I have seen many different options for dispensing equipment that is “required” for a patients ADL use. The most important question is whether we provide the item for home-going use; “Is the item a personal convenience item not generally covered by Medicare?” If it is categorized as personal convenience, what is the medically necessary rationale for the facility to provide it for training as a loaner vs “as purchase” for home-going? Should the facility absorb the cost if it is an uncovered item but makes the best sense for a patient’s safety purpose?
The following are good references to have on discussions for how your facility should handle personal convenience items.
- 1.) Convenience items not necessarily provided to all patients as part of a stay
- 2.) Convenience items that may be provided as a courtesy for use during the stay
- 3.) Convenience items that may be needed for home use but not covered under DME simply because they are “convenience” in nature.
Each of these topics are referenced in these two areas of the Medicare online manuals. Pay attention to the examples Medicare provides.
Medicare Claims Processing Manual 100-04; Chapter 1: 40.0 Supplies, Appliances & Equipment
Medicare Claims Processing Manual 100-04; Chapter 3; 40.2.3 – Determining Covered and Noncovered Charges – Pricer and PS&R
There is not a hard and fast rule for ADL items unless they are medically necessary. When medically necessary, they must be supplied as part of a covered part A stay for use while in the facility. Home-going use is entirely different. When items are for home-going use, each facility must make the rule and then apply that rule evenly across all patient types when an item is considered ‘convenience’.
Many of the types of equipment dispensed in IRF/IRUs are considered ‘personal convenience items’ when still needed for home-going. This type of equipment is considered an out of pocket expense (not covered under DME). When you provide uncovered equipment for home-going use you CAN bill the patient. It is important to provide the patient with a courtesy notice so they are aware it will be billed separately. It also allows the patient to obtain the item in the manner of their choice since it would be out of pocket. If the item is something that is NEVER covered by Medicare, an Advanced Beneficiary Notification is not technically required but is good practice for courtesy purposes. A simple notification allows the patient to make a choice for who will provide the item when it is not a covered benefit.
If an item is NOT a single use item, meaning it can be sterilized between patient use, it can be loaned to patient. If you want to sell it to the patient for use after discharge, the personal convenience item should be coded as personal convenience and listed in the ‘non-covered’ section of the uniform bill. Personal convenience codes may include 0990, Admitting Kit 0997 (only if not provided to everyone), and ‘other’ 0999 with specific description.
I have seen items available for purchase in a gift shop, through a DME provider store within a hospital and through an equipment closet as a convenience, but billed by an outside business. There are many different ways to permit patients to purchase non-covered items prior to home-going. Creating a fund for ‘hardship’ use when a person qualifies for indigent care is also a good way to provide items for persons who do not have the means to supply their own convenience items.
If you decide not to bill a convenience item that is also used for home-going, it must be provided to all patients free of charge. It is still a wise idea to track those on the UB as a non-covered item with zero charge. Again, applying that rule to all patients equally.