Streamlining your processes in the event of an audit
by Roberta Domos

Most providers know that Medicare regulations differ depending on whether a product is delivered by the DME provider in a face-to-face exchange with the patient versus when the product is shipped to the patient by a package carrier. However, the nuances of complying with shipping rules can be tricky. In the current audit-rich environment, understanding those nuances can make all the difference between the claim being paid or denied on a technicality. Here are some tips to help make your mail order claims picture perfect for Medicare.

When mailing a covered product to a Medicare beneficiary you must obtain confirmation that the shipment was delivered. However, the provider must always use the shipping date (generally the day the package is provided to the shipper) as the date of service on the claim.

There is no need to have the beneficiary sign for the delivered package, but the tracking number on the shipment must be matched to the shipper’s delivery confirmation. It’s best to have a process in place to obtain this confirmation no more than five to seven days after the product is shipped, and keep a copy of the document in the patient file since it will be required by Medicare in the event the claim is audited.

In an audit situation you will also have to prove what was in the package you sent. This is best accomplished by copying and saving the tracking number onto a delivery ticket or packing slip comment field in the software you use to create the delivery ticket and including a printed copy of it in the package you are shipping. Also ensure that the quantity and make/model or brand of the products provided are listed on this same packing slip or delivery ticket.

If you are resupplying the patient, you can ship the product up to 10 days prior to the end date on the span date of last shipment, but remember the claim will not be paid if you miscalculate the previous usage span and ship new supplies even one day early. Double check your previous billing dates and use a span date calculator to ensure you are not shipping the product before the patient is eligible for resupply.

An assignment of benefits (AOB) form must be signed before a provider can bill the claim associated with the shipment, but only if the DME provider is listed as a non-participating provider with the National Supplier Clearinghouse.

Participating providers do not need a signed assignment of benefits statement from the beneficiary because they must accept assignment on all Medicare claims. Companies that have a robust mail order business may wish to be listed as a participating provider to avoid having to wait until the beneficiary signs and mails back the AOB form before billing the claim. Indeed, avoiding the need for a signed AOB from a patient receiving supplies via mail may be the only rational reason a DME provider elects to be a participating provider.

Based on our review of client claims denied during the audit process it’s apparent that not all auditors seem to know that participating suppliers are exempt from the AOB requirement. For this reason we advise all DME providers that are a participating provider and have opted not to obtain an AOB to include the following statement with every audit response, regardless of what type of audit they are responding to:

Because [Name of Company] is a participating supplier, we are not required to procure an Assignment of Benefits per the DMEPOS Mac Supplier Manual – Beneficiary Authorization section: “For all claims submitted on or after January 1, 2005, payment shall be made to physicians and suppliers even without a beneficiary-signed assignment of benefits (AOB) form when the service can only be paid on an assignment related basis. This includes any mandatory assignment situations and participating physician or supplier situations.”

Hopefully, these quick tips will help you streamline your mail order business processes and ensure that all Medicare required documentation related to the shipping process is “ship” shape in the event of an audit.