Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JANET REHNQUIST 

INSPECTOR GENERAL 

SEPTEMBER 2002 

OEI-03-01-00270 

Durable Medical Equipment 

Ordered with Surrogate Physician 

Identification Numbers 
OFFICE OF INSPECTOR GENERAL

http://www.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 OIG's 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 Evaluation and Inspections 

The OIG's 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 the inspections reports generate rapid, accurate, 

and up-to-date information on the efficiency, vulnerability, and effectiveness of departmental programs. 

Office of Investigations 

The OIG's 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. The OI also oversees State Medicaid fraud control units which investigate and 

prosecute fraud and patient abuse in the Medicaid program. 

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. The OCIG imposes program exclusions and civil monetary penalties on health care providers 

and litigates those actions within the Department. The OCIG also represents OIG in the global settlement 

of cases arising under the Civil False Claims Act, develops and monitors corporate integrity agreements, 

develops model compliance plans, renders advisory opinions on OIG sanctions to the health care 

community, and issues fraud alerts and other industry guidance. 
EXECUTIVE SUMMARY 

PURPOSE 

To examine supplier billing and documentation practices for durable medical equipment, 

prosthetics, orthotics, and supplies (hereinafter, referred to as medical equipment) ordered with 

surrogate unique physician identification numbers. 

BACKGROUND 

Title XVIII of the Social Security Act prescribes coverage requirements under Part B of the 

Medicare program. Part B covers physician and outpatient hospital services along with a 

variety of other services, including the rental or purchase of medically necessary medical 

equipment. Medical equipment includes a wide range of items prescribed by a physician for 

use at home, such as hospital beds, wheelchairs, oxygen devices, surgical dressings, splints, and 

casts. 

Medicare beneficiaries covered under Part B are eligible to receive medical equipment ordered 

by a physician or non-physician provider and furnished by a supplier who has been issued a 

billing number by Medicare. If the ordering physician has not been assigned a unique physician 

identification number (UPIN), the supplier must use a temporary or surrogate UPIN when 

submitting claims. 

We selected a sample of 250 medical equipment claims from the Centers for Medicare & 

Medicaid Services’ National Claims History File for 1999 for our review. The sample 

consisted of claims for medical equipment ordered by physicians with surrogate UPINs. We 

contacted the suppliers who submitted the claims and requested documentation to support each 

sample service. We also asked for pertinent physician information, including the State in which 

the prescribing physician is licensed, medical specialty, and permanent UPIN, if known. 

FINDINGS 

Sixty-one percent of services reviewed should have been ordered using a 

permanent UPIN rather than a surrogate 

For 61 percent of services, ordering physicians had permanent UPINs at the time the service 

was provided. Physicians for more than one-third of these services had individual UPINs for at 

least 5 years prior to the dates on the claims. Physicians for 17 percent of these services had 

individual UPINs at least 10 years before the dates of service. 

Medical Equipment Ordered with Surrogate UPINs i OEI-03-01-00270 
Supporting documentation was missing or incomplete for 45 percent of services 

ordered using a surrogate UPIN 

Nearly half of services ordered with a surrogate UPIN (45 percent) had either: (1) no written 

order or certificate of medical necessity (CMN) to support the service, or (2) a written order or 

CMN with one or more items missing. Medicare paid an estimated $61 million for these 

services in 1999. 

Seventeen percent of services ordered using a surrogate UPIN had no supporting 

documentation. For 28 percent of services ordered with a surrogate UPIN, at least one piece 

of required information was missing from the documentation. The elements most often missing 

from the CMN were the beneficiary height (18 percent) and weight (17 percent). 

Documentation for 5 percent of services did not include the physician’s UPIN, and 

documentation for 4 percent of services did not include the supplier billing number. The 

elements missing from physician orders were the physician’s name or signature, description of 

the item being ordered, or the date of the order. 

Documentation for 9 percent of services was dated months after the service date 

Supporting documentation for 9 percent of services was dated more than 31 days after the 

service date provided on the Medicare claim. Seventy-one percent of these services had 

CMNs as supporting documentation and 29 percent had physician orders. Medicare paid an 

estimated $15 million for these services in 1999. For 6 percent of services, documentation was 

dated 4 or more months after the date of service. For 1 percent of services, documentation 

was dated in excess of 1 year after the date of service on the claim. 

