  beneficiaries  who use incontinence  supplies,  we 
sampled  beneficiaries  who received  Medicare-reimbursed  incontinence  supplies  in 
1993.  We  selected  a stratified  random  sample  drawn  from  the  National  Claims 
History  1 percent  sample  file.  This file includes  allowed  claims  paid  by Medicare  in 
1993.  As selection  criteria,  we used  43 billing codes  which  represent  the  types  of 
supplies  most  commonly  used  by incontinent  beneficiaries. 
We  found  that  4,507 individuals  met  our  selection  criteria.  This  number  decreased  to 
3,079 after  we removed  deceased  individuals  identified  through  information  in HCFAS 
Enrollment  Database. 
We  stratified  our  sample  into  the  following  two groups:  individuals  with  $1,000 or 
more  allowed  dollars  for incontinence  supplies  and  individuals  with under  $1,000 
allowed  dollars  for incontinence  supplies  during  1993.  We  sampled  400 beneficiaries; 
the  number  of beneficiaries
 from  each  stratum  is presented  in the  table  below. 
Strata
 Universe  Sample 
Over  $1,000
 476  200 
II 
Under  $1,000
 I 2,603  I 200 
II 
Total
 I 3,079  I 400 
3
 After  selecting  the  sample  and  mailing  questionnaires  to beneficiaries,  we decided  to 
remove  from  the  sample  any beneficiary  whose  claims  might  be  associated  with ostomy 
services.  This  resulted  in removing  81 beneficiary  responses  from  the  302 received. 
After  excluding  this group,  there  were  221 respondents  used  for the  analysis.  The 
responses  from  these  beneficiaries  were  projected  to  141,932 beneficiaries  nationwide. 
As was the  case  in the  nursing  home  sample,  we chose  to project  the  beneficiary 
responses  to the  responding  universe  and  not  the  total  universe  of beneficiaries 
receiving  Medicare-reimbursed  supplies.  We  selected  the  more  consemative  approach, 
since we did not  do an analysis  of non-responses  and  therefore  could  not  determine  if 
there  would  be bias  among  that  group.  A sample  of the  survey instrument,  confidence 
intervals,  and  beneficial  responses  appear  in Appendix  B. 
This  report  is one  of a series  of reports  concerning  Federal  payments  for incontinence 
supplies.  Questionable  Medicare  Payments  for  Incontinence  Supplies  (OEI-03-94-O0772) 
details  trends  and  expenditures  for incontinence  payments.  The  third  report,  Medicaid 
Payments  For Incontinence  Supplies  (C)E1-03-94-00771),  will  examine  how  the  Medicaid 
program  processes  claims  for  incontinence  supplies  in  14 States. 
This  inspection  was conducted  in accordance  with the  Quality  Standards  for  Inspections 
issued  by the  Presidents  Council  on Integrity  and  Efficiency. 
4
 FINDINGS 
INFORMATION  FROM  NURSING  HOMES  INDICATES  THAT  SUPPLIERS

ENGAGE  IN QUESTIONABLE  MARKETING  PRACIXES.

In some  nursing  homes,  suppliers  rather  than  physicians  or nurses  maybe  deciding 
what  amount  and  type  of supplies  are  ordered  for patients.  Twenty-four  percent  of 
nursing  homes  (2459 of 10,245) reported  that  supplier  representatives  decide  the 
number  of supplies  to be  delivered  in a given month  to beneficiaries.  Several  nursing 
homes  commented  that  suppliers  make  these  decisions  based  on Medicare  regulations. 
However,  only half  of the  nursing  homes  with patients  receiving  Medicare  reimbursed 
incontinence  supplies  knew  that  Medicare  limits the  amount  of certain  incontinence 
supplies  allowable  per  month. 
Almost  one-quarter  (24 percent)  of nursing  homes  reported  that  supplier 
representatives  have  helped  determine  which  patients  are  eligible  for Medicare 
reimbursement  of incontinence  supplies.  According  to  14 percent  of nursing  homes, 
supplier  representatives  have  also attempted  to help  facilities  determine  which  patients 
need  incontinence  supplies. 
Suppliers  in 20 percent  of the  nursing  homes  have  provided  the  necessa~  prescription 
forms  to be  filled  out  by the  patients  physician.  In some  nursing  homes  (7 percent) 
with Medicare-reimbursed  supplies,  suppliers  went  a step  further  and  filled  out  the 
prescription  forms  and  presented  it to the  nursing  home  for the  physicians  signature. 
Appendix  A describes  how data  was analyzed  for the  nursing  homes  using Medicare 
reimbursed  supplies. 
One  out  of five nursing  homes  have  had  supplier  representatives  request  to review 
patient  medical  records.  The  nursing  homes  reported  that  the  main  reason  that 
supplier  representatives  review  medical  records  is to collect  documentation  concerning 
the  physicians  order,  diagnosis,  and  necessity  of the  incontinence  supplies.  Others 
indicated  it was to record  usage  numbers  for billing purposes.  However,  several 
nursing  homes  said that  suppliers  do not  review  the  patients  medical  record  but  will 
ask nursing  home  staff to check  medical  records  and  provide  them  with  information. 
Another  nursing  home  said they  allow the  supplier  to review  patient  records  but  only 
if a staff member  is present. 
Some suppliemroutinelywaivethe 20 pementcoinsurancepaymentthatMedicare 
benejiciati  arerequikdtopay. 
Routine  waiver  of Medicare  20 percent  copayments  by suppliers  is unlawful.

