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Department of Health and Human Services

OFFICE OF 

INSPECTOR GENERAL 

M P
EDICAID  ROVIDER 

E S :

NROLLMENT  TANDARDS
M E P
EDICAL  QUIPMENT  ROVIDERS

Daniel R. Levinson

Inspector General 

October 2006

OEI-04-05-00180
 Report Template Update  = 04-30-05_rev.13  
Office of Inspector General 

http://oig.hhs.gov 
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 the following operating components: 
Office of Audit Services 
The 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.  These assessments help reduce waste, 
abuse, and mismanagement and promote economy and efficiency throughout HHS. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 
HHS, Congress, and the public with timely, useful, and reliable information on 
significant issues.  Specifically, these evaluations focus on preventing fraud, waste, or 
abuse and promoting economy, efficiency, and effectiveness in departmental programs.  
To promote impact, the reports also present practical recommendations for improving 
program operations.   
Office of Investigations 
The Office of Investigations (OI) 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 OI lead to criminal 
convictions, administrative sanctions, or civil monetary penalties. 
Office of Counsel to the Inspector General 
The Office of Counsel to the Inspector General (OCIG) provides general legal services to 
OIG, rendering advice and opinions on HHS programs and operations and providing all 
legal support in OIG's internal operations. OCIG imposes program exclusions and civil 
monetary penalties on health care providers and litigates those actions within HHS. 
OCIG also represents OIG in the global settlement of cases arising under the Civil False 
Claims Act, develops and monitors corporate integrity agreements, develops compliance 
program guidances, renders advisory opinions on OIG sanctions to the health care 
community, and issues fraud alerts and other industry guidance.  Report Template Update  = 04-30-05_rev.13 
  E X E C U T I V E   S U M M A R Y  

OBJECTIVE 
To (1) identify the standards used by selected States to enroll Medicaid 
durable medical equipment (DME) providers, (2) determine the extent 
to which States verify that providers meet these standards, and 
(3) determine the extent to which States reenroll Medicaid DME 
providers. 
BACKGROUND 
The Office of Inspector General has previously identified concerns about 
fraudulent DME providers in the Medicare program. Similarly, the 
Government Accountability Office has also determined that 
vulnerabilities exist for ensuring the integrity of Medicaid providers.  
Provider enrollment standards represent one mechanism States can use 
to protect the integrity of their Medicaid DME programs. 
States are mandated to provide certain basic services to recipients of 
Medicaid home health services.  These include medical supplies, 
equipment, and appliances, which are often referred to as DME. States 
enroll providers to supply DME to Medicaid beneficiaries, and assign 
providers identification numbers entitling them to receive 
reimbursements under the States Medicaid program. 
Each State sets its own standards (defined in this report as any 
safeguards, guidelines, requirements, or practices) for the enrollment of 
Medicaid DME providers.  In addition, States may verify whether 
providers meet standards at initial enrollment, and may also review 
providers after enrollment, to determine whether providers continue to 
adhere to State standards.  One method of verifying whether a DME 
provider meets State standards is to conduct site visits of the providers 
location. 
Unlike Medicaid, Medicare has provider enrollment standards that are 
uniform across all States (except licensure requirements that vary from 
State to State). Compliance with most of these standards is verified by 
the National Supplier Clearinghouse (NSC) through site visits, while 
compliance with other standards is verified when the application is 
reviewed.  In addition to initial enrollment, Medicare also requires 
providers to reenroll every 3 years, during which time providers must 
certify they meet and will continue to meet Medicare standards.   
There are planned changes for DME provider enrollment in the 
Medicare program. In August 2006, CMS issued a final rule requiring 
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DME suppliers to go through an accreditation process. This process will 
utilize approved quality standards that DME suppliers must meet to 
participate in and bill the Medicare program.  Until these changes are 
fully implemented, NSC will continue with its enrollment 
responsibilities, which include conducting site visits and reenrolling 
DME providers. 
Providers may enroll in both the Medicare and Medicaid programs. If 
providers are enrolled in both programs, they are subject to both the 
Medicare standards as well as State provider enrollment standards.  
There are no estimates currently available for the number of providers 
dually enrolled.  
To address the three objectives of our evaluation, we collected data from 
14 States and the District of Columbia (referred to as 15 States 
throughout the report) using e-mail and telephone surveys.  We also 
examined States provider enrollment applications and written 
documentation about State standards to conduct a selective review of 
State-reported information.  Our data collection was completed during 
September and October 2005.   
FINDINGS 
States that we reviewed employed a variety of standards for DME 
provider enrollment. All 15 States in our evaluation reported various 
DME provider enrollment standards.  The goal of some of these 
standards, such as providers posting a sign and hours of operation, help 
ensure that an appropriate physical facility is being operated.  In 
addition, standards include licensure of providers and obtaining surety 
bonds. One State imposed a moratorium for enrollment of new DME 
providers.  
Seven of the fifteen States required providers to enroll as Medicare 
DME providers, which subjects all Medicaid providers in these seven 
States to Medicare standards. The eight remaining States did not 
require providers to be enrolled in the Medicare DME program. For 
these eight States, data regarding how many Medicaid DME providers 
choose to enroll as Medicare DME providers (and, therefore would be 
subject to Medicare standards) are not available.  
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EE XX EE CC UU TT II VV EE    SS UU MM MM AA RR YY
Most States that we reviewed were not routinely verifying whether 
providers met all State DME provider enrollment standards. While 
the States in our review requested information from providers during 
the enrollment process, most of these States were not routinely 
verifying all of the information submitted by providers. For example, 
while all 15 States requested that applicants disclose their criminal 
history, only 2 States routinely conducted criminal background checks 
at enrollment. Florida and New York were the only States in our review 
that verified whether providers met all of their reported standards. 
Seven of the fifteen States did not conduct routine site visits at 
enrollment; however, four of these seven States did require Medicare 
enrollment as a condition of Medicaid enrollment. By requiring 
Medicare enrollment, applicants should receive site visits by NSC in 
order to enroll in the Medicare program. The remaining three States 
neither performed routine site visits to verify enrollment information 
nor required Medicare DME participation as a condition of enrollment. 
Four of the fifteen States routinely reenrolled DME providers; two 
additional States reported recent initiatives to reenroll providers. 
For the four States that routinely reenrolled providers, the timeframe 
for reenrollment varied from 2 to approximately every 5 years. One of 
the 2 States that reported recent reenrollment initiatives, California, 
reported that 646 of its 1,420 DME providers voluntarily chose to leave 
the program during 1999 through 2004. The other State, New Jersey, 
was reenrolling all providers for the first time; this process is expected 
to continue during 2006. 
Nine States did not conduct Medicaid reenrollment. However, five of 
these nine States did require that the provider be enrolled in the 
Medicare program. For Medicare reenrollment, providers must certify 
every 3 years that they meet Medicare standards and should receive site 
visits as part of the Medicare reenrollment process. In contrast, the 
remaining four States neither routinely reenrolled DME providers nor 
required that providers be enrolled in Medicare. 
CONCLUSION 
Our review determined that the 15 States reviewed employed a variety 
of provider enrollment standards to protect their Medicaid DME 
programs. Some of these standards, such as providers posting a sign 
and hours of operation, help ensure that an appropriate physical facility 
is being operated. Also, standards include licensure of providers and 
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E X E C U T I V E   S U M M A R Y

