Post

By Kim Turner , RN

Although CMS has not made any recent changes to the current proof of delivery (POD) documentation requirements and guidelines for Medicare, it is recommended as best practice to evaluate the procedures you have in place for meeting the Medicare requirements for proof of delivery and ensuring you have the documentation available in the beneficiary files to support and ensure Medicare compliance for payment purposes.  

Suppliers must maintain proof of delivery documentation in their files for 7 years; this period starts from the date of service. This includes proof of delivery to verify that the beneficiary received the Durable Medical Equipment Prosthetic, Orthotics, & Supplies (DMEPOS) item and to determine the amounts to pay the provider for the item.

There are three methods of delivering items of DMEPOS to beneficiaries: 

• Method 1-Supplier delivering directly to the beneficiary or designee 
• Method 2- Supplier utilizing a delivery/shipping service to deliver items 
• Method 3- Delivery of items to a nursing facility on behalf of the beneficiary 

Method 1—Direct Delivery to the Beneficiary by the Supplier

Suppliers may deliver directly to the beneficiary or the designee. In this case, POD to a beneficiary must be a signed and dated delivery document. The POD document must include:

• Beneficiary’s name
• Delivery address
• A description of the item(s) being delivered. The description can be either a narrative description (e.g., lightweight wheelchair base), a HCPCS code, the long description of a HCPCS code, or a brand name/model number
• Quantity delivered
• Date delivered
• Beneficiary (or designee) signature

The date delivered on the POD must be the date that the DMEPOS item was received by the beneficiary or designee. The date of delivery may be entered by the beneficiary, designee, or the supplier. The beneficiary (or designee) entered date is the date of service (DOS). Supplies that are delivered directly by the supplier, the date the beneficiary received the DMEPOS supply must be the DOS on the claim.

Method 2—Delivery via Shipping or Delivery Service Directly to a Beneficiary 

If the supplier utilizes a shipping service or mail order, the POD documentation must be a complete record tracking the item(s) from the DMEPOS supplier to the beneficiary. An example of acceptable POD would include both the supplier’s own detailed shipping invoice and the delivery service’s tracking information. The supplier’s record must be linked to the delivery service record by some clear method like the delivery service’s package identification number or supplier’s invoice number for the package sent to the beneficiary. The POD document must include:

• Beneficiary’s name
• Delivery address
• Delivery service’s package identification number, supplier invoice number, or alternative method that links the supplier’s delivery documents with the delivery service’s records
• A description of the item(s) being delivered. The description can be either a narrative description (e.g., lightweight wheelchair base), a HCPCS code, the long description of a HCPCS code, or a brand name/model number
• Quantity delivered
• Date delivered
• Evidence of delivery

If a supplier utilizes a shipping service or mail order, suppliers have two options for the date of service (DOS) to use on the claim:

1. Suppliers may use the shipping date as the DOS. The shipping date is defined as the date the delivery/shipping service label is created or the date the item is retrieved by the shipping service for delivery. However, such dates should not demonstrate significant variation.
2. Suppliers may use the date of delivery as the DOS on the claim. 

Suppliers may also utilize a return postage-paid delivery invoice from the beneficiary or designee as POD. This type of POD document must contain the information specified above.

Method 3—Delivery to Nursing Facility on Behalf of a Beneficiary

For items directly delivered by the supplier to a nursing facility or when a delivery service or mail order is used to deliver the item(s) to a nursing facility, the supplier must have:

• Documentation demonstrating delivery of the item(s) to the facility by the supplier or delivery entity; and,
• Documentation from the nursing facility demonstrating receipt and/or usage of the item(s) by the beneficiary. The quantities delivered and used by the beneficiary must justify the quantity billed.

What if your customer took delivery of equipment (DMEPOS) prior to being eligible for Medicare?

When another insurer paid for the beneficiaries DMEPOS, Medicare does not automatically assume payment for a DMEPOS item that was covered prior to a beneficiary becoming eligible for the Medicare FFS program. When a beneficiary keeps a DMEPOS item received prior to Medicare eligibility, upon entering the Medicare program and seeking coverage, the supplier must complete the following:

• Ensure all Medicare requirements for payment are met, 
• The supplier must examine the equipment and ensure it is in proper working order,
• Supplier must obtain a statement, signed and dated by the beneficiary (or beneficiary's designee), that the supplier has examined the item,  
• Supplier must also attest to the fact that it meets Medicare requirements.

DME MACs educate the supplier community that they must submit a claim for the item and the necessary documentation to support Medicare payment, upon request, including an attestation that the supplier examined the equipment and found it to be in proper working order.  The first day of the first rental month in which Medicare makes payment for the item serves as the start date of the reasonable useful lifetime and period of continuous use. This is true even if there is no change in the beneficiary’s medical condition.

Did you know?

Suppliers, their employees, or anyone else having a financial interest in the delivery of the item(s) are prohibited from signing and accepting an item on behalf of a beneficiary (i.e., acting as a designee on behalf of the beneficiary).

If delivery is signed by the beneficiary’s designee, the relationship of the designee to the beneficiary should be noted on the delivery slip obtained by the supplier (i.e. daughter, son, spouse, neighbor).

The signature of the designee should be legible. If the signature of the designee is not legible, the supplier/shipping service should note the name of the designee on the delivery slip.

POD documentation must be available to the Medicare contractor on request.

All services that do not have appropriate POD from the supplier will be denied and overpayments will be requested. 

Need help?

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