Billing: Prepare by self-auditing

Q. A recent OIG report discussed replacement CPAP supplies that do not comply with the Medicare guidelines. What is the correct documentation to collect?
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Monday, July 30, 2018

A. Don’t take for granted the documentation requirements for refill requests. CPAP supplies fall under the non-consumable guidelines, which are more durable requiring periodic replacement. Refills cannot be dispensed automatically; there needs to be communication with the patient to assess the need and must be documented making sure each requested item is being addressed. The request must include the patient’s name (or authorized person), date of request, description of each item: non-consumable supplies assess why each item is no longer functional (CPAP mask broken, humidifier chamber leaking).

Is there a valid detailed written order (DWO)? Most state laws require an annual order for supply-type items. It’s highly recommended to get an order annually to meet both the state law and continued medical need requirements. The DWO also needs the frequency of refills for each item, i.e., nasal mask once every three months, tubing once every six months, etc. 

When a patient walks into the store make sure the proof of delivery lists the store address as the delivery address or has an indicator that it was picked up in the store. If this is not done, the POD appears as though it was a delivery/shipment to the home.

When a delivery service is being used a tracking number is created. The records must link the shipping invoice to the confirmation of delivery from the shipping service. The confirmation of delivery is just part of the proof of delivery that will be requested in an audit. The shipping services DO NOT store these confirmations.

There will be more audits on CPAP supplies. Be prepared by doing self-audits looking for correct documentation.