obtaining surety bonds. In addition, seven of the States that we 
reviewed also required Medicaid providers to enroll as providers in the 
Medicare program, which subjects Medicaid providers in these States to 
Medicare standards.  
Despite the presence of these standards, we determined that most of the 
15 States were not verifying whether providers met all provider 
enrollment standards, and that 7 of the 15 States were not conducting 
routine site visits at initial enrollment.  In addition, only 6 of the  
15 States reported that they either routinely reenrolled providers, or 
had recent initiatives to reenroll providers.   
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  T A B L E   O F   C O N T E N T S  

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i

I N T RO DUC T IO N  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  1

F I N D IN G S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  6

State Medicaid standards for DMEprovider enrollment  . . . . . . . .  6

Verificationof DME provider enrollment standards  . . . . . . . . . . .  7

Reenrollment of Medicaid DME providers. . . . . . . . . . . . . . . . . . . .  9

CONC LUSION  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  11

E N D NO T ES  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  12

APPENDIXES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  15

A:	  Medicare Standards  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  15

B:	  Categories and Definitions of State Standards  . . . . . . . . . . . .  19

C:	  Medicaid Standards Implemented by the 15 States. . . . . . . . .  21

D: 	Effect of Requirements to Enroll in Medicare on State 

   Standards  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  24

 . 
A C K NO WL E D G M E N T S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  26
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  I N T R O D U C T I O N  

