Got FAQs? - October 2019

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By Lisa Lake

Billing for O&P services seems to get more complicated by the day. Count on Got FAQs? to help answer your toughest questions. This month's column addresses the circumstances allowed for billing a device delivered to a patient in a skilled nursing facility (SNF) and using templates for documenting clinical information.

Q:  I am new to O&P billing, and I am confused about when we can bill for an item delivered to a patient who is in an SNF or is getting ready to leave one. I was told we could deliver a brace to a patient who was going home after discharge from the SNF, but our claim was denied as the patient was in a facility at the time of delivery. So, I am not sure when we can or can't deliver devices to a patient in a SNF. Any information you can provide would be most helpful.

A:  The following are CMS policy and billing procedures regarding the circumstances under which a supplier may deliver prostheses and orthoses to a beneficiary who is in an inpatient facility that does not qualify as the beneficiary's home. The following conditions must be met:

1. The item is medically necessary for use by the beneficiary in the beneficiary's home.
2. The item is medically necessary on the date of discharge.
3. The supplier delivers the item to the beneficiary in the facility solely for the purpose of fitting or training the beneficiary in the use of the item, and the item is for subsequent use in the beneficiary's home.
4. The supplier delivers the item to the beneficiary no earlier than two days before the day the facility discharges the beneficiary.
5. The reason the supplier furnishes the item is not for the purpose of eliminating the facility's responsibility to provide an item that is medically necessary for the beneficiary's use or treatment while the beneficiary is in the facility.

Also note, CMS rules regarding date of service for pre-discharge delivery of DMEPOS: Pre-discharge delivery of items intended for use upon discharge are considered provided on the date of discharge. Visit https://go.cms.gov/30vYRnM to view the policy. A tool at https://bit.ly/2Pb8neS can help you determine if an item is considered under consolidated billing for the SNF. It will also provide information when an item is payable in the SNF when the Part A stay has ended. For example, when you put in L-5301, the tool shows that it is separately payable during a Part A stay. L-5301 is payable in a SNF (POS 31 or 32) once the Part A stay has ended. L-5301 is separately payable during a home health episode, and it would be separately payable if unrelated to hospice diagnosis.

Q:  I have recently opened a practice in Alabama and before I start seeing patients, I want to ensure all my paperwork is correct. I have heard different opinions on my question so I prefer to hear it from an expert. If I treat a patient who has Medicare, am I allowed to use preprinted templates for my records?

A:  Medicare does not prohibit the use of templates to facilitate record-keeping. However, it does not endorse or approve any particular templates except for the clinical templates it publishes on its website. A provider "may choose any template to assist in documenting medical information. Contractors shall consider information captured in templates when conducting medical review. Some templates provide limited options and/or space for the collection of information such as by using check boxes, predefined answers, limited space to enter information, etc." Medicare discourages the use of such templates. It has been my experience that limited space templates often fail to capture sufficient detailed clinical information to demonstrate that all coverage and coding requirements are met. "Providers should be aware that templates designed to gather selected information focused primarily for reimbursement purposes are often insufficient to demonstrate that all coverage and coding requirements are met. This is often because these documents generally do not provide sufficient information to adequately show that the medical necessity criteria for the item are met." To view the policy, visit https://go.cms.gov/2PaESK8, Medicare Program Integrity Manual, Chapter 3 section 3.3.2.1.1 - Progress Notes and Templates.

Lisa Lake is an independent medical consultant with over 24 years of experience in the O&P industry, increasing providers' revenue by product recommendation, product and billing knowledge, and contract access assistance. She is a nationally recognized speaker on billing reimbursement and government compliancy. While every attempt has been made to ensure accuracy, The O&P EDGE is not responsible for errors. Lake can be contacted at llakeusa@gmail.com.