CONCLUSION AND RECOMMENDATIONS 

We believe the use of surrogate UPINs on Medicare claims poses a vulnerability to the 

Medicare program. We found a substantial number of documentation problems in the 

supporting evidence submitted by suppliers for claims processed with surrogate UPINs. Our 

review found that 17 percent of services had no supporting documentation, and another 28 

percent had at least one piece of required information missing from the documentation. We 

have referred all of the services with missing or incomplete documentation to CMS for 

appropriate action. In 1999, we estimate Medicare paid $61 million for services ordered 

with a surrogate UPIN that had missing or incomplete supporting documentation. 

The findings detailed in this report also revealed misuse of surrogate UPINs on Medicare 

claims. We found that surrogate UPINs were incorrectly used for many services since the 

ordering physician had already been issued a permanent UPIN. We believe this is a 

Medical Equipment Ordered with Surrogate UPINs ii OEI-03-01-00270 
significant problem given that the use of a surrogate UPIN on medical equipment claims allows 

them to be processed automatically whether the equipment has been ordered by a physician or 

not. If the inappropriate use of surrogate UPINs by suppliers goes unchecked, the Medicare 

program becomes vulnerable to fraudulent billings and inappropriate payments. Therefore, we 

recommend that CMS: 

< Perform targeted reviews of claims for medical equipment ordered with surrogate 

UPINs. 

< Continue to educate suppliers and physicians that accurate UPINs must be used on 

claims, and surrogate UPINs should not be used if the ordering physician has a 

permanent UPIN. For example, an article could be included in carrier bulletins 

reminding suppliers of proper documentation practices. 

Agency Comments 

The CMS concurred with our recommendations and indicated that the agency will take the 

necessary steps to increase the monitoring of UPINs and to educate suppliers and providers 

that accurate UPINs are required on submitted claims. The CMS also stated that Medicare 

must set priorities for validating the UPIN information. As a result, CMS will be implementing 

several initiatives to improve the accuracy of UPIN reporting. Such initiatives include 

instructing DMERCs to decrease the use of surrogate UPINs through education and training, 

expanding Medicare Carrier Manual UPIN monitoring instructions to include DMERCs, and 

increasing central office/regional office monitoring of DMERCs’ UPIN activities. Appendix B 

contains the full text of CMS’ comments. 

Medical Equipment Ordered with Surrogate UPINs iii OEI-03-01-00270 
TABLE OF CONTENTS 

PAGE

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

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

FINDINGS 

Services Should Have Been Ordered Using a Permanent UPIN ...................... 6

Services with Missing or Incomplete Documentation ............................... 7

Documentation Dated Later than Service Date ................................... 8

CONCLUSION .............................................................. 9

RECOMMENDATIONS ....................................................... 9

APPENDICES

A. Estimates and Confidence Intervals ........................................ 11

B. Comments from the Centers for Medicare & Medicaid Services .................. 15

ACKNOWLEDGMENTS ..................................................... 16

Medical Equipment Ordered with Surrogate UPINs iv OEI-03-01-00270 
INTRODUCTION 

PURPOSE 

To examine supplier billing and documentation practices for durable medical equipment, 

prosthetics, orthotics, and supplies (hereinafter, referred to as medical equipment) ordered with 

surrogate unique physician identification numbers. 

BACKGROUND 

Title XVIII of the Social Security Act prescribes coverage requirements under Part B of the 

Medicare program. Part B covers physician and outpatient hospital services along with a 

variety of other services, including the rental or purchase of medically necessary medical 

equipment. Medical equipment includes a wide range of items prescribed by a physician for 

use at home, such as hospital beds, wheelchairs, oxygen devices, surgical dressings, splints, and 

casts. 

The Centers for Medicare & Medicaid Services (CMS), which administer the Medicare 

program, contract with four durable medical equipment regional carriers (DMERCs) to process 

and pay claims for medical equipment. Medicare beneficiaries covered under Part B are 

eligible to receive needed medical equipment ordered by a physician or non-physician 

provider and furnished by a supplier who has been issued a billing number by Medicare. 

Suppliers submit claims for reimbursement to the DMERCs in either paper or electronic format. 

In 1999, the DMERCs paid more than $6.2 billion for medical equipment claims. These 

payments include the 20 percent coinsurance amount for which Medicare beneficiaries are 

responsible. 