OBJECTIVE 
To (1) identify the standards used by selected States to enroll Medicaid 
durable medical equipment (DME) providers, (2) determine the extent 
to which States verify that providers meet these standards, and 
(3) determine the extent to which States reenroll Medicaid DME 
providers. 
BACKGROUND 
The Office of Inspector General (OIG) has previously highlighted 
concerns about fraudulent DME providers in the Medicare program.1 
Similarly, the Government Accountability Office (GAO) has also 
determined that vulnerabilities exist for ensuring the integrity of 
Medicaid providers.2  A 2004 GAO report advised that preventing high 
risk providers, intent on fraudulently billing, from entering the 
Medicaid program is more efficient than attempting recovery of 
payments once they have been made.3  Provider enrollment standards 
represent one mechanism States can use to protect the integrity of their 
Medicaid DME programs. 
Durable Medical Equipment, Supplies, and Appliances  
States are mandated to provide certain basic services to recipients of 
Medicaid home health services.  These include the provision of medical 
supplies, equipment, and appliances,4 which are often referred to as 
DME. DME includes many different types of devices, such as 
wheelchairs, oxygen equipment, diabetic equipment, and canes. Federal 
regulations do not define DME for Medicaid, and each State decides 
what equipment to cover.  In addition, States may offer other devices, 
such as prosthetics, at their discretion.5  The Centers for Medicare & 
Medicaid Services (CMS) does not estimate expenditures specifically for 
Medicaid DME. 
Enrollment of Medicaid DME Providers 
Federal Requirements. At enrollment, Medicaid providers are required to 
disclose information regarding ownership and control of the DME 
business.6  In addition, providers must disclose whether individuals 
with ownership and control of, or management or other similar 
responsibilities for, the DME provider have been convicted of any 
criminal offense relating to the Medicare or Medicaid program.7 
Providers must also disclose if an individual with ownership or 
management responsibilities has had civil or monetary penalties 
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imposed relating to health care programs, and if such a person has been 
excluded from participation in Medicare or any State health care 
program.8  States must notify the Department of Health and Human 
Services (HHS) Inspector General of any disclosures made by a 
provider,9 as well as any action taken regarding the providers 
participation in the program.10  To ensure that they are not enrolling 
excluded individuals, States may check any provider seeking Medicaid 
enrollment against OIGs List of Excluded Individuals/Entities, 
available on the Internet. 
State Standards for Provider Enrollment. Each State sets its own  
standards for enrollment of Medicaid providers. Pursuant to 
42 CFR  431.51(b)(1), Medicaid services may only be provided by 
individuals or organizations that are qualified to provide a specified 
service.  States differ in their definition of a qualified provider.  State 
standards for Medicaid DME provider enrollment can range from 
requiring that the DME business location be accessible during 
reasonable business hours to requiring that Medicaid applicants enroll 
in the Medicare program as a condition of Medicaid enrollment.  In 
addition, States may verify whether providers meet standards at initial 
enrollment, and may also review providers after enrollment to 
determine whether providers continue to adhere to State standards.  
One method of verifying whether a DME provider meets State 
standards is to conduct site visits of the providers location.   
After a State approves an applicant to provide DME, the State assigns a 
Medicaid DME identification number entitling the provider to receive 
reimbursements under the States Medicaid program.  
Medicare DME Provider Standards  
Unlike Medicaid, Medicare provider enrollment requirements are 
standardized across all States (except licensure requirements that vary 
from State to State).  CMS contracts out the enrollment process to the 
National Supplier Clearinghouse (NSC).  At the time our review was 
conducted, Medicare DME providers were required to meet 
21 standards in order to obtain billing privileges.11  These standards 
include accessibility during reasonable business hours, liability 
insurance, and compliance with Federal and State licensure 
requirements.12  (See Appendix A for the complete listing of Medicare 
standards.) Compliance with most of these standards is verified by 
NSC through site visits.  OIG has previously found that the site visit 
process improved supplier compliance with Medicare standards.13 
Other types of standards are verified when the application is reviewed. 
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For example, the analyst reviewing the provider application will verify 
liability insurance through the insurance company underwriting the 
policy. 
In addition to initial enrollment, Medicare also requires providers to 
renew their application every 3 years, which is referred to as 
reenrollment.  Medicare DME providers must certify in their 
applications that they meet and will continue to meet all Medicare 
standards. NSC conducts site visits of the providers during 
reenrollment to verify continued compliance with the standards.   
There are planned changes for provider enrollment in the Medicare 
program. Section 302(a)(1) of the Medicare Prescription Drug, 
Improvement, and Modernization Act of 2003 requires the Medicare 
program to develop and implement quality standards for DME 
suppliers.14  Pursuant to a final rule published by CMS, all suppliers 
are required to meet quality standards included as part of the 
accreditation process to participate in and bill the Medicare program.15 
According to the final rule, CMS will phase in the accreditation process 
of DME suppliers.16  Until these changes are fully implemented, NSC 
will continue with its enrollment responsibilities, which include 
conducting site visits and reenrolling DME providers.  
Vulnerabilities in Medicare Enrollment 
Both OIG and GAO have identified vulnerabilities in the Medicare 
enrollment process.  In a 1997 report, OIG recommended numerous 
improvements to the Medicare enrollment process, including surety 
bond requirements and site visits of DME suppliers.17 In a follow-up 
report in 2001, OIG determined that Medicares expansion of oversight 
activities improved compliance with Medicare standards, but that more 
measures were needed to receive a higher compliance rate.18 In 2005, 
GAO determined that CMS should improve DME supplier compliance 
with Medicare standards.19  Among its recommendations, GAO stated 
that CMS should both strengthen its procedures to verify that suppliers 
were meeting the Medicare standards, as well as enhance the standards 
themselves. 
Dual Enrollment and the National Provider Identifier 
Any Medicaid provider who voluntarily enrolls in the Medicare 
program, or is required to enroll in Medicare by a State agency as a 
condition of Medicaid enrollment, is required to meet Medicare 
standards. When the new quality standards and the accreditation 
process are implemented, such providers will fall under these new 
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I N T R O D U C T I O N  
requirements.  CMS does not track the number of DME providers 
exclusively enrolled in the Medicaid program, nor those who are dually 
enrolled in both Medicare and Medicaid.  One of the obstacles in 
determining these figures is the absence of a unique, national 
identification number for providers. The Health Insurance Portability 
and Accountability Act of 1996 required the Secretary of HHS to 
implement unique identifiers for all health care providers. In 
January 2004, the National Provider Identifier (NPI) was established by 
final rule.  All Medicare and Medicaid DME providers that are covered 
health care providers, as defined by the rule, are required to use an NPI 
by May 2007.20  In the future, the NPI may provide data to determine 
which providers are dually enrolled in both Medicare and Medicaid.   
METHODOLOGY 
Scope 
The purpose of our evaluation was to provide a report that broadly 
outlined the standards used by selected States for their DME provider 
enrollment programs; determine the extent to which States verify that 
providers meet these standards; and determine the extent to which 
these States reenroll Medicaid DME providers. We examined 
reenrollment because the Medicare program uses reenrollment to verify 
continued compliance with the Medicare standards; we sought to 
determine if States similarly had reenrollment processes in place. 
Reenrollment is important as it provides States the opportunity to 
verify continued compliance with their standards.   
Our evaluation was designed to provide descriptive information about 
State-implemented standards, and we did not assess the effectiveness of 
the standards.  Also, we did not determine whether States were meeting 
the specific Federal requirements pertaining to disclosure of ownership 
and criminal history disclosure.21 
For this evaluation, we defined DME provider enrollment standards as 
any safeguards, guidelines, requirements, or practices that State 
provider enrollment programs use to protect the integrity of their 
Medicaid DME programs.  We included 14 States and the District of 
Columbia in our evaluation of DME provider enrollment standards 
(referred to as 15 States throughout this report). The 15 States are 
listed in Appendix C.  These 15 States represent a mix of States with 
different population sizes; are geographically diverse; and include 
States participating in the Medi-Medi program.22  While results from 
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this report cannot be projected to other States, our selection process 
ensured that a diverse selection of States were included to provide 
insight on DME provider enrollment practices. 
Data Collection  
To meet our three objectives, we collected data through e-mail and 
telephone surveys.  The surveys included questions addressing the 
following areas: 
o	 DME provider enrollment standards that must be met for an   
applicant to be enrolled as a Medicaid provider (e.g., licensure and  
accessibility during reasonable business hours), 
o	 The extent to which States routinely verify that providers meet  
State standards, 
o	 The extent to which States routinely conduct site visits as part of  
their verification processes, and 
o	 Whether States reenroll Medicaid DME providers, what activities   
occur during reenrollment, and how often reenrollment occurs. 
As a part of the e-mail survey, we also requested that States submit 
provider enrollment application packages as well as written documents 
that supported their reported standards.  We used this information to 
conduct a document review.  This was a selective review of the general 
accuracy of State-reported information.  If there were discrepancies 
between State documentation and State responses, we worked with the 
States to resolve these differences. 
The data collection was completed during September and October 2005.  
Therefore, unless otherwise noted, the standards included in this report 
reflect standards in place during that timeframe.  If State responses 
were incomplete, we continued to follow up with States throughout the 
fall of 2005. 
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspections issued by the Presidents Council on Integrity and 
Efficiency and the Executive Council on Integrity and Efficiency. 
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  F I N D I N G S

