Proof of Delivery
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Proof of Delivery
Recent claim reviews by members of the Medical Review staff have revealed widespread deficiencies in proof of delivery documentation.  Some of the issues identified include:
  • Lack of delivery documentation
  • Date of delivery not listed
  • Missing or illegible signature of person accepting delivery
  • Designee relationship to beneficiary not documented
  • Incomplete description of the item(s) delivered
Suppliers are reminded that proof of delivery is one of the supplier standards as noted in 42 CFR, §424.57(12). Proof of delivery is required in order to verify that the beneficiary received the DMEPOS billed.  Proof of delivery documentation must be maintained in the supplier's files for seven years.
If the supplier delivers the DMEPOS directly to the beneficiary, a signed and dated delivery slip offers proof of delivery if it contains sufficient detail to identify the items and verify that they were correctly coded.  The delivery slip should list the beneficiary's name as well as the following information for each item delivered:
  • The quantity delivered,
  • A detailed narrative description of the item,
  • The brand name (manufacturer),
  • The model name or number (if applicable), and
  • The serial number (if available).
The date listed on the delivery slip should be the date the beneficiary or designee received the item.
When utilizing a shipping service or mail order, an example of proof of delivery is the service's tracking slip plus the supplier's own shipping invoice.  If possible, the supplier's records should also include the delivery service's package identification number for the package sent to the beneficiary.  The shipping service's tracking slip should reference each individual package, the delivery address, the corresponding package identification number given by the shipping service, and if possible, the date delivered.
Suppliers may also utilize a return postage-paid delivery invoice from the beneficiary or designee as a form of proof of delivery.  The descriptive information concerning the DMEPOS item (i.e., the beneficiary's name, the quantity, detailed description, brand name, and serial number) as well as the required signatures from either the beneficiary or the beneficiary's designee should be included on this invoice as well.
Regardless of the method used to document proof of delivery, the beneficiary or a designee must sign and accept delivery of the item(s).  Suppliers, their employees, or anyone else having a financial interest in the delivery of the item are prohibited from signing and accepting an item on behalf of a beneficiary.
The relationship of the designee to the beneficiary must be noted on the delivery slip (i.e., spouse, neighbor, etc.). The signature of the designee should be legible.  If the signature of the designee is not legible, the supplier (or the shipping service) should note the name of the designee on the delivery slip.

Claims for services which do not have proof of delivery or the proof of delivery is unclear will be denied and, in the case of post-payment reviews, any identified overpayments will be recovered.  Suppliers who consistently do not provide documentation to support their services may be referred to the OIG for investigation and/or imposition of sanctions.


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