Medicare  requires  beneficiaries  (unless  there  is financial  hardship)  to pay a 20 percent

portion  of the  cost of incontinence  supplies.  Twelve  percent  of nursing  homes

reported  that  suppliers  routinely  waive  the  20 percent  copayment  required  of

Medicare  beneficiaries.  One  of every four  Medicare  beneficiaries  (26 percent)

5  sampled  stated  that  they  did not  pay coinsurance  for their  incontinence  supplies  nor 
did they  have  any other  insurance  which would  have  paid  the  coinsurance  amount. 
While  12 percent  of nursing  homes  said they were  aware  of suppliers  waiving 
copayment  fees,  another  21 percent  did not  answer  the  question.  One  reason  for this 
may be  the  fact  that  nursing  homes  are  not  always aware  of what  suppliers  are  billing 
to Medicare  or the  amounts  that  Medicare  is reimbursing  for the  supplies.  Of the 
nursing  homes  that  have  patients  using incontinence  supplies  paid  for by Medicare, 
more  than  three-quarters  utilize  external  suppliers  that  directly  bill Medicare  . 
One  nursing  home  indicated  that  it was not  aware  of the  amount  of money  their 
supplier  was billing to Medicare  for incontinence  kits until  residents  began  to receive 
notices  of Medicare  billings in excess of $900 to $1200 dollars  a month  and  bills for 
large  monthly  copayment  amounts.  Upon  becoming  aware  of the  suppliers  billing 
practices,  the  nursing  home  refused  to accept  kits from  this company.  Another 
nursing  home  related  this experience: 
We were  approached  by a supplier  who stated  Medicare  paid  for 
incontinence  care.  After  15 years  of us paying, we decided  to try this. 
We were  appalled  when  families  called  us about  the  bills.  We  stopped 
the  service  immediately.  We have  not  seen  this supplier  again. 
Some musing homes  have been ofled  ikducemen~by suppliem. 
Eleven  percent  of the  nursing  homes  (1127)  reported  that  suppliers  had  offered  them 
inducements,  such  as free  supplies,  in exchange  for  allowing  them  to provide 
incontinence  supplies  to their  patients.  Nursing  homes  have  been  provided  free 
supplies  such  as catheter  care  kits, incontinent  pads,  and  disposable  undergarments. 
One  nursing  home  reported  that  they  received  free  gloves if they  ordered  incontinence 
supplies  and  free  disposable  diapers  with the  purchase  of incontinent  kits. 
BENEFICIARIES  MAY  BE  RECEIVING  UNNECESSARY  OR  NON-COVERED

suPPLIEs.

Beneficiary  responses  indicate  that  their  incontinence  problems  did not  always meet

the  coverage  guidelines  developed  by HCFA.  Medicare  guidelines  require

beneficiaries  to have  a diagnosis  of permanent  urinary  incontinence  in order  to receive

incontinence  supplies.  However,  15 percent  of the  beneficiaries  with  incontinence

conditions  related  that  they  experienced  problems  only sometimes  or rarely.

Beneficiaries  also report  that  they  do not  utilize  all of the  incontinence  supplies  that

are  reimbursed  by Medicare.  Of the  beneficiaries  who received  these  supplies,  almost

30 percent  said  they  did not  use all the  supplies  paid  for by Medicare.  As illustrated

in the  chart  on the  next  page,  while  15 percent  said they used  most  the  of the  supplies

another  14 percent  stated  they  used  some  or none  of the  supplies.

6
 Portion  of  Incontinence  Supplies	
Used  by  Beneficiaries	
MOST 
15% 
DON T RECALL  I 
-
13%  12% 
NONE 
2% 
%~ercentages have been  rounded to the nearest whole number 
NURSING  HOMES  REPORT  THAT  SOME  SUPPLIERS  PRESENT  THEM  WITH

FALSE  OR  MISLEADING  INFORMATION.