States that we reviewed employed a variety of 
All 15 States reported various DME 
standards for DME provider enrollment  provider enrollment standards.  
Table 1 provides the standards  
that 15 States reported had been implemented specifically for their 
Medicaid programs.  For the definition of each standard listed below, 
refer to Appendix B.  For a State-by-State comparison of Medicaid 
standards, refer to Appendix C. 
Table 1: State Enrollment Standards Reported by 15 States 
September  October 2005 
States With 
Percentage Who Have 
Standard  Implemented 
the Standard 
Standards 
Criminal History Disclosure  15/15  100% 
Ownership Disclosure  15/15  100% 
P.O. Box Prohibition  14/15  93% 
Primary Phone Number    12/15  80% 
Licensure   8/15  53% 
Records Storage  8/15  53% 
Signage and Hours Posted  8/15  53% 
Accessibility During 
Reasonable Business  8/15  53% 
Hours 
Medicare Enrollment 
7/15  47% 
Required 
Inventory  6/15  40% 
Liability Insurance  3/15  20% 
Surety Bonds  1/15  7% 
Moratorium*   1/15  7% 
*A moratorium for provider enrollment is a safeguard that prevents the entry of new 
providers into the program.  This differs from the other standards in Table 1, which 
are standards that providers must meet.  
The standards in Table 1 provide safeguards for DME programs in 
different ways. For example, standards such as the P.O. Box 
Prohibition and the requirement to post a sign and hours of operation 
help to ensure that an appropriate physical facility is being operated.  
Additionally, in eight States, providers must comply with State 
licensure requirements.  Licensure is often required to make certain 
that guidelines or regulations are being followed to ensure that 
providers are offering services in a correct and safe manner to 
beneficiaries.  The type of licensure that is required varies from State to 
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F I N D I N G S  

State; some States only require a sales tax permit, while others require 
a professional license, such as a DME or a hearing aid license. 
Two other standards included in Table 1 illustrate additional ways 
States protect their DME programs from fraud and abuse.  Florida 
requires providers to obtain a surety bond as a condition of participation 
in the Medicaid program.  Surety bonds help indemnify the State 
against fraud by requiring enrolling providers to post a bond that can be 
later used by the State to recover any losses incurred by the provider. 
Floridas surety bond amount was $50,000.  Two other States had taken 
steps to develop a surety bond requirement, but due to opposition from 
the provider community, these initiatives have not been implemented. 
In another example of State safeguards, California imposed a 
moratorium for new DME providers, an initiative that began in 1999.  
Through the moratorium, California stopped issuing new Medicaid 
DME provider numbers, with a few exceptions (e.g., a provider who has 
restructured ownership).   
As noted in Table 1, seven States required providers to enroll as 
Medicare DME providers.  Therefore, Medicaid providers in these States 
were subject to Medicare standards, which include all of the State 
standards included in Table 1, except surety bonds and moratorium.23 
For the seven States with the requirement to enroll in Medicare, Table 
1 includes only those standards that States reported they had instituted 
specifically for their Medicaid program. If a State did not report having 
a particular standard that is indirectly addressed through the 
requirement to enroll in Medicare, we did not classify the State as 
having the standard in Table 1.  However, Appendix D provides analysis 
of the effect of the Medicare requirement on the total number of 
standards. 
States can verify whether 
Most States that we reviewed were not routinely 
providers meet some standards 
verifying whether providers met all State DME 
through site visits, while other 
provider enrollment standards 
standards can be verified when 
the application is reviewed.  For example, a States review process of 
providers applications can include verifying the legitimacy of licenses 
online via State databases or Web sites, and verifying primary phone 
numbers via Web searches or calling the number directly. 
While the States in our review requested information from providers 
during the enrollment process, we found that gaps exist between 
standards and State verification processes.  For example, while all 15 
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States requested that applicants disclose their criminal history, only 2 
States routinely conducted criminal background checks at enrollment. 
Florida and New York were the only States in our review that verified 
all of their reported standards.     
Table 2 outlines State standards, the number of States verifying 
providers met each standard, and the percentage of States verifying 
whether providers met the standards.  Appendix B provides a definition 
of each standard and verification process listed below.  Appendix C 
details totals for each State.   
Table 2:  State-Implemented Standards vs. Verification Process 
15 Reviewed States* 
 September - October 2005 
Type of Standard*  Number of  Number of  Percentage That 
States With  States That  Verified the 
Standards  Verified the  Standard 
Standard 
Criminal History 
2  13% 
Disclosure  15 
Ownership 
15  14**  93% 
Disclosure  
P.O. Box Prohibition  14  10  71% 
Primary Phone 
12  5  42% 
Number 
Licensure  8  7  88% 
Records Storage  8  5  63% 
Signage and Posted 
8  8  100% 
Hours 
Accessibility During 
Reasonable  8  7  88% 
Business Hours 
Medicare 
7  7  100% 
Enrollment Required 
Inventory  6  6  100% 
Liability Insurance  3  2  67% 
Surety Bonds  1  1  100% 
*The safeguard of moratorium that was listed in Table 1 was not applicable to 
this table, because a moratorium stops issuance of DME numbers to new 
providers. 
**We define verification of ownership disclosure as States checking owners 
against OIGs List of Excluded Individuals/Entities. 
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F I N D I N G S  
Seven of the fifteen States did not routinely conduct site visits at enrollment 
to verify whether providers were meeting State standards 
Site visits can determine whether certain information provided during 
enrollment is accurate and the provider is operating a legitimate DME 
business. Site visits are often the only method available to verify 
specific standards. For example, a site visit enables a State to 
determine whether a providers business is accessible during reasonable 
business hours.  Other standards that can be verified through site visits 
include: records storage, inventory, and posted sign and hours of 
operation. 
Seven of the fifteen States did not conduct routine site visits as part of 
their provider enrollment process. However, four of these States did 
require Medicare enrollment as a condition of Medicaid enrollment. By 
requiring Medicare enrollment, applicants should receive site visits by 
NSC in order to enroll in the Medicare program.  The remaining three 
States neither performed routine site visits to verify enrollment 
information nor required Medicare DME participation as a condition of 
enrollment.  Without State-conducted site visits or enrollment in 
Medicare, Medicaid-only providers were unlikely to have their DME 
business reviewed through routine site visits at enrollment. 
Eight of the fifteen States routinely conducted site visits at 
enrollment.24  Four of the eight States conducting site visits reported 
that site visits were the most effective component of their provider 
enrollment standards and verification processes. 
Four of the fifteen States routinely reenrolled  Connecticut, Florida, 
DME providers; two additional States reported  Georgia, and Illinois 
routinely reenroll DME 
recent initiatives to reenroll providers 
providers, but 
reenrollment in these 
States does not include routine site visits.  An example of the types of 
activities that occur at reenrollment is illustrated by the State of 
Florida.  In that State, the provider must verify basic demographic 
information, such as name, tax identification number, address, 
telephone number, and whether or not a change of ownership has 
occurred.  Further, providers are required to sign a new provider 
agreement at reenrollment.  The timeframes the four States used for 
reenrollment varied as specified below: 
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F	 I N D I N G S  
o	 Every 2 years (Connecticut and Georgia), 
o	 Every 5 years (Illinois), and 
o	 Once every fiscal agent contract, approximately every 5 years 
(Florida). 
Although New Jersey and California did not report conducting 
reenrollment on a routine basis, both States reported recent initiatives 
to reenroll providers.  New Jersey reported that they were reenrolling 
all providers for the first time; this process is expected to continue 
during 2006.  California recently completed a 5-year effort to reenroll all 
DME providers. From 1999 through 2004, 646 of the 1,420 DME 
providers voluntarily chose to leave the program.25 In addition to 
reenrollment, the State restricted entry of new DME providers into 
California Medicaid, imposing a moratorium for new DME providers 
beginning in 1999. 
Nine States did not conduct Medicaid reenrollment.  However, five of 
these nine States did require that the provider be enrolled in the 
Medicare program.  For Medicare reenrollment, providers must certify 
every 3 years that they meet Medicare standards and should receive site 
visits as a part of the Medicare reenrollment process.  In contrast, the 
remaining four States neither routinely reenrolled DME providers nor 
required that providers be enrolled in Medicare. Therefore, providers in 
these States were unlikely to be routinely reviewed for continued 
compliance with provider enrollment standards, unless they had 
voluntarily enrolled in the Medicare program.  
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  C O N C L U S I O N  

