Post-Payment Review

Normally we look at claim denials, but there are other reasons why HME providers don’t receive their money. One of them comes in the form of a post-payment review, a request from the DME MAC Medical Review team to prove that the claim the provider was paid is compliant with Medicare coverage policies. If it is not, Medicare will identify overpayments and recover the money that was reimbursed. Providers who consistently do not provide documentation to support their claims may be referred to the Office of Inspector General for investigation and/or sanctions.

Cigna Government Services, the DME MAC for Jurisdiction C, recently completed a claim review that revealed widespread deficiencies in proof-of-delivery documentation. Some of the issues Cigna identified include:

• Lack of delivery documentation;
• Date of delivery not listed;
• Missing or illegible signature of person accepting delivery;
• Designee relationship to beneficiary not documented; and
• Incomplete description of the item(s) delivered.

Proof of delivery is required in order to verify that the beneficiary received the DMEPOS billed. Proof-of-delivery documentation must be maintained in the provider’s files for seven years.

If you deliver the DMEPOS directly to the beneficiary, a signed and dated delivery slip offers proof of delivery if it contains sufficient detail to identify the items and verify that they were correctly coded. The delivery slip should list the beneficiary’s name as well as the following information for each item delivered:

• The quantity delivered;
• A detailed narrative description of the item;
• The brand name (manufacturer);
• The model name or number (if applicable); and
• The serial number (if available).

The date listed on the delivery slip should be the date the beneficiary or designee received the item.

When utilizing a shipping service or mail order, an example of proof of delivery is the service’s tracking slip plus your own shipping invoice. If possible, your records should also include the delivery service’s package identification number for the package sent to the beneficiary. The shipping service’s tracking slip should reference each individual package, the delivery address, the corresponding package identification number given by the shipping ervice and, if possible, the date delivered.

You can also utilize a return postage-paid delivery invoice from the beneficiary or designee as a form of proof of delivery. The descriptive information concerning the DMEPOS item (i.e., the beneficiary’s name, the quantity, detailed description, brand name and serial number) as well as the required signatures from either the beneficiary or the beneficiary’s designee should be included on this invoice as well.

Regardless of the method used to document proof of delivery, the beneficiary or a designee must sign and accept delivery of the item(s). Providers, their employees or anyone else having a financial interest in the delivery of the item are prohibited from signing and accepting an item on behalf of a beneficiary.

The relationship of the designee to the beneficiary must be noted on the delivery slip (i.e., spouse, neighbor, etc.). The signature of the designee should be legible. If the signature of the designee is not legible, the provider (or the shipping service) should note the name of the designee on the delivery slip.

Even though this probe was done in Jurisdiction C, all HME providers should make sure their proof of delivery is in accordance with Medicare guidelines.

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].

Of 6,612,408 claims adjudicated by the four DME MACs and processed for RemitDATA customers in Q4 2008, there were 1,143,760 total denials. Source: RemitDATA, 866/885-2974, www.remitdata.com