Comments for Business of Medicine

Comment on Changes to Stock and Bill DME by Cathy Weaver

Cathy Weaver — Thu, 11 Mar 2010 13:33:29 +0000

Jackie,

The rules we are referencing relate specifically to physicians billing for DME and a physician dispensing DME in their office setting. The rule simply put states that he who fits the orthotic bills the orthotic and they need to be credentialed with Medicare to do so. If the DME company bills the orthotic, they need to have a separate storefront and address adjacent to the physician office to do so.

I am not familiar with the Rehab Agency rules related to DME. But it seems if you are being asked to be a stock and bill company, that is a separate venture from your Rehab Agency services. If you are being asked to stock and bill in the physician practice setting, then you need to follow the rule as stated above for Medicare patients. I think to be certain you are in compliance or selecting the correct billing route, you should have a one-on-one conversation with a good healthcare attorney or consultant.

Comment on Changes to Stock and Bill DME by jackie

jackie — Thu, 11 Mar 2010 02:22:22 +0000

we were currenty approached on becoming a stock and bill company. However, we fall under rehab agency with medicare and are not required to carry a separate dme number because of our specialty we bill to our fiss Would there be any benefits to be a stock and bill company . If I am understanding correctly you have a vendor supply dme do the physicians fit the orthotics or does the vendor. Also in turn then the physician bills for this service not quite sure I understand this whole process

Comment on Changes to Stock and Bill DME by Cathy Weaver

Cathy Weaver — Tue, 02 Feb 2010 13:01:37 +0000

If there are different rules for CAH or rural facilities related to this new rule, I am not aware of it. I would recommend you contact your MAC to verify. We would welcome a posting from you on your findings.

Comment on Changes to Stock and Bill DME by Dan Ehman

Dan Ehman — Mon, 01 Feb 2010 20:56:52 +0000

Coming up on the deadline, as a DME provider, I’ve been told that hospitals who own specialty clinic, such as an orthopedic office, that have been designated “Critical Access Hospitals” will be exempt. Any info on this?

Comment on Compliance Standards for Consignment Closets and Stock and Bill Arrangements by Alli Anderson

Alli Anderson — Thu, 31 Dec 2009 19:28:35 +0000

I believe I have found my answer under other recent comments. Thank you!

Comment on Compliance Standards for Consignment Closets and Stock and Bill Arrangements by Alli Anderson

Alli Anderson — Wed, 30 Dec 2009 21:57:13 +0000

In regards to the CMS Consignment Closet Compliance Update with new effective date Mar 1, this question comes from a DMEPOS provider. Does a hospital fall under the category of “practice location or a physician’s or a non-physician practitioner”? Any insight would be appreciated on this topic.

Comment on Changes to Stock and Bill DME by Cathy Weaver

Cathy Weaver — Tue, 24 Nov 2009 13:37:01 +0000

The requirement focuses on practice locations that are “not owned by the enrolled DMEPOS supplier, but rather, owned by a physician, non-physician practitioner or other health care professional for the purpose of distribution, commonly referred to as a consignment closet and/or stock and bill arrangement.”

Arrangements with hospitals and other facilities are not affected by the change. One would need to review the requirement and the specific ownership and billing arrangements to be certain they do not fall under the new requirements.

Comment on Changes to Stock and Bill DME by Linda

Linda — Fri, 20 Nov 2009 13:31:21 +0000

There are many hospitals who provide these DME “closets” so that the DME can supply and bill the Medicare beneficiary directly. This not only relieves the hospital from ordering, restocking and carrying this inventory on their books, but also from running the risk of not being reimbursed for the equipment had they been the party to issue it. Does this change prohibit hospitals from continuing this practice?

Comment on Changes to Stock and Bill DME by Cathy Weaver

Cathy Weaver — Thu, 12 Nov 2009 22:41:50 +0000

To answer your question, David, I am going to assume that your ASC has also applied for a DME number and is billing DME using that number. If that is the case, you should be OK. If you have a true stock and bill situation as described in the requirement, then you would likely be in violation as you are furnishing the DME but not billing for it. They do not call out ASCs or facilities in the requirement because they are specifically addressing the issue seen in many physician offices. But the rule applies to DME suppliers, which your facility would be if enrolled.

Since Medicare Certified ASCs are allowed to apply for DME certification with Medicare, you would still be required to meet the requirements set on DME suppliers. Therefore: I dispense, I educate, I bill. If you are doing that, you should be OK. Since I do not know the nuances of your particular situation, I would recommend that you engage your consultant or health care attorney to address.

As far as the referral question you pose. Typically profits are distributions are paid to owners based upon one’s pro-rata share of ownership in the surgery center. If you are distributing profits via some other method, then you could be in violation of Stark laws. I would recommend you consult with your health care attorney.

Remember the base issue here: CMS Does not want anyone distributing DME to a Medicare patients, only to have a second party (who the patient may not even know exists) bill Medicare for the DME.

Comment on Changes to Stock and Bill DME by Cathy Weaver

Cathy Weaver — Wed, 11 Nov 2009 20:05:59 +0000

Thank you for your question, David. We are looking into this and will have an answer for you in the coming days.