UPIN Requirements 

The unique physician identification number (UPIN) is a six-character identifier assigned to 

physicians, non-physician practitioners, and medical groups that provide services or order 

medical equipment for Medicare beneficiaries. In this report, we use the term “physician” to 

describe both physicians and other medical providers who are assigned UPINs. 

To receive a UPIN, each physician must send an application to the carrier serving his or her 

jurisdiction. The carrier reviews the application, validates the credentials of the applicant, and 

ensures that the physician is eligible for Medicare payment. Assigned UPINs are maintained in 

a national Registry of Medicare Physician Identification and Eligibility Records, also known as 

the UPIN Registry. Each physician should receive only one individual UPIN. 

Medical Equipment Ordered with Surrogate UPINs 1 OEI-03-01-00270 
Medicare requires medical equipment suppliers to provide the name and UPIN of the physician 

ordering the equipment on the claim form. Without this information, the claim should be denied. 

The DMERCs use the UPIN in a variety of analyses, such as medical review and program 

integrity activities. 

The Health Insurance Portability and Accountability Act of 1996 (the Act) mandated the 

establishment of a new provider identifier, known as the National Provider Identifier (NPI). 

According to the Act, the NPI will eventually replace the UPIN. 

Surrogate UPINs 

If the ordering physician has not been assigned a UPIN, the supplier must use a substitute 

UPIN, known as a surrogate UPIN, when submitting claims. According to Medicare 

guidelines, surrogate UPINs are temporary and may be used until an individual UPIN has been 

assigned. The DMERCs are required to monitor claims with surrogate UPINs. The CMS has 

established specific surrogate UPINs and guidelines for their use. These include: 

PHS000 To be used by physicians serving in the Public Health Service, including the 

Indian Health Service. 

VAD000 To be used by physicians employed by the Department of Veterans Affairs or 

serving on active duty in the U.S. military. 

RES000 To be used by physicians meeting the description of intern, resident or fellow. 

OTH000 To be used when the ordering physician has not yet been assigned a UPIN, and 

does not qualify for other surrogates listed above. 

Claim Documentation Requirements 

Suppliers submit medical equipment claims to the DMERCs for review and payment. In 

order for a claim to be paid by Medicare, the supplier must have a written order from a 

physician to justify the medical need for the equipment. The order must include 1) the 

beneficiary’s name, 2) the ordering physician’s signature, 3) a description of the item ordered, 

and 4) the date of the order. 

Selected items of medical equipment require a Certificate of Medical Necessity (CMN) to 

justify Medicare coverage. For these items, the CMN may serve as the physician’s written 

order. The certificates are divided into four parts: Section A, which may be completed by the 

supplier, contains information on the beneficiary, supplier, and the beneficiary’s physician. 

Section B, which must be completed by the patient’s physician 

Medical Equipment Ordered with Surrogate UPINs 2 OEI-03-01-00270 
or the physician’s employee, requires medical information and/or the results of clinical testing. 

Section C provides supplier information regarding a description of the item(s) being provided, 

the supplier’s charge for the item(s), and the Medicare allowance for the item(s). Section D 

contains the physician signature and date along with the physician’s attestation that the 

information provided is true and accurate. 

Suppliers must retain in their files the physician order as well as the CMN, if required, along 

with any other medical necessity information submitted by the ordering physician or required by 

the DMERCs. Medicare also requires suppliers to maintain a detailed record of all items 

furnished to the beneficiary, including brand names of items supplied, model numbers, and dates 

of delivery. The DMERCs are required to periodically audit supporting documentation in 

suppliers’ files. 

Related Work by the Office of Inspector General 

In a related study entitled, “Medical Equipment and Supply Claims with Invalid or Inactive 

Physician Numbers,” (OEI-03-01-00110), we found that Medicare paid $32 million for 

medical equipment claims with invalid UPINs in 1999. Additionally, we found Medicare paid 

$59 million for medical equipment claims billed with UPINs that were inactive on the dates of 

service. 

In an earlier report, “Accuracy of Unique Physician Identification Number Data,” 

(OEI-07-98-00410), information in the UPIN Registry was found to be inaccurate. For 

example, there was a lack of recent claims activity for almost 25 percent of the “active” UPINs. 

In addition, the study found evidence of erroneous State license number information. 

