Regulatory: Verify, verify, verify

Q. Can suppliers bill monthly rentals for Medicare patients with recalled Philips CPAP devices?

A. Yes, so long as the patient continues to use the device. Suppliers, however, should be increasingly diligent in their monthly verification procedures because the publicity surrounding the recall may persuade regular CPAP users to stop using their machines, even those produced by Philips’ competitors.

Remote monitoring is the easiest way to satisfy the requirement, but suppliers can also affirm use in person. Medicare accepts signed delivery tickets related to in-store purchases of PAP accessories as evidence the patient is using their base equipment. Although less common in practice, suppliers can also document continued use with a visual inspection of the analog hour counter on the device while visiting the patient’s home.

Alternatively, suppliers can confirm use verbally. For example, during a routine resupply call with the patient, associates ask about the condition and remaining quantity of PAP accessories on hand. Suppliers should also ask if the customer is using the CPAP device. If the customer says they are, the documented conversation supports continued billing for the machine even if the patient does not require resupply at that time.

Each claim for rental presumes the supplier can document active use, and suppliers must consider the possibility that patients may not be using recalled equipment. Those that modify verification procedures, however, can confidently claim reimbursement for recalled CPAP rentals.

Andrea Stark is the founder and head of reimbursement at MiraVista, LLC. You can reach her at ask@miravistallc.com.