Tip: Use OIG?s strategy for tracking device credits
APCs Weekly Monitor, December 9, 2011
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Special billing rules apply when facilities receive devices for free or at a reduced cost. The OIG continues to review whether hospitals properly identify rebates received for no-cost and reduced-cost devices as separate line items in their Medicare cost reports.
During its investigations, the OIG communicated with device manufacturers and obtained lists of device credits. This helped it determine that facilities weren't ¬reporting or requesting credits. Contact the manufacturers with which your facility conducts business and determine how you can better identify and track these credits.
Ask manufacturers to do the following:
- Create a list of patients who received a no-cost or reduced-cost device. This should include patients who have already received such a device and those who are waiting to receive one.
- Identify devices subject to the reporting requirement with brightly colored packaging or labels—something to make them easily and readily identifiable.
- Ask their field representatives to advise your hospital at the time of a procedure that a device may be subject to special payment requirements, and ask them to leave a distinctively colored form as confirmation of this notification.
If manufacturers won’t highlight or flag affected devices, consider instructing staff members who receive these devices at your facility to highlight or flag them.
The tip is adapted from “Correctly bill for free, reduced-cost devices” in the November Briefings on APCs.
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