News

Is the DME industry like a box of chocolates?

Date Published: September 10 2014

Do we ever know what we are going to get?

If a durable medical equipment (DME) supplier discovers an error in the office notes or written order prior to delivery (WOPD) “after” they have submitted the claim, they must recover the DME and a new supplier must complete the transaction. 

Face-to-Face ACA 6407 requirements – I read it and believed I understood the corrections and amendments. The treating physician must conduct a face-to-face examination, document the medical necessity and write a detailed (WOPD). This sounded familiar but I was curious - what’s new?

If a DME supplier discovers an error in the office notes or on the WOPD before delivering the equipment, they may go back to the physician and explain what is missing and request the amended paperwork. They must remember to get signatures and dates for anything that is added or amended. If the supporting information is just not there, the supplier can request that the physician conduct a new face-to-face exam. All of this must happen “before” the DME is delivered. Got it.

If the supplier finds an error in the office notes or on the WOPD “after” they have delivered the DME but “before” they have submitted a claim, the supplier must “recover” the DME. The supplier must then go back to the physician and explain what is found to be in error, in the WOPD and/or the office notes, and request amended paperwork. Once received the DME provider can redeliver the DME. Got it.

However, if a durable medical equipment (DME) supplier discovers an error in the office notes or WOPD “after” they have submitted the claim, they must recover the DME and a new supplier must complete the transaction. Did I understand that correctly?

The Centers for Medicare and Medicaid Services picked an interesting choice of words in the ACA 6407 amended requirements: “Recover” and “Transaction.” The supplier must recover (pick up) the DME and another supplier must complete the transaction (redeliver the equipment) to the client.

I asked myself, how could this happen? The answer is a prepayment audit. DME Company ABC receives face-to-face office notes and WOPD from a referral source and believes them to be in compliance with the ACA 6407 requirements. ABC delivers a semi-electric hospital bed to Mr. Jones and bills the claim.  Three months into the rental, ABC receives a prepayment audit. ABC sends the supporting face-to-face documentation and it is found to be non-compliant. ABC “recovers” the hospital bed from Mr. Jones and waits for the overpayment letter or completes a voluntary refund. The hospital bed has been in Mr. Jones’ home for three months, an ABC employee has made two home visits and the supplier still hasn’t received reimbursement. ABC cannot bill Mr. Jones because the liability determination is applied. They cannot use a blanket advance beneficiary notice and they cannot redeliver the bed. Like Forrest Gump, ABC never knew what they were going get.

The bottom line: when it comes to face-to-face documentation, know what you are getting. Check, double check and if possible triple check supporting documentation from referral sources prior to delivering the DME. Though it cannot alleviate human error such as forgetting to date stamp documentation, a standardized online documentation tool like DMEevalumate.com can ensure the WOPD and face-to-face office notes are complete and accurate.

- Jamie Loper, Co-Founder of DMEevalumate.com.

Back to news