The Centers for Medicare and Medicaid Services (CMS) require that DME suppliers maintain proof that any time dispensed was received by the beneficiary in the form of a Proof of Delivery document. This document must be maintained for a least seven years. This could be requested by DMEMACs, recovery auditors, supplemental medical review contractors, or Comprehensive Error Rate Testing (CERT) medical review contractors. Failure to adhere to this regulation can result in not only claim denial and payment recoupment, but also removal of the guilty provider from the Medicare program.
Methods of Delivery
There are three different methods by which a DME item may be delivered. These include direct delivery by the supplier, delivery of the item to the patient via shipping or delivery service, and delivery to a nursing facility. Beyond the requirements covered in the February 2019 blog, there are additional documentation requirements for Proof of Delivery, and they differ based on the method of delivery.
Delivery To Nursing Facility
When patients are under their part A stay in a skilled nursing facility, they do not have coverage for DME items provided by a physician’s office. However, when patients are:
- In a facility AND
- Not receiving skilled care AND
- Not under a part A stay
their benefits are no different than when they are seen in the office setting. In this situation, providers may want to provide surgical dressings and/or compression garments to patients in a nursing facility. When this occurs, it may be convenient to have these items delivered directly to the facility.
Proof of Delivery Document Requirements
When DME items are delivered by the provider to a nursing facility or when a delivery service/mail order is used to deliver DME items to a nursing facility, the Proof of Delivery must contain:
- Documentation demonstrating delivery of the item(s) to the facility by the provider or delivery entity
- Documentation from the nursing facility demonstrating receipt and/or usage of the item(s) by the benficiary
- Description of the item in the form of a narrative, a HCPCS code, the HCPCS code descriptor, the brand name of the item, or the item’s model number
- Quantity delivered
Dr. Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPC, CPMA
Dr. Lehrman is a podiatrist practicing in Fort Collins, CO and operates Lehrman Consulting, LLC which provides consultation services regarding coding, compliance and documentation. Dr. Lehrman is a Certified Professional Coder and Certified Professional Medical Auditor. He serves as a staff liaison at the AMA CPT® Editorial Panel meetings where CPT codes are created, edited, and deleted. He is a Diplomate of the American Board of Foot and Ankle Surgery, Fellow of the American Society of Podiatric Surgeons, and is recognized as a “Master” by the American Professional Wound Care Association. Dr Lehrman is a Fellow of the American Academy of Podiatric Practice Management, Past Director of the American Professional Wound Care Association Board of Directors, and is a Past Chairman of the Board of the American Society of Podiatric Surgeons. Dr. Lehrman is also on the editorial advisory board of the journal WOUNDS.
