Avoiding CERT denials for Proof of Delivery - JD DME

The Durable Medical Equipment Medicare Administrative Contractors (DME MAC) have noted an increase in Comprehensive Error Rate Testing (CERT) denials for Proof of Delivery (POD) issues. There are two methods for POD that may be utilized for all DME items:

1. Delivery directly to the beneficiary or authorized representative
2. Delivery via shipping or delivery service

Note: Some policies also have Method 3, delivery of items to a nursing facility on behalf of the beneficiary. Currently the DME MACs are not seeing CERT denials related to this method.

Per the CMS Internet Only Manual (IOM), Publication 100-08, Medicare Program Integrity Manual, Chapter 4, Section 4.7.3.1.1 and CMS IOM, Publication 100-08, Medicare Program Integrity Manual, Chapter 5, Section 5.10, Method 1 - Direct Delivery to the Beneficiary by the Supplier, suppliers may deliver directly to the beneficiary or the designee. In this case, POD to a beneficiary must be a signed and dated delivery document. The POD document must include:

• Beneficiary's name
• Delivery address
• A description of the item(s) being delivered. The description can be either a narrative description (e.g., lightweight wheelchair base), a HCPCS code, the long description of a HCPCS code, or a brand name/model number
• Quantity delivered
• Date delivered
• Beneficiary (or designee) signature

Method 1 is direct delivery to the beneficiary or authorized representative. Listed below is a common CERT denial comment for this POD method:

TECHNICAL BILLING ERROR: Submitted documentation shows the beneficiary signed for and took receipt of the Lancets on 01/12/2022 - not the billed date of service 01/10/2022.

RECEIVED: 1) Proof of delivery signed and dated by a designee on 01/12/2022.

When suppliers utilize Method 1 per the policy, "The date delivered on the POD must be the date that the DMEPOS item was received by the beneficiary or designee."

Common scenarios for billing an incorrect date of service (DOS) include: the date the order was filled, the date the beneficiary orders the items, the date the beneficiary says they will be in to pick up the item.

To avoid this type of error, suppliers must always make sure the DOS on the claim matches the date the beneficiary or authorized designee picked up the DME item(s).

Per the CMS Internet Only Manual (IOM), Publication 100-08, Medicare Program Integrity Manual, Chapter 4, Section 4.7.3.1.1 and CMS IOM, Publication 100-08, Medicare Program Integrity Manual, Chapter 5, Section 5.10, Method 2 - Delivery via Shipping or Delivery Service Directly to a Beneficiary, if the supplier utilizes a shipping service or mail order, the POD documentation must be a complete record tracking the item(s) from the DMEPOS supplier to the beneficiary. An example of acceptable proof of delivery would include both the supplier's own detailed shipping invoice and the delivery service's tracking information. The supplier's record must be linked to the delivery service record by some clear method like the delivery service's package identification number or supplier's invoice number for the package sent to the beneficiary. The POD document must include:

• Beneficiary's name
• Delivery address
• Delivery service's package identification number, supplier invoice number, or alternative method that links the supplier's delivery documents with the delivery service's records
• A description of the item(s) being delivered. The description can be either a narrative description (e.g., lightweight wheelchair base), a HCPCS code, the long description of a HCPCS code, or a brand name/model number
• Quantity delivered
• Date delivered
• Evidence of delivery

Method two is delivery via shipping or delivery service. Listed below is a common CERT denial comment for this method:

MISSING: 1) Proof of delivery that is inclusive of supplier's record/tracking information that is detailed to support the items shipped and linked to delivery services' records.

RECEIVED: Proof of delivery without beneficiary address and tracking without delivery address.

In cases when a shipping or delivery service is use, suppliers often forget to send in the complete set of documents to support the tracking information. The following documents are needed to complete a proper POD:

• Tracking information from the shipping or delivery service
• Supplier's invoice that lists, in detail, what DME items were sent to the beneficiary
• Address of beneficiary
• Ship date {Which may serve as the DOS - Suppliers may also use the date of delivery as the DOS}

Reviewers must be able to identify the item(s) shipped and see that the item(s) were delivered.