Nursing  homes  reported  incidents  where  suppliers  furnished  false  or misleading 
statements  about  Medicare  coverage  policies.  This  may lead  to non-covered  or 
unnecessary  services  being  billed  to Medicare  and  possibly  to beneficiaries. 
Twenty-two  percent  of nursing  homes  received  false  information  from  suppliers  stating 
that  Medicare  is introducing  new broader  coverage  for incontinence  supplies. 
Another  six percent  of nursing  homes  have  been  told  by suppliers  that  Medicare 
requires  the  use  of syringes,  sterile  saline  solutions,  and  lubricant/skin  barriers  on 
incontinent  patients.  As one  supplier  put  it, weve seen  this when  suppliers  are  trying 
to sell products  that  dont  meet  the  Medicare  criteria. 
Medicare  does  not  cover  supplies  such as disposable  incontinent  briefs  or absorbent 
undergarments  or pads.  There  are  indications,  however,  that  suppliers  may be 
marketing  these  products  as female  external  urinary  collection  devices.  Figure  1, on 
the  following  page,  is an illustration  of an actual  pouch  type  female  urinary  collection 
device.  The  device  is a plastic  pouch  which is attached  to the  body with  adhesives  and 
has  a drainage  port  at the  other  end.  This  device  would  meet  Medicare  guidelines  for 
coverage.  Figure  2 is an illustration  of what  one  supplier  is calling  a pouch-type 
female  urinary  collection  device  in information  provided  to nursing  homes.  This 
7  MANY  NURSING  HOMES  DO NOT  TIWC!K  MEDICARE-REIMBURSED

SUPPLIES  TO  THE  SPECIFIC  BENEFICIARY  FOR  WHICH  THEY  WERE

BILLED.

