Proof of Delivery: Part 4

The Centers for Medicare and Medicaid Services (CMS) require that DME suppliers maintain proof that any item dispensed was received by the beneficiary in the form of a Proof of Delivery document. This document must be maintained for at 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 a 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:

  1. In a facility AND
  2. Not receiving skilled care AND
  3. 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.

Sample Proof of Delivery Forms are included with the 2019 HCPCS Coding Guidance for AMERX Surgical Dressings.

Download your FREE copy today!

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 beneficiary
  • 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

DISCLAIMER: The information provided here is intended to educate health care providers regarding compliance for ICD, CPT, and HCPCS coding. The information provided does not guarantee reimbursement and is accurate to the best of our knowledge at the time of this publication. Coding guidelines can change and we encourage you to stay up to date. The existence of a code does not guarantee payment.

About the Author

Dr. Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPC

Dr. Lehrman is in private practice in Fort Collins, CO and operates Lehrman Consulting, LLC. 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. He is a Fellow of the American Academy of Podiatric Practice Management and an Expert Panelist on Codingline. In his role as a Consultant to the APMA Health Policy and Practice Department, Dr. Lehrman serves as an advisor to the APMA Coding Committee and the APMA MACRA Task Force. Dr. Lehrman sits on the board of directors of both the American Professional Wound Care Association and the American Society of Podiatric Surgeons. He is also on the editorial advisory board of the journal WOUNDS.

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