Are you Billing Medicare Part B for Blood Glucose Testing Supplies and other items that are refilled on a recurring basis?
If you are, Medicare has some new rules and clarified some older ones. These apply to ALL suppliers, whether accredited or not.
Pharmacies are required to contact the beneficiary or designee regarding refills. This must take place no sooner than 14 calendar days prior to the refill due date and you may not dispense the item to the beneficiary sooner than 10 calendar days prior to the end of usage for the current product. This is regardless of delivery method.
Additionally, Medicare Compliance for refills requires a new prescription when:
- There is a change in the treating physician.
- There is a change in the item(s), frequency of use, or amount prescribed.
- There is a change in the length of need or a previously established length of need expires.
Medicare has also enacted new rules regarding “proof of refill request” for items that are going to be delivered to the beneficiary. We will see if the large mail-order entities follow this one. For these items, you need to document the request for refill either with 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.
The refill record must include:
- Beneficiary’s name or authorized representative if different than the beneficiary
- A description of each item that is being requested
- Date of refill request
- Quantity of each item that the beneficiary still has remaining
For the “proof of refill request” for items that are going to be picked up at the Pharmacy, the pharmacy only needs to obtain a signature from the beneficiary or caregiver that they have actually received the supplies.
This information (in addition to other Medicare required documentation) must be kept on file and be available upon request.
BE SURE to train your staff to make these requirements a part of their daily tasks.