Compliance Blog - R.J. Hedges & Associates

Who should have a DMEPOS Compliance Program in place?

[fa icon="calendar'] Mon, Oct 15, 2018 / by Becky Templeton


Sometimes life isn’t as easy as we hoped it would be. An accident, illness, or injury can happen resulting in the need for extra products and services for our patients to lead their daily lives.  For patients requiring these devices, they can rest assured knowing a local community provider is available to help them with their particular needs.  In today’s blog, we will discuss why having a DMEPOS compliance program is important, things you can do to get started, examples of other people who thought they didn’t need to have all their DME items in place and the issues they got into and some solutions to help keep your sanity while juggling all the items needed to bill Medicare for DMEPOS items.

3_ Who should have a DMEPOS compliance program in place_ _ Jenny Schell _ R.J. Hedges & Associates

How compliant is your pharmacy? Take our DMEPOS Compliance Assessment

Because Medicare is so heavily regulated, it is necessary for providers to have a DMEPOS compliance program in place that matches up with the CMS Supplier Standards.  Once you achieve a status that you can bill Medicare, you have to ensure all your support documents are 100% correct; if not, you will lose every audit, every time. 

Pharmacies that have been accredited for at least 5 years and are billing 5% or less of total sales of DME items are eligible for a classification known as exemption.  While some would think they are exempt from the rules, they are only exempt from the accreditation requirement. So, even if you have achieved exemption status, you still need to have a DME compliance program in place.

Do It Yourself (DIY) Compliance

To create your own DMEPOS program, you need to juggle a few items at the same time: 

  • Decide what items you wish to bill Medicare, making sure there is a need in your community and you have facilities and employees to store, dispense and deliver.
  • Determine what training is needed and if licensed personnel is required
  • Pick an Accreditation Organization and find out what they require for their application and on-site survey.
  • Establish Policies & Procedures, create several forms to use with your patients and have some extra items in place which we will outline shortly.
  • Submit an application to the Accreditation Organization of your choice including all the items you hope to dispense and bill to Medicare (commodes, off the shelf braces, ostomy supplies, etc.).
  • Prepare for an on-site survey by your Accreditation Organization.
  • Complete your CMS-855S application and gather all necessary support documents but DO NOT submit until you have received your accreditation certificate.

So now that you have about 6 items you are juggling, I’ll assume that you received your Accreditation Certificate, were awarded a PTAN and are ready to start dispensing - Congrats!

Getting Started

Now the tough part starts.  If you are a pharmacy, pharmacy language and pharmacy process will not work when dispensing DMEPOS products.  This also includes Part B Meds.  The staff must understand that the paperwork and the process are different.  For example:

  • You no longer have a PBM to work through; you have a DME MAC Region
  • The governing rule is called a Local Coverage Determination or LCD
  • A prescription or eScript is now a Detailed Written Orders or DWO
  • Part B Meds dosage requirements may not match your quantity, and you will need to bill differently, for example:
    • A doctor orders 2 mg BID; however, the LCD requirement is 1 mg
    • The solution to be paid: 1mg x2 BID
Who is going to keep all your files updated (or up-to-date) with changing Supplier Standards and modified LCD’s?  Are you confident you’re dispensing and billing practices will be 100% to ensure you are getting your full reimbursement?  What’s the worst case scenario for not doing these things? 

The hardest thing with Medicare Part B billing is knowing:

  • What are the correct documents needed, i.e., Detailed Written Order (DWO) or Written Order Prior to Delivery (WOPD)
  • Physician clinical notes requirements, if necessary
  • What the dispensing requirements are
  • What is the correct documentation the patient must receive
  • What is signed and returned
  • What the patient must keep
  • How to bill and when does the billing actually occur
  • How to maintain the documentation.

When it comes to Medicare Part B and DMEPOS products, no truer words have ever been spoken than the adage “the Devil is in the Details”.  If you’re not sure of your “juggling skills”, but wish to get some help establishing a program or revamping an existing program, the R.J. Hedges & Associates DMEPOS program is designed to fit the needs of any pharmacy or DME facility that is offering DME products. Our program ensures that you have what you need to meet the Medicare requirements and have support documents like streamline Proof of Delivery, DWO's, WOPD, Intake Forms, Assessments, Plan of Care and many more.  We will also complete all your Medicare applications and can help with your exemption application.

To test how you are currently doing, feel free to take our DMEPOS Compliance Assessment to see areas you are excelling or areas that may need improvement.

How compliant is your pharmacy? Take our DMEPOS Compliance Assessment


Video Clip: Full Transcript

Topics: DMEPOS

Becky Templeton

Written by Becky Templeton

Becky is a Board Certified DME Specialist and Accredited Business Intermediary. Her education and training background fuels her desire to understand how things work, while trying to get the simplest answers and best methods for implementation. She is the go to woman for R.J. Hedges’ training and the voice of many of our videos.

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