Resources and Information

This is a resource page for industry-specific news related to women's health and COVID-19.

Performant (RAC Region 5) Halts Auditing During COVID-19 Emergency

March 26, 2020

It was confirmed that Performant will be following CMS’s guidance during the COVID-19 emergency and will not be sending out any new Additional Documentation Request (ADR) letters for 30 days beginning March 18, 2020.

Recommendations for retailers and mastectomy fitters from CDC and OSHA:

  • If the patient is at all sick (even one sniffle), she should not come in for a fitting.
  • Do not engage in contact that is not absolutely necessary – no hugs, handshakes, etc.
  • Limit length of time for fitting.
  • Limit the number of people in your store at one time.
  • Wash hands thoroughly after fitting. Also, patient should wash hands after fitting. And no face touching.
  • If returning prostheses to inventory, clean prostheses after each fitting session.
  • If soap and water are not readily available, use a hand sanitizer that contains at least 60% alcohol.
  • Clean frequently touched surfaces after each fitting.

Resupply Orders

Question: It would be helpful if CMS would temporarily allow people to call in a request for an order. Right now I have the person come in and resize. If I know what size they are, they should be able to resupply without seeing someone in person. Is there a requirement for seeing a patient face-to-face annually vs. quarterly for resupply in mastectomy bras?


As long as continued use and continued medical need are in the beneficiary medical record, a provider can dispense the product. Typically, the continued medical need is valid for 12 months. An in-office visit is not required to dispense a resupply of a mastectomy bra as long as the patient has not changed sizes.

Continued Use and Continued Medical Need are required. See the following for the requirements for continued use and continued need as outlined in the standard documentation requirements (SDR):

Continued Use –comes from the supplier

  • Describes ongoing utilization of supplies or rented equipment
  • Suppliers are responsible for monitoring use of rented equipment and utilization of supplies
  • Suppliers must discontinue billing Medicare when rented equipment or ongoing supply is not being used by patient
  • Examples of proving continued use:
    • Requests for refill of supplies
    • Delivery ticket showing supplies
    • Documentation in patient file discussing use
    • Medical record from treating practitioner that discusses usage
    • Timely documentation is within the preceding 12 months

Continued Medical Need: comes from the treating practitioner

For ongoing supplies and rented DME, in addition to meeting initial coverage criteria outlined in an LCD, there must be information in the patient’s medical record to support that the item continues to remain reasonable and necessary.

Any of the following may serve as documentation justifying continued medical need:

  • A recent order by the treating practitioner for refills, or
  • A recent change in prescription/order, or
  • A properly completed CMN/DIF with appropriate length of need, or
  • Timely documentation in the medical record showing usage
  • Timely documentation is a record in the preceding 12 months

Refill Documentation

This section contains general refill requirements that pertain to all policies. Refer to the applicable LCD for policy specific refill requirements.

A routine prescription for refills is not needed.

For items that the beneficiary obtains in-person at a retail store, the signed delivery slip or a copy of the itemized sales receipt is sufficient documentation of a request for refill.

For items that are delivered to the beneficiary, documentation of a request for refill must be either a written document received from the beneficiary or a contemporaneous written record of a phone conversation/contact between the supplier and beneficiary. The refill request must occur and be documented before shipment. A retrospective attestation statement by the supplier or beneficiary is not sufficient.

The refill record must include:

  • Beneficiary’s name or authorized representative if different from the beneficiary
  • A description of each item that is being requested
  • Date of refill request
  • For consumable supplies i.e., those that are used up (e.g., ostomy or urological supplies, surgical dressings, etc.) the supplier must assess the quantity of each item that the beneficiary still has remaining to document that the amount remaining will be nearly exhausted on or about the supply anniversary date.
  • For non-consumable supplies i.e., those more durable items that are not used up but may need periodic replacement (e.g., PAP and RAD supplies) the supplier must assess whether the supplies remain functional, providing replacement (a refill) only when the supply item(s) is no longer able to function. The supplier must document the functional condition of the item(s) being refilled in sufficient detail to demonstrate the cause of the dysfunction that necessitates replacement (refill).

This information must be kept on file and be available upon request.

Proof Of Delivery (POD)

42 CFR 424.57(c)(12) requires suppliers to maintain POD documentation in their files.
POD documentation, as well as claims documentation, must be maintained in the supplier’s files for 7 years (starting from the DOS).

Suppliers, their employees, or anyone else having a financial interest in the delivery of the item(s) are prohibited from signing and accepting an item on behalf of a beneficiary (i.e., acting as a designee on behalf of the beneficiary). The relationship of the designee to the beneficiary should be noted on the delivery slip obtained by the supplier (i.e., spouse, neighbor). The signature of the designee should be legible. If the signature of the designee is not legible, the supplier/shipping service should note the name of the designee on the delivery slip.

For the purpose of the delivery methods noted below, designee is defined as any person who can sign and accept the delivery of DMEPOS on behalf of the beneficiary.

The supplier should also have on file any documentation containing a description of the item delivered to the beneficiary to determine the accuracy of claims coding including, but not limited to, a voucher, invoice or statement in the supplier records. A description of the items(s) delivered must be noted on the POD. The description can be either a narrative description (e.g., lightweight wheelchair base), a HCPCS code, the long description of a HCPCS code, or a brand name/model number.

