Health Information Management

Meet proper compliance when dispensing crutches in the ED

APCs Insider, March 10, 2006

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Meet proper compliance when dispensing crutches in the ED

QUESTION: If a hospital is not a durable medical equipment (DME) provider, is it a compliance concern to give patients crutches and not charge for the crutches? Does the hospital need to reflect the crutches as a supply with a zero-dollar charge? Can you offer any rules/suggestions for this scenario?

ANSWER: Consider these two important factors:

1. Inducement. Hospitals should ensure that their actions don't violate the prohibition on inducements to Medicare or Medicaid beneficiaries that the hospital knows/should know are likely to influence the beneficiary's selection of a particular provider/supplier. It is unlikely that beneficiaries will select a provider on the basis of receiving a "free" pair of crutches.

2. Giving the crutches away versus bundling them. Hospitals typically provide crutches in the course of treatment for specific procedures. For this reason, it is often possible to build the cost of crutches into the procedure charges. In these instances, treat the crutches like other non-billable supply items. One option is to build them into your ED visit/treatment room charge. If you follow this approach, you are no longer "giving" them away.

Some providers have elected to provide patients with a "loaner" pair of crutches. Surprisingly, patients often do return them after use. Other providers have elected to rent a space in the hospital to a DME company, who in turn, can bill for the DME items provided to the patient.

It is difficult to categorically state that you'll have a compliance concern if you don't bill for crutches, however as long as the activity is designed not to commit fraud or induce patients to seek care in your facility, it is not a compliance violation. If you are truly concerned, seek advice from your FI. Your FI would provide support for your actions should you ever be questioned.

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