CMS Updates COVID-19 POD Signature Requirements

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In April, the Centers for Medicare & Medicaid Services (CMS) waived signature requirements on proof of delivery (POD) documentation for dates of service within the public health emergency (PHE) for the COVID-19 pandemic. Given the nature of the pandemic and the inability to collect signatures, CMS said it would not enforce the signature requirement.


CMS has updated its requirement to advise suppliers to append a CR modifier and include a narrative of "COVID-19" to all claims that are affected by the COVID-19 PHE, including situations where a signature is not able to be obtained on a POD document. The narrative should be entered into the NTE 2400 (line note) or NTE 2300 (claim note) segments of the American National Standard Institute (ANSI X12) format, field 390-BM of the National Council for Prescription Drug Program (NCPDP) format, or Item 19 of paper claims.


Proof of delivery via shipping or delivery service does not require a signature from the beneficiary or designee; however, it does require evidence of delivery.


Review the Standard Documentation Requirements for All Claims Submitted to DME MACs (A55426) External Website Policy Article for complete information on proof of delivery documentation requirements.