Tuesday, September 30, 2003

More denials in Region A
With Karen Moore

Q. Region A is fixing its system to handle overlapping dates of service for enteral nutrition and supplies, but we are still receiving denials. What can I do?

A. Region A has not changed its software to handle overlapping dates of service associated with enteral deliveries that occur as a result of the proof of delivery requirements. CMS had initially determined that they would work with Region A to prevent denials for the dates of service for these items that overlap by a few days. However, Region A was reluctant to make this change as it could prevent its system from catching other overlapping date of service issues, that if paid, would be considered an overpayment.

In recent discussions between CMS’s operations staff and the medical directors of the four DMERCs, it was decided relaxing Medicare’s proof of delivery requirements for enteral therapy would solve the problem. In turn, CMS has drafted a policy that includes a change that would allow suppliers to provide enteral formula and administration supplies up to five days ahead of when the patient will require them but report the date of service on the claim as the date the patient will begin using the items. This would ensure that suppliers do not receive erroneous denials for overlapping dates of service. Until this policy change is introduced and finalized by CMS, claims that are denied by Region A for overlapping dates of service will have to be sent to Medical Review to be adjusted. The draft policy on enteral proof of delivery change is currently going through Change Management at CMS. If approved, this change could go into affect within three to six months. Until there is a change in policy, suppliers are required to adhere to current proof of delivery requirements.

Karen Moore is a v.p. of Ancor Healthcare Consulting. Contact her at 954-757-3121.