Our review determined that the 15 States reviewed employed a variety 
of provider enrollment standards to protect their Medicaid DME 
programs. Some of these standards, such as providers posting a sign 
and hours of operation, help ensure that an appropriate physical facility 
is being operated.  Also, standards include licensure of providers and 
obtaining surety bonds. In addition, seven of the States that we 
reviewed also required Medicaid providers to enroll as providers in the 
Medicare program, which subjects Medicaid providers in these States to 
Medicare standards.  
Despite the presence of these standards, we determined that most of the 
15 States were not verifying whether providers met all provider 
enrollment standards, and that 7 of the 15 States were not conducting 
routine site visits at initial enrollment.  In addition, only 6 of the  
15 States reported that they either routinely reenrolled providers, or 
had recent initiatives to reenroll providers.   
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  E N D N O T E S  

1 Medical Equipment Suppliers:  Assuring Legitimacy (OEI-04-96-
00240, December 1997). 
2 Medicaid: HCFA and States Could Work Together to Better Ensure 
the Integrity of Providers (GAO/T-HEHS-00-159, July 18, 2000), and 
Medicaid Program Integrity:  State and Federal Efforts to Prevent and 
Detect Improper Payments (GAO-04-707, July 16, 2004). 
3 Opportunities for Congressional Oversight and Improved Use of 
Taxpayer Funds:  Budgetary Implications of Selected GAO Work (GAO-
04-649, May 7, 2004). 
4 42 CFR  440.70(b)(3) and 42 CFR  441.15(a)(3). 
5 CMS details information about State Medicaid programs including 
optional services offered by States in Medicaid At-a-Glance 2005. 
Available online at http://www.cms.hhs.gov/MedicaidGenInfo/ 
Downloads/ MedicaidAtAGlance2005.pdf. Accessed February 8, 2006. 
6 42 CFR  455.104. 
7 42 CFR  455.106. 
8 42 CFR  1002.3(a). 
9 42 CFR  455.106(b)(1) and 42 CFR  1002.3(b)(1).  
10 42 CFR  455.106(b)(2) and 42 CFR  1002.3(b)(3).   
11 CMS published a final rule on August 18, 2006, at 71 FR 48354, 
entitled Medicare Program; Inpatient Rehabilitation Facility Prospective 
Payment System for Federal Fiscal Year 2007; Certain Provisions 
Concerning Competitive Acquisition for Durable Medical Equipment, 
Prosthetics, Orthotics, and Supplies (DMEPOS); Accreditation of 
DMEPOS Suppliers.  In part, this final rule amends the durable medical 
equipment certification standards regulation at 42 CFR  424.57(c) by 
OEI-04-05-00180  MEDICAID PROVIDER ENROLLMENT STANDARDS: MEDICAL EQUIPMENT PROVIDERS  12  Report Template Update  = 04-30-05_rev.13 
adding four additional standards.  See Appendix A for the standards in 
place at the time of evaluation, as well as the text of the new standards. 
12 42 CFR  424.57(c). 
13 Medical Equipment Suppliers:  Compliance with Medicare 
Standards (OEI-04-99-00670, August 2001). 
14 Pub. L. 108-173, adding section 1834(a)(20) of the Social Security Act. 
15 See 42 CFR  424.57(c)(24) (as added by the Medicare program final 
rule at 71 FR 48354 (August 18, 2006)). CMS has posted quality 
standards for suppliers of DMEPOS on its Web site at 
http://www.cms.hhs.gov/CompetitiveAcqforDMEPOS/downloads/CMS_ 
DMEPOS_Quality_ Standards_081406.pdf. 
16 See the preamble to the Medicare program final rule at 71 FR at 
48392. 
17 Medical Equipment Suppliers:  Assuring Legitimacy (OEI-04-96-
00240, December 1997). 
18 Medical Equipment Suppliers:  Compliance with Medicare 
Standards (OEI-04-99-00670, August 2001). 
19 Medicare:  More Effective Screening and Stronger Enrollment 
Standards Needed for Medical Equipment Suppliers (GAO-05-656, 
September 22, 2005). 
20 45 CFR  162.404. 
21 Our study included general survey questions to States, including 
whether States obtain ownership disclosure from providers, and whether 
States obtain providers and business owners criminal history 
disclosures.  However, we did not determine whether States fully met the 
specific Federal requirements for ownership disclosure (42 CFR    
 455.104) and criminal history disclosure (42 CFR  455.106). 
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22 Medi-Medi is the Medicare-Medicaid match program in which claims 
data are analyzed to determine vulnerabilities in both programs.  By 
analyzing data from both programs together, patterns may be detected 
that may not be evident when billings for either program are viewed in 
isolation.     
23 The eight remaining States did not require providers to be enrolled 
in the Medicare DME program.  For these States, data regarding how 
many Medicaid DME providers choose to enroll as Medicare DME 
providers (and, therefore would be subject to Medicare standards) were 
not available. 
24 The eight States that routinely conducted site visits at enrollment 
were California, Connecticut, Florida, Georgia, Illinois, Nevada, New 
Jersey, and New York.  Connecticut conducted site visits only for 
Medicaid DME providers that offered services that were not covered by 
Medicare (e.g., hearing aids), and subsequently were not enrolled in the 
Medicare program.  If a provider was enrolled in Medicare, Connecticut 
verified the Medicare supplier number and relied on Medicares site visit 
verification. 
25 California estimated a savings of approximately $193 million per 
year from this reenrollment project. The State based this estimate on the 
average monthly billing for this provider type, which is $25,000 per 
month. OIG did not independently assess this estimate.   
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 A P P E N D I X   A  
Medicare Standards 
This appendix contains both the standards in place at the time of our 
review as well as standards recently added by CMS. 
The following are the 21 Medicare standards as outlined in 
42 CFR  424.57(c), at the time of our review. The supplier: 
(1) Operates its business and furnishes Medicare-covered items in 
compliance with all applicable Federal and State licensure and 
regulatory requirements; 
(2) Has not made, or caused to be made, any false statement or 
misrepresentation of a material fact on its application for billing 
privileges.  (The supplier must provide complete and accurate 
information in response to questions on its application for billing 
privileges. The supplier must report to CMS any changes in 
information supplied on the application within 30 days of the change.); 
