Keeping Your HME/DME Documentation Complete and Compliant in 2017
With a new year underway, it is important to take a step back and analyze how your business can be more productive and efficient. One key area to target is documentation.
Here are three common sources of documentation errors that should be evaluated to ensure that your HME business starts 2017 with compliant documentation practices.
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- ABN: Is your HME business properly using the Advanced Beneficiary Notice (ABN)? When used correctly, the ABN helps ensure that patients are aware of their financial obligations for products and services that Medicare typically covers but are likely to deny under the particular circumstances.Here are some details to keep in mind about ABNs. They:
- Must be provided to patients before products and services are furnished
- May not be used as a means to charge beneficiaries for bundled services
- Are only effective for one year and do not apply to services that Medicare never covers
- Do not impact duplicate denials (CO-18), rejections/formatting denials (CO-16), and any denial not related to medical necessity
- Are valid when patients are requesting duplicate or similar equipment and when requesting quantities of supplies that exceed Medicare’s allowed amounts
- May require modifiers. The GA modifier (Waiver of Liability Statement Issued as Required by Payer Policy) must be used when a required ABN has been collected and the supplier is billing for a covered service. The GA should not be combined on the same line with any other liability modifiers, such as GX, GY, or GZ2.
2. Oxygen: Oxygen regulations are complex, but careful attention to detail can help maximize reimbursements. Here are some important reminders on oxygen protocols to ensure that your documentation is complete.
- In the case of damage, loss, or theft, a new 36-month rental period begins on the date that the new equipment is provided.
- If a supplier decides to stop providing oxygen to Medicare beneficiaries, the supplier must give beneficiaries a 90-day notice in writing.
- If a patient stops using your provided oxygen equipment for a period of more than 60 days plus whatever days remain through the end of the month—perhaps due to lengthy hospitalization and inpatient rehab for example—a new 36-month rental period can be started when the patient returns to your care.
- After oxygen equipment reaches its 5-year RUL, patients may request new equipment, which will start a new 36-month rental cycle. To supply the replacement equipment, you will need:
- Documentation of a face-to face encounter
- Written order prior to delivery
- New CMN
- To submit a claim that includes a narrative explanation that the RUL has ended and new DME is needed
- The HCPCS for the new items plus the RA modifier (for the first month of billing only)
- To maintain proof of delivery in your files plus proof of delivery for the items being replaced that supports that the items were used continuously during the RUL
- Audit avoidance and response: For every Medicare provider, audits of some type are almost certain to happen although you are more likely to avoid them when you have everything attached to your claim prior to billing. When audits do occur, though, you have to respond quickly. Here are some tips to keep in mind:
- If you are still relying, even in part, on paper documentation, you are more likely to struggle with locating everything you need for accurate billing and audit response. Paperless documentation is now a necessity.
- Remember that supplier-generated forms are not valid, even if completed and signed by physicians.
- Common compliance issues that could lead to an audit:
- Incomplete oxygen documentation—the orders must specify delivery methods and flow rates, and three qualification studies must be documented
- Incomplete face-to-face mobility evaluations—objective measurements are required
- Failure to specify specific refill requests or providing refills when not actually needed
- Illegible and/or stamped signatures
- Incomplete forms—all required elements must be addressed
- Incorrect diagnosis codes
- Invalid proof of delivery
- Failure to document ongoing medical necessity
- Failure to follow up on re-evaluation requirements
- Failure to document continuous use (when required)
4. Audit letters from the NSC are clearly marked, “Do Not Forward.” So if you are planning to relocate your business, have someone continue to collect the mail at your former address for at least a week after the move to ensure you receive all mail that might have been in process before your change of address became official.
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