METHODOLOGY 

Sample Design 

We created a file consisting of all paid medical equipment claims from the National Claims 

History file for the year 1999. This file contained $6.2 billion in allowances for medical 

equipment. From this file, we extracted all services for equipment ordered with surrogate 

UPINs and removed claims submitted by beneficiaries. The resulting file contained $147 

million in allowances for services ordered with surrogate UPINs. 

From the universe of medical equipment services ordered with surrogate UPINs in 1999, we 

removed all services with allowed amounts of $10 or less. Total Medicare allowances for the 

remaining services was $146 million. We then divided these services into two strata. The first 

stratum contained services for suppliers that met two criteria: 1) at least 25 percent of their 

allowed dollars were ordered with a surrogate UPIN, and 2) they received Medicare payments 

Medical Equipment Ordered with Surrogate UPINs 3 OEI-03-01-00270 
for at least 50 services ordered with a surrogate UPIN. The second stratum contained services 

for suppliers that did not meet the two criteria. The first stratum contained 137,342 services 

and the second stratum contained 1,165,145 services. We selected a random sample of 125 

services from each stratum, for a total sample size of 250 services. 

Data Collection 

Carrier requests. We contacted each DMERC and requested copies of the sample claims. 

We received copies of claims for 246 of the 250 sample services. 

Supplier requests. Using address information obtained from the National Supplier 

Clearinghouse, we sent letters to suppliers requesting documentation to support each sample 

service. We also requested pertinent physician information, including the State in which the 

prescribing physician is licensed, the medical specialty of the physician, and the physician’s 

individual UPIN, if known. 

We received responses for 227 of the 250 sample services. Of the 227 responses, 198 

contained supporting documentation and 29 had no supporting documentation. We made three 

attempts to contact suppliers for the requested information. If the suppliers did not respond to 

the three requests, we concluded that, for the purposes of this inspection, they did not have 

documentation to support the sample services. We did not receive responses for 14 services 

following three requests. We could not locate the suppliers for the 9 remaining services. We 

did not include these 9 services in our analysis. 

Data Analysis 

Documentation from suppliers. We reviewed documentation from suppliers to identify 

ordering physicians. We also compared physician information on the claim form with the 

documentation submitted by suppliers. For medical equipment requiring a CMN, we reviewed 

the CMN as the supporting documentation. For all other medical equipment, we reviewed the 

physician’s order. We analyzed the documentation to determine if the CMNs and orders were 

completed according to DMERC requirements. 

We determined the type and number of required items that were not completed by physicians 

or suppliers in each document. We did not review documentation to determine if the 

beneficiary met medical necessity requirements. 

UPIN database. We examined the UPIN database to determine if the ordering physicians 

identified on claims or by suppliers had been assigned individual UPINs. If the physician had 

been assigned a permanent UPIN, we compared the date the UPIN was assigned to the 

physician with the date of service on the sample claim. 

Computation of estimated allowances. To compute Medicare payments for undocumented 

services and services with incomplete documentation, we totaled the 

Medical Equipment Ordered with Surrogate UPINs 4 OEI-03-01-00270 
allowed amounts for these services and weighted the estimate to reflect our stratified sample 

design. The allowed amounts include the 20 percent coinsurance amount for which Medicare 

beneficiaries are responsible. 

Point estimates and confidence intervals for all statistics presented in the findings of this report 

are provided in Appendix A. 

____________ 

This inspection was conducted in accordance with the Quality Standards for Inspections 

issued by the President’s Council on Integrity and Efficiency. 

Medical Equipment Ordered with Surrogate UPINs 5 OEI-03-01-00270 
FINDINGS 

The use of surrogate UPINs on claims for medical equipment services is a vulnerability to the 

Medicare program. From a universe of services totaling $146 million in 1999, we reviewed a 

statistically valid sample of 250 Medicare claims for medical equipment ordered with surrogate 

UPINs and found that suppliers could not provide adequate documentation for approximately 

45 percent of the services. Specifically, our review found that 17 percent of services had no 

supporting documentation, and another 28 percent had at least one piece of required 

information missing from the documentation. Nationally, we estimate that $61 million was paid 

for services not adequately documented in 1999. We also found that surrogate UPINs were 

incorrectly used for many services since the ordering physician had already been issued a 

permanent UPIN. We are recommending that CMS: (1) perform targeted reviews of claims 

for medical equipment ordered with surrogate UPINs, and (2) continue to educate suppliers 

and ordering physicians that accurate UPINs must be used on claims and that surrogate UPINs 

should not be used if the ordering physician already has a permanent UPIN. 

