CMS Updates Compliance Standards for Consignment Closets and Stock Bill Arrangements
Recently the Centers for Medicare and Medicaid Services (CMS) released Change Request 6528a outlining guidelines for durable medical equipment, orthotics, prosthetics and supplies (DMEPOS) that are maintained at a location owned by a physician or non-physician practitioner with a purpose to distribute products to Medicare beneficiaries. Suppliers involved in these arrangements, commonly referred to as consignment closets or stock/bill arrangements are required to meet current standards. CR 6528 also details additional guidelines for these arrangements that are included in the Program Integrity Manual (PIM), chapter 10, section 21.8.
Effective March 1,2010, Medicare will allow enrolled suppliers to maintain inventory at a practice location or a physician or a non-physician practitioner when the following conditions are met.
- The title to the DMEPOS shall be transferred to the enrolled physician or non-physician practitioner’s practice at the time the DMEPOS is distributed to the beneficiary
- The physician or non-physician practitioner’s practice shall bill for the DMEPOS supplies and services using their own enrolled DMEPOS billing number.
- All services provided to a Medicare beneficiary concerning fitting or use of the DMEPOS shall be performed by individuals being paid by the physician or non-physician practitioner’s practice, not by any other DMEPOS supplier.
- The beneficiary shall be advised that, if they have a problem or questions with the DMEPOS, they should contact the physician or non-physician practitioner’s practice, not the DMEPOS supplier who placed the DMEPOS at the physician or non-physician practitioner’s practice.
For more information, suppliers can read the MLN Matters article in its entirety at www.cms.hhs.gov/MLNMattersArticles/downloads/MM6528.pdf.