Be Careful with Supply Refills

When providing refills to patients for supply items, providers are sometimes unsure about their responsibilities in contacting the patient and providing their needed supplies on a regular basis. Medicare has very specific rules regarding dispensing supplies on a recurring basis to beneficiaries. The regulations pertain to supply items including, but not limited to: urologicals, surgical dressings, CPAP/BiPAP supplies, nebulizer supplies, glucose monitor supplies and enteral nutrition, etc.

According to the Medicare Claims Processing Manual, Chapter 20, Section 200:

“Suppliers/manufacturers may not automatically deliver DMEPOS to beneficiaries unless the beneficiary, physician, or designated representative has requested additional supplies/equipment. The reason is to assure that the beneficiary actually needs the DMEPOS. A beneficiary or their caregiver must specifically request refills of repetitive services and/or supplies before a supplier dispenses them. A supplier may not initiate a refill of an order. The supplier must not automatically dispense a quantity of supplies on a predetermined regular basis.”

In addition, the Medicare Program Integrity Manual, Chapter 4, Section 4.26.1, states:

“For DMEPOS products that are supplied as refills to the original order, suppliers must contact the beneficiary prior to dispensing the refill. Contact with the beneficiary or designee regarding refills should take place no sooner than approximately seven days prior to the delivery/shipping date. For subsequent deliveries of refills, the supplier should deliver the DMEPOS product no sooner than approximately five days prior to the end of usage for the current product.”

Beneficiaries cannot “authorize” in advance the routine dispensing of DMEPOS items. Also, because of the time frames specified, the request for subsequent delivery cannot be made at the time of or soon after the current delivery of items. For example, when a beneficiary receives a supply of glucose test strips, it would not be acceptable for the beneficiary to tell his or her provider at that time to deliver a new supply of test strips in one to three months.

Providers should document the request for a refill. This can be documented in a number of ways, such as a postcard signed and dated by the beneficiary or the written record of a phone conversation between the provider and beneficiary/caregiver, etc. The documentation must be available on request.

Sarah Hanna is a reimbursement consultant and vice president of ECS Billing & Consulting, Tiffin, Ohio, and specializes in proper billing protocols, Medicare coverage guidelines and billing office procedures. You can reach her at 419/448-5332 or [email protected].

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