By: Christina Colegrove, RN,BSN – Clinical Consultant
Here are some things to remember when completing a refill request to avoid denials. Documentation of a refill request must be either a written document received from the beneficiary or a written record of a phone conversation between the supplier and beneficiary. The request must include the beneficiary’s name/authorized representative, description of each item being requested and date of refill request. If consumable supplies are being requested, then the supplier should assess the quantity of each item that the beneficiary has remaining. The supplier manual mentions, “Vague or nonspecific references to the quantity remaining are not sufficient to demonstrate compliance with the requirement that refills be provided when the current supply on hand is ‘approaching exhaustion’.” Although an actual count is not necessary, it is recommended. The record should demonstrate that individual assessment was performed. Examples of consumable supplies includes surgical dressings or urological supplies. If non-consumable supplies (items that are not used up but may need periodic replacement) are being requested, then the supplier should assess if the supplies remain functional and provide replacement/refill only when the item(s) are no longer functioning. The documentation should support the functional condition of the item(s) being refilled and demonstrate the cause of dysfunction which necessitates replacement. Examples of non-consumable supplies includes PAP or RAD supplies.
Per the Medicare Program Integrity Manual, “Suppliers must contact the beneficiary prior to dispensing the refill and not automatically ship on a pre-determined basis, even if authorized by the beneficiary.” The beneficiary/designee should be contacted no sooner than 14 calendar days prior to the delivery/shipping date. The supplier must deliver the product no sooner than 10 calendar days prior to the end of usage for the current product.