Supplier Documentation

Documentation Requirements on or after Date of Service January 1, 2020

Before submitting a claim to the DME Medicare Administrative Contractor (MAC), a supplier must have the below on file.

There are numerous CMS manual requirements, reasonable and necessary (R&N) requirements, benefit category, and other statutory and regulatory requirements that must be met for payment to be justified. In the event of a claim review, a DMEPOS supplier must provide sufficient information to demonstrate that the applicable criteria have been met thus justifying payment.

The supplier should also obtain as much documentation from the beneficiary's medical record to assure themselves that coverage criteria for an item have been met. If the information in the beneficiary's medical record does not adequately support the medical necessity for the item, the supplier is liable for the dollar amount involved unless a properly executed Advance Beneficiary Notice of Noncoverage (ABN) of possible denial has been obtained.

CMS requires that in the event of an audit, the Medicare Administrative Contractors (MACs), Comprehensive Error Rate Testing (CERT) contractor, Supplemental Medical Review Contractor (SMRC), Recovery Auditors, and Unified Program Integrity Contractor (UPIC) shall determine that an item/service is correctly coded. The supplier must have on file a description of items provided to the beneficiary in sufficient detail to determine the accuracy of claims coding including a description of the items(s) 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.

Documentation must be maintained in the supplier's files for seven (7) years from DOS.

If the Medicare qualifying supplier documentation is older than seven (7) years, proof of continued medical necessity of the item or necessity of the repair can be used as the supporting Medicare qualifying documentation.

Purchased Items (Including Supplies)

If, at the time of transition to Medicare, a beneficiary owns a DMEPOS item that can be purchased under the Medicare program, Medicare can pay for reasonable and necessary supplies and repairs to that item. Suppliers should review the "Beneficiary's Entering Medicare" Section of policies for directions specific to that policy if applicable. At the time of that entire item replacement, Medicare treats the claim as a new, initial claim (not as a replacement). Therefore, all coverage and documentation requirements must be met to justify reimbursement for the item. Refer to the applicable Local Coverage Determination (LCD) and related Policy Article (PA) for specific information about coverage, coding and documentation. For durable medical equipment, only certain items can be paid for on a purchase basis under the Medicare program. Medicare payment can only be made for necessary supplies and repairs of beneficiary-owned equipment that Medicare can purchase, which includes items classified under the Medicare program as inexpensive or routinely purchased items, complex rehabilitative power wheelchairs, or customized items uniquely constructed or substantially modified for a specific beneficiary. This applies in all situations, including situations where the equipment is purchased prior to Medicare eligibility.

Rental Items

For rental items (i.e., beneficiary does not own item at time of transition to Medicare), Medicare does not automatically assume payment for the item. Rental coverage by Medicare is treated as a new, initial claim (not as a replacement). Therefore, all coverage and documentation requirements must be met to justify reimbursement for the item. Refer to the applicable LCD and related PA for specific information about coverage, coding and documentation and Beneficiaries Entering Medicare.

The disposition of the original item rests with the original payer, not Medicare. In addition to meeting Medicare's coverage requirements, Medicare requires that the Medicare-billed equipment be new, refurbished or inspected for functionality and ability to meet reasonable useful lifetime (RUL) requirements at the start of an initial rental.

All rented equipment must remain in good working order for the entire five-year RUL of the equipment. If the equipment does not last for the entire five-year RUL, the supplier must replace the equipment at no charge to Medicare or the beneficiary (42 CFR 414.210(e) (4)). When billing Medicare for the initial date of service, standard documentation requirements, including proof of delivery, apply. See CMS Internet Only Manual (IOM), Publication 100-08, Medicare Program Integrity Manual, Chapter 4, Sections 4.26 and CMS IOM, Publication 100-08, Medicare Program Integrity Manual, Chapter 5, Section 5.8.

Payment for Delivery and Service Charges for Durable Medical Equipment

Delivery and service are an integral part of oxygen and durable medical equipment (DME) suppliers' costs of doing business. Such costs are ordinarily assumed to have been considered by suppliers (along with all other overhead expenses) in setting the prices they charge for covered items and services. As such, these costs have already been accounted for in the calculation of the fee schedules. Also, most beneficiaries reside in the normal area of business activity of one or more DME supplier(s) and have reasonable access to them.

Therefore, DME MACs may not allow separate delivery and service charges for oxygen or DME except as specifically indicated in CMS IOM, Publication 100-04, Medicare Claims Processing Manual, Chapter 20, Section 90 or in rare and unusual circumstances when the delivery is not typical of the supplier’s operation.

There may be situations where beneficiaries live in remote areas that are not served by a local supplier or when a local supplier(s) is temporarily out of stock of required oxygen or equipment and the DME dealer incurs extraordinary delivery expenses. For example, DME MACs may recognize a reasonable separate delivery charge when the supplier must deliver an item of DME outside its normal area of business activity and the beneficiary does not have access to a supplier whose location is nearer.

When a supplier delivers oxygen or DME outside the area in which he/she normally does business, but the item could have been obtained locally, DME MACs may allow any separate additional delivery charge only to the extent that it does not raise the total payment for the oxygen or DME above the local fee schedule.

Suppliers should work with the beneficiary to find a local supplier to help with their DMEPOS needs. See CMS IOM, Publication 100-04, Medicare Claims Processing Manual, Chapter 20, Section 60

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Last Updated Wed, 16 Feb 2022 17:43:33 +0000