POD documentation must be available to the Medicare contractor on request. All services that do not have appropriate POD from the supplier will be denied and overpayments will be requested. Suppliers who consistently fail to provide documentation to support their services may be referred to the Office of Inspector General (OIG) or the National Supplier Clearinghouse for investigation and/or imposition of sanctions.

As a general Medicare rule, the date of service shall be the date of delivery. There are three methods of delivery. Regardless of the method of delivery, the contractor must be able to determine that the item(s) delivered are the same item(s) submitted for Medicare reimbursement and that the item(s) were received by a specific beneficiary:

  • Delivery directly to the beneficiary or authorized representative
  • Delivery via shipping or delivery service
  • Delivery of items to a nursing facility on behalf of the beneficiary

Method 1—Direct Delivery to the Beneficiary by the Supplier
Suppliers may deliver directly to the beneficiary or the designee. In this case, POD to a beneficiary must be a signed and dated delivery document. The POD document must include:

  • Beneficiary’s name
  • Delivery address
  • A description of the item(s) being delivered. The description can be either a narrative description (e.g., lightweight wheelchair base), a HCPCS code, the long description of a HCPCS code, or a brand name/model number
  • Quantity delivered
  • Date delivered
  • Beneficiary (or designee) signature

The date delivered on the POD must be the date that the DMEPOS item was received by the beneficiary or designee. The date of delivery may be entered by the beneficiary, designee, or the supplier. When the supplier’s delivery documents have both a supplier-entered date and a beneficiary or beneficiary’s designee signature date on the POD document, the beneficiary (or designee) entered date is the DOS.

In instances where the supplies are delivered directly by the supplier, the date the beneficiary received the DMEPOS supply must be the DOS on the claim.

Method 2—Delivery via Shipping or Delivery Service Directly to a Beneficiary 
If the supplier utilizes a shipping service or mail order, the POD documentation must be a complete record tracking the item(s) from the DMEPOS supplier to the beneficiary. An example of acceptable POD would include both the supplier’s own detailed shipping invoice and the delivery service’s tracking information. The supplier’s record must be linked to the delivery service record by some clear method like the delivery service’s package identification number or supplier’s invoice number for the package sent to the beneficiary. The POD document must include:

  • Beneficiary’s name
  • Delivery address
  • Delivery service’s package identification number, supplier invoice number, or alternative method that links the supplier’s delivery documents with the delivery service’s records
  • A description of the item(s) being delivered. The description can be either a narrative description (e.g., lightweight wheelchair base), a HCPCS code, the long description of a HCPCS code, or a brand name/model number
  • Quantity delivered
  • Date delivered
  • Evidence of delivery

If a supplier utilizes a shipping service or mail order, suppliers have two options for the DOS to use on the claim:

  1. Suppliers may use the shipping date as the DOS. The shipping date is defined as the date the delivery/shipping service label is created or the date the item is retrieved by the shipping service for delivery. However, such dates should not demonstrate significant variation.
  2. Suppliers may use the date of delivery as the DOS on the claim. 

Suppliers may also utilize a return postage-paid delivery invoice from the beneficiary or designee as POD. This type of POD document must contain the information specified above.

Method 3—Delivery to Nursing Facility on Behalf of a Beneficiary
For items directly delivered by the supplier to a nursing facility or when a delivery service or mail order is used to deliver the item(s) to a nursing facility, the supplier must have:

  • Documentation demonstrating delivery of the item(s) to the facility by the supplier or delivery entity; and,
  • Documentation from the nursing facility demonstrating receipt and/or usage of the item(s) by the beneficiary. The quantities delivered and used by the beneficiary must justify the quantity billed.

Participating Vendor Partners who Offer Cleaning Supplies


OfficeMax/Office Depot


Industry Matters Podcast Episode 49: COVID-19 Updates for DMEPOS Providers 

March 23, 2020

VGM's Payer Relations experts Ronda Buhrmester and Craig Douglas team up to give an update on COVID-19 for DMEPOS providers. Ronda and Craig discuss COVID-19 hot topics, address some frequently asked questions and provide the most recent updates we have. Topics include telehealth visits related to DMEPOS, proof of delivery requirements, oxygen testing, essential business interpretations and more.

Listen here or click here.

Home Delivery, Billing, and Sales in a COVID-19 Environment Webinar

March 20, 2020

Presenters: Ronda Buhrmester (VGM & Associates), Ty Bello (Team At Work Coaching), Laura Williard (AAHomecare)

Just like supply chain preparedness, medical equipment suppliers that go to homes need to be prepared and take steps to maintain best practices for home delivery, billing, and sales in a COVID-19 Environment.
What do external stakeholders need to know about our cleaning policies and procedures? What are the precautions we need to take to mitigate exposure and compromised scenarios for our delivery and clinical staff that are in the homes of patients?
We must also be prepared for limited access to the medical referral community. How will we stay top of mind, while adhering to closed access? What best practices can our sales team execute during this time? What can be done to ensure the submission of claims continues so the cash flow isn’t impacted?

Click on the webinar links below to listen to Ronda Buhrmester, Ty Bello, and Laura Williard as they answer these.


Essentially Women


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