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Documentation Compliance Review Common Errors for Glucose Testing Supplies

The purpose of this article is to notify suppliers who provide glucose testing supplies of the common errors resulting in claim denial under the documentation compliance prepayment review and provide tips for resolving those errors and avoiding future errors.

About the Documentation Compliance Review

National Government Services, the Jurisdiction B DME MAC continues to conduct a documentation compliance prepayment review of home blood glucose monitoring supplies due to the high volume of errors for missing and/or incomplete documentation.

When a claim has been selected for documentation compliance prepayment review, you will receive an ADR letter requesting that you provide all of the following technical documentation:

  1. Current physician’s order for the glucose testing supplies, for the billed dates of service
  2. Valid POD
  3. Valid proof of request for refill of glucose testing supplies

You must provide the requested documentation within 45 days from the date on the ADR letter. If the requested documentation is not provided within 45 days from the date on the ADR letter, the claim will be denied.

The Jurisdiction B DME MAC reviews supplier trends each month to determine if an individual supplier impacted by the prepayment medical review is exhibiting behavior consistent with our edit release thresholds. Suppliers who are consistent with documentation compliance may be excluded from the random sample for the current audits. However, this does not exclude the supplier from future audits based on trends within the Jurisdiction B workload.

Below are the common documentation errors resulting in claim denial along with tips for resolving the errors received and avoiding future errors.

Documentation Errors Relating to Detailed Written Orders

The DWO is the only documentation provided and is signed and dated by the physician after the date of service.

Remember that you must have a valid order before you dispense any DMEPOS item. If the DWO was signed and dated after the date of service, but you have a valid dispensing order dated on or prior to the date of service, you may submit an appeal providing a copy of the verbal or preliminary written dispensing order. Make sure to submit all other required documentation with your appeal request. When the DWO is signed/dated after the date of service and you do not have a dispensing order, the current claim denial cannot be corrected.

The order is vague (states “may include” and doesn’t specify what is actually being ordered) or does not contain all required elements, such as the number of refills/length of need, or frequency of testing. 

Check your files to see if a valid order exists. The order must specifically state what the physician is ordering, rather than suggesting what the supplier “may include,” and must include the quantity, number of refills or a length of need (“lifetime” or “99” is acceptable), and frequency of testing. If you have a valid order, you may file an appeal. Make sure to submit all other required documentation with your appeal request. If you do not have an order that contains all of the required elements, the current claim denial cannot be corrected. However, you must obtain a new valid order to support coverage of future claims.

The order has an expiration date indicated and has expired.

Check the medical record for the presence of a valid ‘current’ order, if none exists, the claim error cannot be corrected. You must contact the physician to obtain a new order to support coverage for future claims.

The claim was filed with Medicare based upon receipt of a dispensing order only (did not obtain a DWO).

A dispensing order alone is not sufficient for billing Medicare. All DMEPOS suppliers, including pharmacies, must have a DWO prior to submitting the claim. Check your files to determine the presence of a detailed written order. If the detailed written order was signed/dated prior to submitting the claim, you may file an appeal and submit a copy of the DWO along with all other documentation to support coverage of your claim. If you do not have a DWO signed/dated prior to claim submission, this claim denial cannot be corrected. You must contact the ordering practitioner to obtain a signed/dated detailed written order to support coverage of future claims.

A testing log is provided, but does not indicate the timeframe, or is not for the timeframe under review.

Obtain the valid testing log and request an appeal. Make sure to submit all other required documentation with your appeal request. If there is no notation in the beneficiary’s medical record and no valid log, this error cannot be corrected.

Documentation Errors Relating to Request for Refill

The date of the contact with the beneficiary (or care giver) took place more than 14 days prior to the shipping/delivery date or date of service.

The error cannot be corrected for this date of service. For future dates of service, ensure contact takes place no more than 14 days prior to the shipping/delivery date or date of service.

The documentation does not indicate each item being requested and only states “glucose supplies.”