(3) Must have the application for billing privileges signed by an 
individual whose signature binds a supplier; 
(4) Fills orders, fabricates, or fits items from its own inventory or by 
contracting with other companies for the purchase of items necessary to 
fill the order.  If it does, it must provide, upon request, copies of 
contracts or other documentation showing compliance with this 
standard. A supplier may not contract with any entity that is currently 
excluded from the Medicare program, any State health care programs, 
or from any other Federal Government Executive Branch procurement 
or nonprocurement program or activity; 
(5) Advises beneficiaries that they may either rent or purchase 
inexpensive or routinely purchased durable medical equipment, and of 
the purchase option for capped rental durable medical equipment, as 
defined in  414.220(a) of this subchapter.  (The supplier must provide, 
upon request, documentation that it has provided beneficiaries with this 
information, in the form of copies of letters, logs, or signed notices.); 
(6) Honors all warranties expressed and implied under applicable State 
law. A supplier must not charge the beneficiary or the Medicare 
program for the repair or replacement of Medicare covered items or for 
services covered under warranty. This standard applies to all 
purchased and rented items, including capped rental items, as described 
in  414.229 of this subchapter. The supplier must provide, upon  
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A P P E N D I X   A  
request, documentation that it has provided beneficiaries with 
information about Medicare covered items covered under warranty, in 
the form of copies of letters, logs, or signed notices; 
(7) Maintains a physical facility on an appropriate site.  The physical 
facility must contain space for storing business records including the 
supplier's delivery, maintenance, and beneficiary communication 
records.  For purposes of this standard, a post office box or commercial 
mailbox is not considered a physical facility.  In the case of a multi-site 
supplier, records may be maintained at a centralized location; 
(8) Permits CMS, or its agents to conduct on-site inspections to 
ascertain supplier compliance with the requirements of this section. 
The supplier location must be accessible during reasonable business 
hours to beneficiaries and to CMS, and must maintain a visible sign and 
posted hours of operation;  
(9) Maintains a primary business telephone listed under the name of 
the business locally or toll-free for beneficiaries.  The supplier must 
furnish information to beneficiaries at the time of delivery of items on 
how the beneficiary can contact the supplier by telephone.  The 
exclusive use of a beeper number, answering service, pager, facsimile 
machine, car phone, or an answering machine may not be used as the 
primary business telephone for purposes of this regulation; 
(10) Has a comprehensive liability insurance policy in the amount of at 
least $300,000 that covers both the supplier's place of business and all 
customers and employees of the supplier.  In the case of a supplier that 
manufactures its own items, this insurance must also cover product 
liability and completed operations. Failure to maintain required 
insurance at all times will result in revocation of the supplier's billing 
privileges retroactive to the date the insurance lapsed;  
(11) Must agree not to contact a beneficiary by telephone when 
supplying a Medicare-covered item unless one of the following applies: 
(i) The individual has given written permission to the supplier to 
contact them by telephone concerning the furnishing of a 
Medicare-covered item that is to be rented or purchased. 
(ii) The supplier has furnished a Medicare-covered item to the 
individual and the supplier is contacting the individual to 
coordinate the delivery of the item. 
(iii) If the contact concerns the furnishing of a Medicare-covered 
item other than a covered item already furnished to the individual, 
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A P P E N D I X   A  
the supplier has furnished at least one covered item to the 
individual during the 15-month period preceding the date on 
which the supplier makes such contact. 
(12) Must be responsible for the delivery of Medicare covered items to 
beneficiaries and maintain proof of delivery.  (The supplier must 
document that it or another qualified party has at an appropriate time, 
provided beneficiaries with necessary information and instructions on 
how to use Medicare-covered items safely and effectively); 
(13) Must answer questions and respond to complaints a beneficiary 
has about the Medicare-covered item that was sold or rented. A 
supplier must refer beneficiaries with Medicare questions to the 
appropriate carrier.  A supplier must maintain documentation of 
contacts with beneficiaries regarding complaints or questions; 
(14) Must maintain and replace at no charge or repair directly, or 
through a service contract with another company, Medicare-covered 
items it has rented to beneficiaries. The item must function as required 
and intended after being repaired or replaced; 
(15) Must accept returns from beneficiaries of substandard (less than 
full quality for the particular item or unsuitable items, inappropriate for 
the beneficiary at the time it was fitted and rented or sold); 
(16) Must disclose these supplier standards to each beneficiary to whom 
it supplies a Medicare-covered item; 
(17) Must comply with the disclosure provisions in  420.206 of this 
subchapter; 
(18) Must not convey or reassign a supplier number; 
(19) Must have a complaint resolution protocol to address beneficiary 
complaints that relate to supplier standards in paragraph (c) of this 
section and keep written complaints, related correspondence and any 
notes of actions taken in response to written and oral complaints.  
Failure to maintain such information may be considered evidence that 
supplier standards have not been met. (This information must be kept 
at its physical facility and made available to CMS, upon request.); 
(20) Must maintain the following information on all written and oral 
beneficiary complaints, including telephone complaints, it receives: 
(i) The name, address, telephone number, and health insurance 
claim number of the beneficiary. 
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A P P E N D I X   A