In many  nursing  homes  there  appears  to be no tracking  system  to ensure  that  all of 
the  incontinence  supplies  billed  to Medicare  for  a specific  patient  are  used  for that 
patient.  Almost  two-thirds  of nursing  homes  (62 percent)  using Medicare-reimbursed 
incontinence  supplies  report  that  when  supplies  are  delivered  by suppliers  they  are  not 
marked  or identified  as being  intended  solely for  a particular  patient.  Then  after 
receiving  the  supplies,  more  than  two-thirds  of nursing  homes  (68 percent)  store  them 
in a general  store  room  without  patient  labels  or identification. 
Since  the  majority  of nursing  homes  did not  indicate  the  existence  of any specific 
tracking  mechanism  for Medicare-reimbursed  supplies,  Medicare  and  individual 
beneficiaries  may be  paying  month  after  month  for unnecessa~  supplies  which  maybe 
used  for  other  patients.  In fact,  almost  one-third  of nursing  homes  (32 percent)  using 
Medicare-reimbursed  incontinence  supplies  stored  unused  excess  supplies  and  then 
used  them  as needed  for all patients. 
Several  nursing  homes  did report  that  supplies  are  tracked  for usage  by specific 
beneficiaries  and  subsequently  billed  to Medicare  only when  used.  Some  of these 
nursing  homes  explained  that  when  the  supply  is removed  from  the  supply  room  for 
usage  it is logged  on to a patient  usage  sheet.  Other  nursing  homes  described  that 
Medicare-reimbursed  supplies  were  kept  in supply  rooms  that  contained  only 
Medicare  Part  B supplies. 
9
 NEXT  STEPS
IncontinenceSuppikx 
In response  to the  information  presented  in this report  and  a companion  report,  the 
Office  of Inspector  General  plans  to: 
o initiate  an audit  review  to examine  in more  detail  payments  made  for 
incontinence  supplies  in order  to determine  if any overpayments  are 
involved  in this are%  and 
o launch  a national  investigation  in this area,  examining  potentially 
fraudulent  practices  by specific  suppliers  of incontinence  supplies. 
We  also support  ongoing  activity in HCFA  and  the  DMERCS  to develop  more  specific 
coverage  guidelines  and  educate  providers  and  suppliers  about  proper  billing for such 
supplies.  We  hope  the  information  contained  in this report  is helpful  as they  complete 
this activity. 
OIG StudiesOf  OtherN&g  Home Services 
The  OIG  will continue  studies  and  audits  related  to its major  initiative  examining 
services  and  supplies  provided  to Medicare  beneficiaries  residing  in nursing  facilities. 
As this report  and  other  OIG  work  has  reflected,  the  fragmentation  of billing  for 
services  and  supplies  provided  to residents  of nursing  homes  has  created  a host  of 
improper  incentives  for billers  to the  Medicare  program. 
Bundliizgof Sen.kes 
We  continue  to support  HCFAS efforts  to pursue  a systematic  solution  to these  kinds 
of problems  through  a requirement  for bundling of services  in nursing  home  settings. 
Under  such  an approach,  the  nursing  home  would  be  responsible  for providing 
commonly  needed  services  to residents  of that  facility, rather  than  allowing  for 
separate  billing by suppliers.  Such a solution  would  eliminate  the  incentives  suppliers 
now have  to aggressively  seek  out  patients  in nursing  homes  and  market  their  products 
inappropriately  in those  settings.  It would  also ensure  that  nursing  homes  take  on 
appropriate  responsibilities  for services  and  supplies  delivered  to residents  in their 
facilities. 
10
 APPENDIX  A
NURSING  FACILITY  SURVEY  INSTRUMENT  AND  RESPONSE  RATES 
Each  nursing  home  in our  sample  was asked  to complete  a 39 question  survey.  The 
questions  for the  survey were  developed  by reviewing  information  on incontinence 
supplies  produced  by HCF~  the  Durable  Medical  Equipment  Regional  Carriers,  and 
the  Office  of Investigations  within  the  OIG. 
For  most  questions,  we report  the  percentage  of nursing  home  responses  to the 
question  and  the  projected  number  of responses.  The  percentages  have  been  rounded 
to the  nearest  whole  number  and  therefore  will not  always add  up  to exactly  100 
percent.  The  projected  numbers  have  been  rounded  and  will therefore  not  always add 
up  to exactly  10,245 nursing  homes.  In addition,  for several  questions  respondents 
selected  more  than  one  answer.  These  questions  are  identified  by an asterisk  in the 
sample  survey  instrument  that  follows. 
We  also report  the  semi-width  for each  of the  response  percentages  at the  95 percent 
confidence  level. The  semi-width  is the  standard  error  of the  projection  multiplies  by 
1.96.  The  semi-width  added  or subtracted  to the  percentage  provides  a 95 percent 
confidence  interval.  The  range  of the  95 percent  confidence  interval  is presented  in 
the  table  following  each  question. 
In the  several  questions  where  respondents  were  asked  to provide  numerical  data  (e.g. 
number  of beds  or percentage  of patients  receiving  incontinence  supplies),  an average 
number  or percentage  is provided.  For  questions  where  we requested  textual 
responses,  a percentage  of respondents  who provided  written  responses  is given. 
In addition,  when  written  responses  were  furnished,  these  questions  were  analyzed  for 
content  and  used  in the  report.  However,  due  to the  length  of the  responses,  they  are 
not  presented  in this Appendix. 
There  are  instances  in the  report  where  information  from  a subset  of nursing  homes 
which  used  Medicare-reimbursed  incontinence  supplies  for patients  is presented. 
These  data  were  developed  by evaluating  responses  from just  the  75 percent  of 
nursing  homes  (7,584 projected  number  of facilities)  who  answered  yes to question 
six of the  survey- are any of the  incontinence  supplies  used  for patients  in your 
nursing  facility billed  to Medicare  Part  B. 
A-1
 INCONTINENCE  SUPPLIES:  NURSING  FACILITY  SURVEY 
This survey is being conducted by the Oftice of Evaluation and Inspections within the U.S. Department 
of Health and Human ServicesOffke of Inspector General.  We are currently reviewingMedicares 
payments for incontinence supplies.  We are also interested in learning about equipment suppliem 
marketing practices for incontinence supplies. 
Our review is focusing on Medicare Part B payment of incontinence supplies.  Please keep this in mind 
when completing this survey. We are not at this time interested in incontinence supplies that are 
included in Medicare Part A cost reports. 
All information DrOVidedwill be keDt confidential.  All data will be reported out in the amreeate and 
the namesofnurshv!facilitieswillneverbe identified to the Dublic. Ifyou haveanyquestions about 
this survey, please call Robert Katz or Linda Ragone at 1-800-531-9562. 
Please return this survey by September 15, 1994 in the enclosed self-addressed, pre-paid envelope or if 
you prefer you can fax it to us at (215) 5%-6987.  We appreciate your cooperation and assistance. 
Pklseprilu  &  fouowing rnfmmation@kzsefirtasthenqmn&mtthept7sonwho  ans Wersthemq 
W@@@ 
RESPONDENT

JOB TITLE

NURSING FACILITY:

ADDRESS:

