We have a letter from the Regional Centers for Medicare and Medicaid stating that we are not a Certified SNF even though we provide the skilled level of care. In billing DMEPOS glucose strips and lancets the Nursing staff have to do the testing as the patients can not. The Medicare Administrator keeps denying our Documentation and Determination that there is no delivery to the patient even though the Nursing Staff document each test. How can we get these to process?

DMEPOS may be covered under Medicare’s Supplemental Insurance Program (Part B), if it is furnished for use, in the beneficiary’s home. Medicare defines a beneficiary’s home as his or her dwelling, an apartment, a relative’s home, a home for the aged, or some other type of institution. However, a hospital or skilled nursing facility is specifically excluded as a resident’s home.

Medicare will reimburse the supplies, if delivered to the patient on his/her home address.

To be reimbursed for a claim for any quantity of test strips and/or lancets, the DME supplier must maintain:

• An appropriate diagnosis code for diabetes per the International Classification of Diseases 10th Revision (ICD-10) on each claim for DTS as listed in MCD A52464 and related LCDs, listed above

• Whether the patient requires insulin

• A physician’s order (signed and dated) containing the items to be dispensed

• The specific frequency of testing

• Proof of delivery

• Contact with beneficiary to ensure near-exhaustion of previous supply before dispensing refills (automated refills are inappropriate)

Refer page 8/23 of the below link for further details.

https://oig.hhs.gov/oei/reports/oei-06-92-00862.pdf

As per your scenario, the services are being performed at the SNF and the delivery sheet can only be obtained; if the DME is delivered at the patient’s home address. Hence, you cannot bill for the DMEPOS in SNF.

Sorry, but the Medicare letter says that the Veterans Homes for DME purposes are to be considered the resident's home - POS 12. So we can bill these supplies - the issue is that of Proof of Delivery. We are stating that the Nursing documentation is proof of delivery.

We need clarification on the POS. What place of service are you using for DME supplies? POS 12 for Home/Veterans Home or 31 for SNF. Also, Nursing documentation cannot be used as Proof of delivery of DMEPOS. For DMEPOS, supplier's and beneficiary's address must be different. If your facility is acting as supplier and beneficiary's address, then you cannot bill DMEPOS.

Make sure, your addresses are different, then Patient or designee (Any person who can sign and accept the delivery of durable medical equipment on behalf of the beneficiary) could be either a Nurse/assistant can receive the DMEPOS on behalf of patients.

An example of proof of delivery to a beneficiary is having a signed delivery slip, and it is recommended that the delivery slip include: 1) The patient’s name; 2) The quantity delivered; 3) A detailed description of the item being delivered; 4) The brand name; and 5) The serial number. The date of signature on the delivery slip must be the date that the DMEPOS item was received by the beneficiary or designee.

For better understanding, read the articles on the Links:

1. https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads/R61PI.pdf

2. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/pim83c05.pdf

Sorry, we are not a SNF POS 31 as we do not have the Medicare Part A beds at all. The letter from Medicare says: "our Division of Survey and Certification checked the status of the facilities ... not certified by the State of Illinois as Medicare skilled nursing facilities or Medicaid nursing facilities. Consequently, Medicare considers these facilities to be the equivalent of the beneficiary's home and, therefore, medically necessary DME would be a Medicare Part B covered item." ... would bill the DMERC using the place of service code "12" for "home". As you can see, the State run homes are unique to any other kind of Nursing Facility.

The Nursing Staff documentation for each test are not the supporting documents that can be considered as the proof of delivery. Hence, for POS 12, the below mentioned criteria is a mandate. The proof of delivery to a beneficiary should have a signed delivery slip, and it is recommended that the delivery slip include: 1) The patient’s name; 2) The quantity delivered; 3) A detailed description of the item being delivered; 4) The brand name; and 5) The serial number. The date of signature on the delivery slip must be the date that the DMEPOS item was received by the beneficiary or designee.

If any of the above criteria is not met, then the DME would not be considered as delivered.