(ii) A summary of the complaint; the date it was received; the 
name of the person receiving the complaint, and a summary of 
actions taken to resolve the complaint. 
(iii) If an investigation was not conducted, the name of the person 
making the decision and the reason for the decision. 
(21)  Provides to CMS, upon request, any information required by the 
Medicare statute and implementing regulations. 
The additional standards recently added by CMS, see footnote 11, are: 
(22) All suppliers of DMEPOS and other items and services must be 
accredited by a CMS-approved accreditation organization in order to 
receive and retain a supplier billing number.  The accreditation must 
indicate the specific products and services, for which the supplier is 
accredited in order for the supplier to receive payment for those specific 
products and services. 
(23) All DMEPOS suppliers must notify their accreditation 
organization when a new DMEPOS location is opened.  The 
accreditation organization may accredit the new supplier location for 
three months after it is operational without requiring a new site visit. 
(24) All DMEPOS supplier locations, whether owned or subcontracted, 
must meet the DMEPOS quality standards and be separately accredited 
in order to bill Medicare. An accredited supplier may be denied 
enrollment or their enrollment may be revoked, if CMS determines that 
they are not in compliance with the DMEPOS quality standards. 
(25) All DMEPOS suppliers must disclose upon enrollment all products 
and services, including the addition of new product lines for which they 
are seeking accreditation.  If a new product line is added after 
enrollment, the DMEPOS supplier will be responsible for notifying the 
accrediting body of the new product so that the DMEPOS supplier can 
be re-surveyed and accredited for these new products. 
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 A P P E N D I X   B  
This appendix consists of categories and definitions of State provider enrollment 
standards we developed to analyze State standards for DME providers. 
Categories and Definitions for State Provider Enrollment Standards 
Accessibility During Reasonable Business Hours:  Providers location 
must be accessible during reasonable business hours to beneficiaries 
and to the State. 
Accessibility Verified:  State verifies that providers are accessible 
during reasonable business hours. 
Criminal History Disclosure:  Criminal history must be disclosed by 
providers.  
Criminal History Verified:  State conducts criminal background checks 
of providers. 
Inventory: State requires providers to fill DME orders from their own 
inventory or have contracts in place to fill the order.   
Inventory Verified: State verifies that providers fill DME orders from 
their own inventory or have contracts in place to fill the order. 
Liability Insurance:  State requires providers to have liability 
insurance. 
Liability Insurance Verified:  State verifies that providers have liability 
insurance. 
Licensure: State requires some or all providers to hold a license  
(e.g., sales tax permit or professional license). 
Licensure Verified:  State verifies that providers hold appropriate 
licensure (e.g., sales tax permit or professional license).   
Medicare Enrollment Required: State requires Medicaid DME 
providers to be enrolled in the Medicare program in order to be enrolled 
in the State Medicaid DME program. Any provider enrolled in 
Medicare is required to meet Medicare standards (see Appendix A). 
States Requiring Medicare that Verify:  For State with the Medicare 
enrollment requirement, State verifies whether the provider is enrolled 
in Medicare. 
Moratorium: State has stopped issuing DME provider numbers. 
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A P P E N D I X   B  
Ownership Disclosure: Provider must disclose who has business 
ownership and/or control of the DME business. 
Ownership Reviewed for Exclusions: State checks owners against OIGs 
List of Excluded Individuals/Entities. 
P.O. Box Prohibition:  State prohibits the providers from using a P.O. 
Box or commercial mailbox as their physical facility.  
P.O. Box Verified: State verifies that providers are not using a P.O. Box 
or commercial mailbox as their physical facility. 
Primary Phone Number: Provider must have a primary business 
telephone number. 
Primary Phone Number Verified:  State verifies the primary business 
phone number of DME provider applicants.   
Records Storage: Providers physical facility must contain space for 
storing records (including delivery, maintenance, and beneficiary 
communication records). 
Records Storage Verified: State verifies that providers physical facility 
contains space for storing records. 
Signage and Hours Posted: Providers are required to maintain a visible 
sign and posted hours of operation. 
Signage and Hours Posted Verified:  State verifies that providers are 
maintaining a visible sign and posted hours of operation. 
Surety Bonds:  Providers must post a surety bond prior to enrollment. 
Surety Bonds Verified: State verifies that providers meet the surety 
bond requirement. 
OEI-04-05-00180  MEDICAID PROVIDER ENROLLMENT STANDARDS: MEDICAL EQUIPMENT PROVIDERS  20  .. APPENDIX C
Table 1: Medicaid Standards Implemented by the 15 States as of October 2005
State Accessibilty Accessibility Criminal Criminal Inventory Inventory Liabilty Liabilty
During Verified History History Verified Insurance Insurance
Reasonable Disclosure Verified Verified
Business
Hours
CA X X X X X X X
CT X X X X X
DC X X
FL X X X X X X
GA X X
IL X X X X X
MN X
MT X
NV X X X X X
NJ X X X X X
NY X X X X X X
NC X
OH X
TX X
WY X
Total 8 7 15 2 6 6 3 2
Source: Analysis of State Medicaid DME standards compiled by OIG.
OEI.04.05.00180 MEDICAID PROVIDER ENROLLMENT STANDARDS: MEDICAL EQUIPMENT PROVIDERS