TELEPHONE

General Information

A-2
 2.  How many beds does your nursing facility contain? 
Number of Skilled Nursing Beds  63.2  *10.9 
!  I 
II 
Number of Nursing Beds  62.3  *9.6 
3.  How many patients are currently residing in your facility? 
4.  What percentage of your population is eligible for Medieare Part B Coverage? 
Pereent Eligible for Medieare Part B Coverage  83.3  *3.2 
5. What percentage of your current patient population receive incontinence supplies (e.g. 
indwelling catheters, external urinary and fecal collection deviees, irrigation syringes, sterile 
irrigation solutions, skin barriers, lubricants)? 
Percent of Patients Receiving Incontinence Supplies  2s.4  *5.2 
6. Are any of the incontinence supplies used for patients in your nursing facility billed to 
Medicare Part B? 
A-3
 7. Does your nursing facility act as the sole supplier for incontinence supplies by billing Medicare 
Part B or do you have at least one external supplier of incontinence supplies? 
Nursing Facility is sole supplier  19   6.5  1947 
I  I  I 
At least one external supplier  69  *7.7  7069 
I  I  I 
Other (please specify)  6  *3.9  615 
I  I  I 
No Response  5  *3.6  512 
Use of Incontinence Sumiiea 
8.  Who decides that a patient has a need for incontinence supplies? 
Family Physician  69  *7.7  7069 
Medical Director of Nursing  9  *4.7  922 
Facility 
I 
Supplier Representative  o  o 
Nurse/Nursing Facility  54  *8.3  5532 
Attendant 
Invento~  Supervisor  1  *1.6  102 
Other (please specify)  14  *5.7  1434 
No Response  1  *1.6  102 
more than one answer was selectedb  y some respondents 
9. What medical conditions need to be present in order for you to order incontinence supplies for 
Medicare beneficiaries? 
Physical dysfunction of urinary  77  *7.O  7889 
or intestinal tracts 
Permanent Urinary Incontinence  49  *8.3  5020 
Need for indwelling catheter  54  *8.3  5532 
I  1 I 
Alzheimers/Dementia  16  *6.1  1639 
I I I 
Other (please specify)  16  *6.1  1639 
I I I 
No Response  4  *3.2  410 
more than one answer was selected by some respondents 
A-4  10.  Who deeides what specific supplies will be ordered for the patient? 
Family Physician  I  54  I  *8.3  I  5532 
Medical Director of Nursing  9  *4.7  922 
Facility 
Supplier Representative  4  *3.2  410 
Manufacturer of Supplies  1  +1.6  102 
Nurse/Nursing Facility  59  *8.1  6045 
Attendant 
Inventory Supervisor  I  11  I  *5.2  I  1127 
Other (please specifi)  I  14  I  *5.7  I  1434 
No Response  2  *2.3  205 
more than one answer was selected by some respondents 
11.  How are the incontinence supplies initially ordered? 
Nursing facility contacts supplier  81  *6.5  8298 
Supplier is told of need when  15  *5.9  1537 
supplier representative or 
delivery person visits 
Supplier suggests incontinence  3   2.8  307 
supplies would be appropriate 
for certain patients 
Other (please speci$)  12  *5.4  1229 
No Response  2  *2.3  205 
more than one answer was seleeted by some respondents 
A-5
 SumlierMarketiwPraeticea 
12.  How did your facility become aware of the suppliers you use? 
._:,...,,.. ., ,,,,,..,.,.:,..  .,,  ,.  ,,,:.,...... :,., ,:,,:,::,  ,,..:..:::,....., . ..:..::,.::: .::.,,,. , ,:. , :,,.,,. :~:.:>::...:,:,,: .,;,,  :,,. 
.,,.,.... :::%t&+@f;~!::::::.!.j:.:  ,<P &%i#@l :+: $x%.wwiti%:i:i;?.tijwwiNu#k*:
,.  .,,..: :,,::,:,.: ,.:.,.:.:.......  ...... ....::-........ 
....#tit6iWKw::?lxM@iiig*q;
.....  .  ...::. .-.,.  .,....,...... ........... 
Through supplier advertisements  10  +5.0  102.5 
Through supplier direct mail  6  *3.9  615 
marketing 
Through supplier  61  *8.1  6249 
representative/salesperson visit 
Other (please speeify)  32  *7.7  3278 
No Response  5  *3.6  512 
%more than one answer was selected by some respondents 
13.  How many different suppliers provide you with incontinence supplies for your patients? 
A-6
 16. Have supplier representatives ever attempted to help you determine which patients in your 
facility need incontinence supplies? 
Yes  14  *5.7  1434 
No  83  *6.2  8503 
I 
No Response  3  *2.8  307 
17. Have supplier representatives ever helped you determine which patients in your facility quali& 
for Medicare reimbursement of incontinence supplies? 
Yes  24  *7.1  2459 
No  73  *7.4  7479 
No ReSDOnse  3  *2.8  307 
18. Have you ever been offered inducements by suppliers such as free products to allow them to 
provide incontinence supplies to your patients? 
Yes  11  *5.2  1127 
No  85  *5.9  8708 
No ResDonse  14  \  +3.2  I  410 
If yes, please describe the nature of such inducements. 
IIProvided Information  13  II 
1 
Did Not Provide Information  87 
19. Has a supplier ever provided you with the necessary prescription forms to be filled out by your 
facilitysphysician or the patients family physician? 
Yes  20  *6.6  2049 
No  78  *6.9  7991 
No Res~onse  2  *2.3  205 
A-7  20.	 Has a supplier ever filled out the prescription form and presented it to you for the physicians 
signature? 
Yes  6  *3.9  615