Sixty-one percent of services reviewed should have been 

ordered using a permanent UPIN rather than a surrogate 

For 61 percent of services, ordering physicians had permanent UPINs at the time the service 

was provided. Physicians for more than one-third of these services had individual UPINs for at 

least 5 years prior to the dates on the claims. Physicians for 17 percent of these services had 

individual UPINs at least 10 years before the dates of service. 

The use of an ordering UPIN on claims for medical equipment can provide certain protections 

to the Medicare program and its beneficiaries. The provision of a permanent UPIN on the 

claim is important because it allows Medicare to identify the physician who actually ordered 

the equipment for a beneficiary. The use of ordering UPINs on claims also ensures that 

Medicare beneficiaries are receiving equipment ordered only by qualified physicians. In 

addition, by summarizing claims data by UPINs, CMS can identify aberrant ordering or billing 

patterns for medical equipment. When surrogates are used instead of permanent UPINs on 

claims for medical equipment, these protections are no longer in place. 

According to Medicare guidelines, if the ordering physician has not been assigned a UPIN, only 

then can one of the surrogates be used. However, such usage is temporary and the surrogate 

should only be used until an individual UPIN is assigned. In a bulletin to suppliers, one 

DMERC stated: “If a physician currently has a UPIN, you must use that number.” Suppliers 

are not taking appropriate steps, as recommended by the DMERCs, to ensure that a 

physician’s individual UPIN is used on claims when he or she has one. Such steps include 

obtaining a UPIN directory from the Government Printing Office, checking Internet websites 

containing listings of permanent UPINs by State, and 

Medical Equipment Ordered with Surrogate UPINs 6 OEI-03-01-00270 
contacting the ordering physician directly. One DMERC stated in a bulletin to suppliers that 

“All suppliers should review their claim submission processes to ensure that they submit all 

claims with correct UPINs.” 

Supporting documentation was missing or incomplete for 

45 percent of services ordered using a surrogate UPIN 

Nearly half of services ordered with a surrogate UPIN (45 percent) had either: (1) no written 

order or CMN to support the service, or (2) a written order or CMN with one or more items 

missing. Depending on the type of equipment provided, suppliers are required to have either a 

completed CMN or a physician order on file to support the Medicare claim. In 1999, we 

estimate Medicare paid $61 million for services ordered with a surrogate UPIN that had 

missing or incomplete supporting documentation. 

Seventeen percent of services ordered using a surrogate UPIN had no supporting 

documentation 

Suppliers did not submit supporting documentation for 17 percent of services ordered using a 

surrogate UPIN. For 3 percent of services, suppliers did not submit documentation after three 

written requests. For 14 percent of services, suppliers did respond but indicated that no 

documentation was available. Medicare paid an estimated $17 million in 1999 for claims with 

missing documentation. 

Documentation for 28 percent of services was incomplete 

For 28 percent of services ordered with a surrogate UPIN, at least one piece of required 

information was missing from the CMNs or orders. The DMERCs require that all elements 

contained on supporting documentation be completed. In 1999, Medicare paid an estimated 

$44 million for services with incomplete documentation. 

Certificates of medical necessity for 25 percent of services ordered with surrogate UPINs were 

missing one or more pieces of information. Missing elements affected all sections of required 

information, including patient information, supplier information, physician information, and 

information related to the medical equipment ordered. For 9 percent of services, CMNs were 

missing three or more elements. The number of items missing on incomplete CMNs ranged 

from 1 to 14. 

There were a number of required elements missing from CMNs and physician orders. The 

elements most often missing from CMNs were the beneficiary height (18 percent) and weight 

(17 percent). For certain items of medical equipment, such as wheelchairs, height and weight 

are elements that need to be reviewed to ensure that beneficiaries are receiving the appropriate 

equipment. Documentation for 5 percent of services did not include the physician’s UPIN, and 

Medical Equipment Ordered with Surrogate UPINs 7 OEI-03-01-00270 
documentation for 4 percent of services did not include the supplier billing number. The 

elements missing from physician orders were the physician’s name or signature, description of 

the item being ordered, or the date of the order. 