21 Ii-PPENDIX C
Table 1 (cont): Medicaid Standards Implemented by the 15 States as of October 2005
State Licensure Licensure Medicare States Moratorium Ownership Ownership Primary Primary
Verified Enrollment Requiring Disclosure Reviewed Phone Phone
Required Medicare for Number Number
that Exclusions Verified
Verify
CA X X X X X X X
CT X* X X X X X
DC X X X X X
FL X X X X X X
GA
X X X
IL X X X X X
MN X X X
MT
X X X
NV X X X X X X
NJ X X X X
NY X X X X X X
NC X X X X X X X
OH X X X X X X
TX** X X X X X
WY X X X X
Total 8 7 7 7 1 15 14 12 5
*For hearing aid dealers only.
**Although Texas does not have a licensure requirement for the purpose of DME provider enrollment, the Department of State Health Services
does license all wholesalers and manufacturers of DME, which may include some DME providers.
Source: Analysis of State Medicaid DME standards compiled by OIG.
OEI.04.05.00180 MEDICAID PROVIDER ENROLLMENT STANDARDS: MEDICAL EQUIPMENT PROVIDERS
22 APPENDIX C
Table 1 (cont): Medicaid Standards Implemented by the 15 States as of October 2005
State P.o. Box P.O. Box Records Records Signage Signage Surety Surety
Prohibition Verified Storage Storage and Hours and Hours Bonds Bonds
Verified Posted Posted Verified
Verified
CA X X X X X X
CT X X X X
DC X X X
FL X X X X X X X X
GA X X X X
IL X X X X X X
MN X X
MT X
NV X X X X X X
NJ X X X X
NY X X X X X X
NC X X
OH X X
TX X
WY
Total 14 10 8 5 8 8 1 1
Source: Analysis of State Medicaid DME standards compiled by OIG.
OEI.04.05.00180 MEDICAID PROVIDER ENROLLMENT STANDARDS: MEDICAL EQUIPMENT PROVIDERS
23 .. APPENDIX D
Seven States required providers to enroll as a Medicare DME provider in order to become Medicaid providers.
determine the extent to which States themselves had implemented
Although the purpose of  our inspection was to 
standards and whether States followed the imp  Ie  mentation ofthese standards with a State review of  providers to
determine if they were compliant, the requirement to enroll in Medicare does provide additional standards for State
Medicaid programs. The following table provides analysis of the effect of the Medicare requirement on the total
number of reviewed State-implemented standards. Please note the following about the information provided:
 Column A lists each standard. For the definition of each standard, refer to Appendix B.
 Column B provides the number of States that have implemented each standard exclusively through their own Medicaid
programs. This column does not include any States with the requirement to enroll in Medicare.
 Column C provides the number of States that have exclusively established each standard by requiring providers to enroll
in the Medicare program as a condition of Medicaid enrollment. States in this column do not review if providers have
met these standards, and instead rely upon the Medicare program for both the establishment of the standards and
the standards. We do not know the extent to which such States are
verifying and enforcing compliance with each of 
aware of  Medicare's verification or enforcement of  compliance with each of  the standards.
 Column D provides the number of States that have both implemented each standard specifically through their own
Medicaid programs, as well as through the requirement for Medicaid providers to enroll in Medicare.
 Columns B- D are mutually exclusively; States can only be included in one column.
States with each standard, by adding columns B-D.
 Column E provides the total number of 
OEI-04-05-00180 MEDICAID PROVIDER ENROLLMENT STANDARDS: MEDICAL EQUIPMENT PROVIDERS
24 ;.,PPENDIX D
Table i: Effect ofthe Requirement to Enroll in Medicare on State Standards*
September - October 2005
Column B: Column C: Column D: Column E:
Number of States Number of States Number of States with both Total Number of
CSotalunmdanr Ad: with State- Establishing Standards State-Implemented States with the
Implemented Exclusively Through Standards and the Standard
Medicare Requirement
Standards Only (B+C+D)
Medicare  Requirement 
Criminal History
Disclosure 8 0 7 15
Ownership
Disclosure 8 0 7 15
P.O. Box
Prohibition 8 1 6 15
Primary Phone
Number 8 3 4 15
Licensure 8 NA** NA** 8
Records Storage 5 4 3 12
Signage and
Hours Posted 5 4 3 12
Accessibility
During
Reasonable 4 3 4 11
Business Hours
Inventorv 3 4 3 10
Liability
Insurance 3 7 0 10
Suretv Bonds
1 NA *** NA ***
Moratorium 1
1 NA *** NA ***
*Providers enrolled in the Medicare program are subject to Medicare standards in addition to those listed in the table. Refer to 1
Appendix A for a complete listing of Medicare standards.
-Medicare providers must operate their business in compliance with all applicable Federal and State licensure and regulatory requirements, as
required in 42 CFR  424.57(c)(1). However, there is no Federal  licensure for Medicare DME providers.
**Surety Bonds and Moratorium are not Medicare requirements, and therefore have been exclusively implemented by States.
Source: Analysis of State Medicaid DME standards compiled by OIG.
OEI-04-05.00 180 MEDICAID PROVIDER ENROLLMENT STANDARDS: MEDICAL EQUIPMENT PROVIDERS
25 Report Template Update  = 04-30-05_rev.13 
  A C K N O W L E D G M E N T S  

A P P E N D I X   A  
This report was prepared under the direction of Ann E. OConnor, 
Regional Inspector General for Evaluation and Inspections in the 
Atlanta regional office. Other principal Office of Evaluation and 
Inspections staff who contributed include: 
Linda Abbott, Program Specialist 
Mark Biagioni, Co-Lead Analyst 
Stacey Bloomer, Team Leader 
Peggy Daniel, Co-Lead Analyst 
Tricia Davis, Director, Medicare Branch 
Sharon Koehler, Program Analyst 
Scott Manley, Program Specialist 
Gerius Patterson, Data and Statistical Analyst  
Rob Rutland-Brown, Program Analyst 
OEI-04-05-00180  MEDICAID PROVIDER ENROLLMENT STANDARDS: MEDICAL EQUIPMENT PROVIDERS  26