No  89   *5.2  9118

No  5  *3.6  512

RW)OIN2 
21. Does the supplier representative decide the number of supplies to be delivered in a given 
month? 
22.  Have you ever received information from a supplier stating that Medicare is introducing new 
Yes  6  *3.9  615  I

No  91  *4.5  9323

I I I  1

No Response  3  *2.8  307

A-8
 24. Have you ever been told by a supplier that Medicare will cover other routine inecmtinemx 
supplies such as absorbent undergarments or pouches if syringes, sterile solutions, and 
lubricants are purchased? 
II I 
Yes  10  I  ,5.0  \  1025 
No  87  *5.6  8913 
No Response  3   2.8  307 
25. Do your suppliers routinely waive the 20 percent copayment required of Medicare 
beneficiaries? 
Yes  12  *5.4  1229 
No  66  *7.8  6762 
No Response  21  *6.7  2151 
26.  Have supplier representatives ever requested to review patient medieal records? 
I  I 
Yes  21  *6.7  2151 
I 
I 
No  74  I  *7.3  I  7581 
No Response  4  *3.2  410 
If yes, for what reason? 
IIProvided Information  24  I 
I 
Did Not Provide Information  76 
A-9
 27.  Are incontinence supplies marketed to you in kits or as bulk supplies? 
1Incontinence Kits  14  *5.7  1434 
I  I  I 
IIBulk Supplies  56  *8.2  5737 
I 
I  I  I 
Both Kits and Bulk Supplies  16  *6.1  1639 
I 
I  I  I 
Other (please speei&)  10  *5.O  102s 
I  I  I  1 
No Response  7  *4.2  717 
more than one answer was selected by some respondents 
28.  Are incontinence supplies shipped to you in kit or bulk form? 
Incontinence Kits  10  *5.O  102s
1 
Bulk Supplies  61  *8.1  6249
I 
Both Kits and Bulk Supplies  16  ~6.1  1639 
I 
I 1 
Other (please speei~)  8  *4.5  820 
I 
I I 
No Response  8  *4.5  820 
more than one answer was selected by some respondents 
29. When delivered by the supplier, are incontinence kits or supplies marked or identified as being 
intended solely for a particular patient? 
Yes  28  *7.4  2869 
No  63  *8.O  6454 
No Response  9  *4.7  922 
30. If suppliers market or ship incontinence kits to your facility,what supplies are typically 
contained in a kit that is not used for the insertion of a mtheter? 
Did Not Provide Information  73 
I 
A-10
 31. Ifsuppliers market or ship incontinence kits to your facility,do you typicallyuse all of the 
supplies within those kits? 
Yes  39  *8.1  3996 
No  14  *5.7  1434 
No Response  48  *8.3  4918 
If no, what supplies are typically not used? 
IIProvided Information  8  I 
I  u 
! Did Not Provide Information  I  92 
32.  Do suppliers provide you with all the necessary incontinence supplies for each patient once a 
month? 
Yes  50  *8.3  5123 
No  36  *8.O 
No Response  14  *5.7  1434 
If no, how are supplies provided by the supplier? 
I  II 
IIProvided Information  28 
Did Not Provide Information  72 
II 
33.  How are incontinence supplies stored in your nursing facility? 
II I  I  I  II 
Stored by individual patient  18  *6.4  1844 
IIassignment in supply room  I 
1 
IIStored in general supply room  74  I *7.3  I  7581  I
r  1 1 
IIStored by the patients bedside  8  *4.5  820  II 
I  1  1 
Other (please specify)  9  *4.7  922
1 1 I 
No Response  6  *3.9  615 
more than one answer was selected by some respondents 
A-II  34.  What happens to unused or excesssupplies? 
Returned to supplier  26  *7.3 
Stored for future use by specific  23  *7.O  2356 
patient 
Stored and used as needed for  34  *7.8  3483 
all patients 
Other (please speci&)  12  *5.4  1229 
No Rewonse  11  *5.2  1127 
1  . 1  1  1  II
4 more than one answer was selected by some respondents 
35.  Have you ever received suppIies that were not ordered? 
36.  Have you ever received supplies where no specific beneficiary was identified? 
37. Do you know if Medicare limits the maximum amount of incontinence supplies allowable for 
payment each month per patient? 
I