This error cannot be corrected for this date of service. For future dates of service, ensure documentation indicates each item being requested.

Documentation does not adequately indicate how much or how many the beneficiary has remaining of each item requested. For example, only “yes or no” statements or general statements such as “patient has nearly exhausted” are documented.

The error cannot be corrected for this date of service. For future dates of service, make sure you have adequate documentation of the quantity of supplies remaining from the previous shipment. The documentation must indicate that contact was made with the beneficiary (or caregiver) and that they assessed how much or the number of days remaining, i.e., 6 days’ worth, 10 test strips, 10 lancets, etc.

Documentation Errors Relating to Proof of Delivery

The shipping/delivery date does not match the date of service (after the date of service or more than two days prior)

The error cannot be corrected for this date of service. For future dates of service, provide new POD with correct information.

The beneficiary signature log can only be matched to the order and not the suppliers invoice showing what was actually provided.

Provide a copy of the internal invoice that can be matched to the beneficiary signature log and submit an appeal. If you are unable to provide this, the error cannot be corrected for this date of service. The proof of delivery must include an itemized list of items the beneficiary received. When the beneficiary picks up their items from a store front, the signed receipt or signature log may serve as proof of delivery as long as it contains the elements required on a proof of delivery record. If an itemized list of all items is not included on the receipt or signature log, the supplier may document the number of the itemized invoice on the receipt or signature log and provide a copy of the itemized invoice as part of their proof of delivery record. Documenting the order number on the receipt would not be sufficient as it does not indicate what the beneficiary received, but only what the physician ordered.

The beneficiary’s full address or delivery address is not on the POD documentation.

The POD must include an itemized listing of what was delivered to the beneficiary and the delivery location. When items are shipped to a beneficiary via a shipping service, make sure the POD record you submit includes your itemized invoice, which contains the beneficiary’s full address, and the shipping service’s tracking slip. Both documents are usually necessary since often the shipping service’s tracking slip does not contain the necessary information, such as an itemized listing of all items shipped, or the beneficiary’s full address. When both documents are necessary to fulfill the POD requirement, make sure the two documents can be linked to one another, i.e., both should include the Invoice number or the tracking number.

When delivering directly to a beneficiary at a store front, make sure that the supplier’s address is indicated somewhere on the POD. The beneficiary’s address may also be listed on the signature log or invoice, but Medicare requires the delivery location on the POD. Therefore, when delivered directly to a beneficiary at the supplier’s storefront, it is the supplier’s address that must appear on the POD. The supplier’s address may be in the header on the store’s letterhead or in some other location. The supplier may also note on the delivery slip that the item was “picked up” or the beneficiary was a “walk in” if it is otherwise unclear that the item was picked up at the store front.

If your claim has been denied because the POD did not contain the delivery address, you may request an appeal if you obtain additional information from the shipping company showing the full delivery address or provide the supplier’s invoice with full delivery address. If you are unable to provide this documentation, the error cannot be corrected for this date of service.

Reopenings and Appeals

If the requested documentation is not provided within the timeframe indicated on the ADR letter, the claim will be denied with ANSI CO-50, ANSI Remark Code – N102. If you subsequently submit a request for appeal within 120 days of the date of receipt of the initial determination and submit the requested documentation with that request, the request will be treated as a reopening and not a redetermination. If the DME MAC determines the documentation is insufficient to support payment of the claim, the claim will be denied with ANSI Denial CO-50, ANSI Remark Code – N115. This allows your appeal rights to remain in effect. If you continue to disagree with the claim determination you may request a redetermination (first level appeal) and submit all pertinent, supporting documentation.

Resources

For details regarding the documentation requirements for glucose monitors and testing supplies, refer to the LCD and PA for glucose monitors. You can locate the LCD and PA for glucose monitors on the National Government Services Web site.

Related Content

Revised Posted Date: 11/08/2013
Original Posted Date: 11/06/2013

Documentation Compliance Review Common Errors for Glucose Testing Supplies
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