Coding and Billing

Proof of Delivery Documentation: How to Serve Patients & Be in Compliance

By Mark Wright, OD, FCOVD,
and Carole Burns, OD, FCOVD

August 7, 2019

The Centers for Medicare and Medicaid Services has established rules about delivering glasses and contact lenses to patients. Here are the details about these rules, and what your practice should do to stay in compliance.

If a Medicare auditor walks into your office and wants to see proof of delivery that you actually delivered the glasses or contact lenses that they paid for to patients – could you do it?

Medicare published an article on January 17, 2019, summarizing the proof of delivery requirements. The article is intended for “… physicians, providers, and suppliers billing Durable Medical Equipment … for items and services provided to Medicare beneficiaries.” That’s us. We bill for Medicare for reimbursable glasses/contact lenses and deliver them to patients.

There are three methods of delivering items of Durable Medical Equipment Prosthetic, Orthotics, & Supplies (DMEPOS) to Medicare beneficiaries:
• Supplier delivering directly to the beneficiary or designee
• Supplier utilizing a delivery/shipping service to deliver items
• Delivery of items to a nursing facility on behalf of the beneficiary

Once the glasses/contacts have been delivered, the beneficiary or designee must accept and legibly sign for the item. When the signature is not legible, the supplier/shipper should note the name of the beneficiary or designee on the delivery slip. A key point is that the signer many not be any party with a financial interest. You and your staff are not allowed to sign that the patient received the item because you have a financial interest.

The date should also be on the proof of delivery form. The date has a couple of possibilities. The date that the beneficiary got the DMEPOS item should be the date of service on the claim or if you use a delivery/shipping service, then you may use the shipping date as the date of service.

There is one more rule you need to know. You must maintain proof of delivery documentation for seven years.

So, what happens if you don’t do this? Medicare can deny payment for any items that do not have proof of delivery. And if you’ve already been paid, then Medicare will recover any over-payments because of such denied claims.

The scary thing that can happen is this: “Suppliers that consistently do not provide documentation to support proof of delivery of billed items may be referred to the Office of Inspector General (OIG) or National Supplier Clearinghouse (NSC) for investigation and/or imposition of sanctions.” Imposition of sanctions may result in revocation from the Medicare program.

What should be our action point from this information? Definitely, we want to have proof of delivery documentation for every Medicare job we dispense. But, let’s not stop there. We should extrapolate to every third party. For every job dispensed to patients for any third party, have them sign a proof of delivery form. It’s a simple step but an essential one. Doing this will let you answer the auditor’s question when they want to see proof of delivery that you actually delivered the glasses/contact lenses that they paid for to patients.

You can find the requirements for proof of delivery and documentation necessary to support compliance for payment purposes in the Medicare Program Integrity Manual, Chapter 4, Section 26.



To Top
Subscribe Today for Free...
And join more than 35,000 optometric colleagues who have made Review of Optometric Business their daily business advisor.