Yes  42  *8.2  4303 
No  51  *8.3  522S

No Response  6  *3.9  615

A-12
 If yes, please describe the limits. 
IIProvided Information  I  36  II 
i Did Not Provide Information  I  64  u 
38.  Do you have written or oral agreements with your incontinence suppliers? 
Yes  37   8.O  3791 
No  54  *8.3  5532 
No Response  9   4.7  922 
If yes, please deseribe the nature of such agreements and enclose a copy of any written 
agreements. 
]]Provided Information  I  31  II 
Did Not Provide Information  69 
39.  Have you ever complained to Medicare or other authorities about the marketing or business 
practices of any suppliers? 
Yes  6  *3.9  615 
1  1 
No  91  *4.5  9323 
I  1 
No Response  4  *3.2  410 
If yes, what was the nature of these practices? 
Thank you for completing this survey.  If you have additwnal  comments  or would like to answer any of the 
questbts  more I?@, please  u.rethe nextpage marked Aaiiitional  Comments for this putpose.  Please return 
the survey in the self-addressed postage-paid  envelope we included in our mailing to you or fzx the survey 
and any additional  information to us at (215) 596-6987 
A-13  APPENDIX  B
BENEFICIARY  SURVEY  INSTRUMENT  AND  RESPONSE  RATES 
Medicare  beneficiaries  in our  sample  were  asked  to complete  a short  six question 
survey.  The  answers  to these  questions  provided  information  on the  severity  of their 
incontinence  conditions  and  the  use of supplies  for their  condition. 
For  the  questions,  we report  the  percentage  of beneficiary  responses  to the  question 
and  the  projected  number  of responses.  The  percentages  have  been  rounded  to the 
nearest  whole  number  and  therefore  will not  always add  up  to exactly  100 percent. 
The  projected  numbers  have  been  rounded  and will therefore  not  always add  up to 
exactly  141,932 beneficiaries. 
We  also report  the  semi-width  for each  of the  response  percentages  at the  95 percent 
confidence  level. The  semi-width  is the  standard  error  of the  projection  mutiplies  by 
1.96.  The  semi-width  added  or subtracted  to the  percentage  provides  a 95 percent 
confidence  interval.  The  range  of the  95 percent  confidence  interval  is presented  in 
the  table  following  each  question. 
The  sample  survey  instrument  with results  begins  on the  next  page. 
B-1
 OUR  RECORDS  SHOW  THAT  BETWEEN  ._.  AND

MEDICARE  PAID  FOR  SUPPLIES  RELATED  TO =ONTINENCE  ON

YOUR  BEHALF.

FOR  THE  PURPOSES  OF  THIS  SURVEY,  INCONTINENCE  SUPPLIES

INCLUDE  EQUIPMENT  AND  PRODUCTS  INTENDED  FOR  PERSONS  WHO

HAVE  PROBLEMS  WITH  BIADDER  AND/OR  BOWEL  CONTROL.

PLEASE  ANSWER  THE  FOLLOWING  QUESTIONS. 
1. DID  YOU  RECEIVE  INCONTINENCE  SUPPLIES  DURING  THE  TIME 
PERIOD  MENTIONED  ABOVE?  SUCH  SUPPLIES  COULD  HAVE 
INCLUDED  CATHETERS,  GAUZE  PADS,  ABSORBENT 
UNDERGARMENTS  (SIMILAR  TO  DIAPERS),  LUBRICANTS, 
DRAINAGE  AND  COLLECTION  DEVICES,  OR  STERILE  LIQUIDS. 
All  59  *9. 1  66,578 
I
Most  15  *6.4  16,950 
I  I  I 
1S ome  12  ~6.O  13,030 
1 
None  2  *2.3  2,254 
Do Not Recall  13  *6.3  14,570 
Yes  59  *8.3  82,955
I  1 
No  36  *8. 1  50,915 
Do Not Recall  1  *1.8  1,540 
No Response  5  *3.2  6,522 
B-2  3.
 WERE YOU RECEIVING SERVICES FROM A HOME HEALTH AGENCY (SUCH AS A 
VISITING NURSE OR AIDE) DURING THE TIME PERIOD  MENTIONED ABOVE? 
Yes  13  *6.O  19,061
1  I 
No  78  *6.8  110,651 
1  II 
Do Not Recall  4  *2.6  5,221  I 
1 
No Response  5  *3.2  6,998 
4.
 DID YOU PAY COINSURANCE (THE USUAL 20 PERCENT OF THE AMOUNT 
MEDICARE ALLOWS FOR SUPPLIES) FOR INCONTINENCE SUPPLIES RECEIVED 
DURING THE PERIOD MENTIONED ABOVE? 
5.
 DURING THE TIME PERIOD MENTIONED ABOVE, DID YOU HAVE ANY 
PROBLEMS ASSOCIATED WITH BLADDER OR BOWEL CONTROL? 
B-3
 IF YOU ANSWERED YES TO QUESTION 5, HOW OFTENDID YOU EXPERIENCE 
SUCH PROBLEMS? (CHECK ONE BLOCK) 
WHEN YOU COMPLETE THE SURVEY FORM- PLEASE IU?lUIW IT TO US IN THE 
ENcLXXED POSTAGE-PAIDENVELOPE 
IF YOU HAVE ANY QUESTIONS REGARDING  THIS SURVEY>