Documentation for 9 percent of services was dated months 

after the service date 

Supporting documentation for 9 percent of services was dated more than 31 days after the 

service date provided on the Medicare claim. Seventy-one percent of these services had 

CMNs as supporting documentation and 29 percent had physician orders. Medicare paid an 

estimated $15 million for these services in 1999. Some of these services also had items missing 

from the documentation. For 6 percent of services, documentation was dated 4 or more 

months after the date of service. For 1 percent of services, documentation was dated in excess 

of 1 year after the date of service on the claim. 

Medical Equipment Ordered with Surrogate UPINs 8 OEI-03-01-00270 
CONCLUSION 

We believe the use of surrogate UPINs on Medicare claims poses a vulnerability to the 

Medicare program. We found a substantial number of documentation problems in the 

supporting evidence submitted by suppliers for claims processed with surrogate UPINs. Our 

review found that 17 percent of services had no supporting documentation, and another 28 

percent had at least one piece of required information missing from the documentation. We 

have referred all of the services with missing or incomplete documentation to CMS for 

appropriate action. In 1999, we estimate Medicare paid $61 million for services ordered 

with a surrogate UPIN that had missing or incomplete supporting documentation. 

The findings detailed in this report also revealed misuse of surrogate UPINs on Medicare 

claims. We found that surrogate UPINs were incorrectly used for many services since the 

ordering physician had already been issued a permanent UPIN. We believe this is a significant 

problem given that the use of a surrogate UPIN on medical equipment claims allows them to be 

processed automatically whether the equipment has been ordered by a physician or not. If the 

inappropriate use of surrogate UPINs by suppliers goes unchecked, the Medicare program 

becomes vulnerable to fraudulent billings and inappropriate payments. 

RECOMMENDATIONS 

We recommend that CMS: 

< Perform targeted reviews of claims for medical equipment ordered with surrogate 

UPINs. 

< Continue to educate suppliers and physicians that accurate UPINs must be used on 

claims, and surrogate UPINs should not be used if the ordering physician has a 

permanent UPIN. For example, an article could be included in carrier bulletins 

reminding suppliers of proper documentation practices. 

Agency Comments 

The CMS concurred with our recommendations and indicated that the agency will take the 

necessary steps to increase the monitoring of UPINs and to educate suppliers and providers 

that accurate UPINs are required on submitted claims. They also stated that Medicare must set 

priorities for validating UPIN information. As a result, CMS will be implementing several 

initiatives, which include instructing DMERCs to decrease the use of surrogate UPINs through 

education and training, expanding Medicare Carrier Manual 

Medical Equipment Ordered with Surrogate UPINs 9 OEI-03-01-00270 
UPIN monitoring instructions to include DMERCs, and increasing central office/regional office 

monitoring of DMERCs’ UPIN activities. Appendix B contains the full text of CMS’ 

comments. 

Medical Equipment Ordered with Surrogate UPINs 10 OEI-03-01-00270 
APPENDIX A 

Estimates and Confidence Intervals

PAGE 

TABLE 1. Services That Should Have Been Ordered Using a Permanent UPIN

Rather Than a Surrogate UPIN ........................................ 12

TABLE 2. Services with Missing or Incomplete Documentation ......................... 12

TABLE 3. Undocumented Services Ordered Using a Surrogate UPIN .................... 13

TABLE 4. Services Supported by Incomplete Documentation .......................... 13

TABLE 5. Items Missing from Documentation ...................................... 13

TABLE 6. Services Supported by Incomplete CMNs ................................ 14

TABLE 7. Services with Supporting Documentation Dated After the Date of Service ......... 14

Medical Equipment Ordered with Surrogate UPINs 11 OEI-03-01-00270 
APPENDIX A 

Estimates and Confidence Intervals

The tables below contain statistical estimates presented in the Findings section of this report. 

These estimates are weighted based on the stratified random sample design and are reported at 

the 95 percent confidence level. 

Table 1. 

Services That Should Have Been Ordered Using a Permanent UPIN 

Rather Than a Surrogate UPIN 

Point Estimate 95% Confidence Interval 

Percent of Services that Should Have Been Ordered 

with a Permanent UPIN 

60.53% 52.89% - 68.17% 

Percent of Services where Ordering Physician had 

a Permanent UPIN for 5 or More Years 

37.93% 27.99% - 47.87% 

Percent of Services where Ordering Physician had 

a Permanent UPIN for 10 or More Years 

16.60% 9.11% - 24.09% 

Table 2. 

