MLN Matters published an article (SE 19003) on January 17, 2019 clarifying the documentation required by CMS as proof of delivery of DMEPOS products to Medicare beneficiaries effective 11/20/2017; the information can be found in the Medicare Program Integrity Manual Chapter 4 Section 26. As a reminder, Medicare Suppliers are required to retain documentation of delivery for 7 years from the starting date of service.
Maintaining proof of delivery is required as part of record keeping for CHAP accredited organizations (Ref: CHAP standards HMEII.2c and HMEII.8a).
HMEII.2c Delivery of equipment and supplies to clients includes, at a minimum: 13) Record keeping including documentation of the delivery, setup and the client’s receipt of equipment
HMEII.8a Records of equipment, services and care provided include: 4) Date product was delivered and service provided.
Refer also to the DMEPOS Supplier Standards (CFR 424.57): (12) Must be responsible for the delivery of Medicare covered items to beneficiaries and maintain proof of delivery. (The supplier must document that it or another qualified party has at an appropriate time, provided beneficiaries with necessary information and instructions on how to use Medicare-covered items safely and effectively);
Recommendations for meeting compliance:
- Verify organizational policy and procedures describe required documentation for delivery of products and services, as well as required timeframes for retention of records/documentation.
- Train applicable staff on documentation required to be obtained with delivery as well as what information should be retained in the client record.
- Review client records for evidence of the proof of delivery. For Medicar Beneficiaries ensure this information is retained on file for 7 years.