PLEASE CALL RICHARD LYONS, PROJECT DIRECTOR,  AT (410) 966-3143.

PLEASE USE THE SPACE BELOW IF YOU WISH TO ADD ANY ADDITIONAL COMMENTS 
B-4
 . 
Department of Health and Human Services 
OFFICE  OF 
INSPECTOR  GENERAL 
MARKETING  OF  INCONTINENCE 
SUPPLIES 
JUNE GIBBS BROWN 
Inspector  General 
DE_ER  1994 
OEI-03-94-00770 
  OFFICE OF INSPE(XOR  GENERAL 
The  mission  of the  Office of Inspector  General  (OIG),  as mandated  by Public  Law 95-452, as 
amended,  is to protect  the  integrity  of the Department  of Health  and Human  Services (HHS) 
programs  as well as the  health  and welfare  of beneficiaries  served by those  programs.  This 
statutory  mission  is carried  out  through  a nationwide  network  of audits,  investigations,  and 
inspections  conducted  by three  OIG  operating  components:  the  Office of Audit  Seti=$  the 
Office of Investigations,  and the  Office of Evaluation  and Inspections.  The  OIG  also informs 
the  Secretary  of HHS  of program  and management  problems  and recommends  courses  to 
correct  them. 
OFFICE OF AUDIT  SERVICES 
The  OIGS Office of Audit  Services  (OAS)  provides  all auditing  services for HHS,  either  by 
conducting  audits with its own audit  resources  or by overseeing  audit work  done  by others. 
Audits  examine  the  performance  of HHS  programs  and/or  its grantees  and contractors  in 
carrying out  their  respective  responsibilities  and are intended  to provide  independent 
assessments  of HHS  programs  and operations  in order  to reduce  waste,  abuse,  and 
mismanagement  and to promote  economy  and efficiency throughout  the  Department. 
OFFICE OF INVESTIGATIONS 
The  010s  Office of Investigations  (01)  conducts  criminal,  civil, and administrative

investigations  of allegations  of wrongdoing  in HHS  programs  or to HHS  beneficiaries  and of

unjust  enrichment  by providers.  The  investigative  efforts  of 01  lead to criminal  convictions,

administrative  sanctions,  or civil money  penalties.  The  01  also oversees  State  Medicaid  fraud

control  units which investigate  and prosecute  fraud  and patient  abuse  in the  Medicaid  program.

OFFICE OF EVALUATION  AND  INSPECIIONS 
The  OIGS  Office of Evaluation  and Inspections  (OEI)  conducts  short-term  management  and 
program  evaluations  (called  inspections)  that  focus on issues of concern  to the  Department, 
the  Congress,  and the  public.  The  findings  and recommendations  contained  in these  inspection 
reports  generate  rapid,  accurate,  and up-to-date  information  on the  efficiency, vulnerability, 
and effectiveness  of departmental  programs.  This report  was prepared  in the Philadelphia 
Regional  Office, under  the direction  of Joy Quill, Regional  Inspector  General  and Robert  A. 
Vito,  Deputy  Regional  Inspector  General.  Project  staff included: 
PHILADELPHIA  REGION  HEADQuARm 
Robert  A. Katz, Project  Leader  Thomas A. Noplock,  Program Specialist 
Linda M. Ragone, Progam Analyst  Richard  P. Lyons, Ofice  of Audit  Services 
Robert  A. Baiocco, fiogram  Analyst  Linda  M. Moscoe,  Technical Suppoti  Stafl 
Cynthia  Hansford,  Administrative  Stafl  Brian  P. Ritchie,  Technical Support Stafi 
Barbara Tedesco, Technical Support Sta# 
To obtain a copy of this repo~  please call the PhiladelphiaRegional Off&at  (800) 531-9562.