Services with Missing or Incomplete Documentation 

Point Estimate 95% Confidence Interval 

Percent of Services with Missing or 

Incomplete Documentation 

44.96% 37.02% - 52.90% 

Total Medicare Allowances in 1999 for Services 

with Missing or Incomplete Documentation 

$60,678,298 $42,226,787 - $79,129,808 

Medical Equipment Ordered with Surrogate UPINs 12 OEI-03-01-00270 
APPENDIX A 

Table 3. 

Undocumented Services Ordered Using a Surrogate UPIN 

Point Estimate 95% Confidence Interval 

Percent of Services with 

No Supporting Documentation 

16.70% 10.76% - 22.64% 

Percent of Services where Suppliers Did Not Submit 

Documentation After 3 Written Requests 

3.18% 0.65% - 5.71% 

Percent of Services where Suppliers Responded but 

Did Not Submit Documentation 

13.53% 7.98% - 19.08% 

Total Medicare Allowances in 1999 for Services 

Ordered with a Surrogate UPIN 

$16,600,257 $8,565,455 - $24,635,060 

Table 4. 

Services Supported by Incomplete Documentation 

Point Estimate 95% Confidence Interval 

Percent of Services Supported by Incomplete 

Documentation 

28.26% 21.18% - 35.34% 

Total Medicare Allowances in 1999 for 

Services Supported by Incomplete Documentation 

$44,078,040 $26,457,005 - $61,699,075 

Table 5. 

Items Missing from Documentation 

Percent of Services 95% Confidence Interval 

Beneficiary’s Height Missing 18.17% 12.00% - 24.34% 

Beneficiary’s Weight Missing 17.44% 11.38% - 23.50% 

Physician’s UPIN Missing 4.62% 1.70% - 7.54% 

Supplier’s Billing Number Missing 3.89% 1.32% - 6.46% 

Description of Item Ordered Missing 3.91% 1.03% - 6.79% 

Medical Equipment Ordered with Surrogate UPINs 13 OEI-03-01-00270 
APPENDIX A 

Table 6. 

Services Supported by Incomplete CMNs 

Point Estimate 95% Confidence Interval 

Percent of Services with CMNs Containing 

1 or More Missing Items 

25.35% 18.51% - 32.19% 

Percent of Services with CMNs Containing 

3 or More Missing Items 

8.82% 4.59% - 13.05% 

Table 7. 

Services with Supporting Documentation 

Dated After the Date of Service 

Point Estimate 95% Confidence Interval 

Percent of Services with Documentation 

Dated After the Date of Service 

8.95% 4.36% - 13.54% 

Percent of These Services with a CMN Dated After 

the Date of Service 

71.46% 47.45% - 95.47% 

Percent of These Services with an Order Dated After 

the Date of Service 

28.54% 4.53% - 52.55% 

Total Medicare Allowances in 1999 for 

Services with Documentation Dated 

After the Date of Service 

$15,081,142 $39,000 - $30,123,283 

Percent of Services with Documentation 

Dated 4 or More Months After the Date of Service 

5.84% 2.10% - 9.58% 

Percent of Services with Documentation 

Dated More Than 12 Months After the Date of 

Service 

0.91% 0% - 2.36% 

Medical Equipment Ordered with Surrogate UPINs 14 OEI-03-01-00270 
APPENDIX B 

Comments from the

Centers for Medicare & Medicaid Services

Medical Equipment Ordered with Surrogate UPINs 15 OEI-03-01-00270 
ACKNOWLEDGMENTS 

This report was prepared under the direction of Robert A. Vito, Regional Inspector General for 

Evaluation and Inspections in Philadelphia and Linda M. Ragone, Deputy Regional Inspector General. 

Other principal Office of Evaluation and Inspections staff who contributed include: 

Robert Katz, Project Leader Tricia Davis, Program Specialist

Erika Lang, Lead Analyst Barbara Tedesco, Mathematical Statistician

Lauren McNulty, Program Analyst

Cynthia R. Hansford, Program Assistant

Medical Equipment Ordered with Surrogate UPINs 16 OEI-03-01-00270