Can anyone help me find or clarify the rules concerning P.O.L. since the 2006 change? I say we have to have proof on file that we have sent one out on all rental items no matter what. Other people in the office argue that it only applies to people before the 2006 option. I have looked in my Medicare guidelines and am only finding rules for the people set up before 2006. Help please!
Since there is no option - you don't have to send them out. However, I if
Medicare pays a site visit to you - one of the things they usually ask to
see is your POL (which we had a site visit 2 years ago and they did ask to
see it) - but it is more because they haven't updated the things they ask to
see since the change in 2006 (typical). It is easier just to have one you
can print out and show them rather than argue the necessity of it. The
policy only refers to the need for items provided before the date of the
change.
I agree with Heather. I have had two visits in the past two years from Medicare (Moved locations) and they asked to see this also. Just have a copy to give them when they stop by and if necessary put something on a check sheet the patient signs.
What the site surveyors are probably supposed to see evidence of is your
notice to patients that they have the right to rent or purchase Inexpensive
or Routinely Purchased (IRP) items (like walkers, canes, etc.)
To meet this requirement every line on our delivery ticket has a place for
us to circle Sale* or Purchase. Then below the equipment list we have a
line that says:
* I understand that Medicare will pay for the rental or purchase of these
items, however I am choosing to have Medicare purchase these items for me.
Since there is no option - you don't have to send them out. However, I if
Medicare pays a site visit to you - one of the things they usually ask to
see is your POL (which we had a site visit 2 years ago and they did ask to
see it) - but it is more because they haven't updated the things they ask to
see since the change in 2006 (typical). It is easier just to have one you
can print out and show them rather than argue the necessity of it. The
policy only refers to the need for items provided before the date of the
change.
Heather, how are you handling capped rental items for which there is not a purchase/rental option? For example, a pump used for chemotherapy that is in continuous use by a patient for 13 months is supposed to have an automatic title transfer to the patient at 13 months...Are agencies truly just giving away their pumps at that time?
Simple answer - yes. It is really a rent to own, so not really "giving" it
away. It isn't like there is a choice - Capped rental items don't have a
purchase option because they are automatically considered purchased after 13
payments. You must notify the patient that ownership of the equipment has
been transferred to them as of the 13th month. I do not have ANY experience
with Chemo Pumps - but this is the rule on the capped rental items we do
provide (i.e., w/c's, beds, patient lifts, etc.) Hope that helps!
Heather
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You're right..."giving" is a poor choice of words.
I suppose I think of it that way because it seems more appropriate and logical for the provider to simply stop billing that particular patient at 13 months, but then proceed to use that same pump (after patient finishes chemo eventually) on subsequent patients, thereby precluding the need for replacing the pump in my inventory.---this would serve Medicare's intention of not paying past 13 months.
I suppose it is not constructive to "wish" Medicare was more practicle in this regard
Your input does help Heather. Thanks!
__________________
Keith Jackson, PharmD
Supervisor
Parkview Home Infusion Services
Fort Wayne, IN
Did you say LOGICAL and PRACTICAL!? lol I'm sure you already read this..
but here is the "official" info:
Initial rental month on or after January 2006:
Section 5101(a) revised the payment rules for capped rental DME. In
accordance with the DRA, after 13 months, the beneficiary owns the capped
rental DME item, and after that time, Medicare pays for reasonable and
necessary maintenance and servicing (i.e., for parts and labor not covered
by a supplier's or manufacturer's warranty) of the item. The beneficiary may
not, as in years past, choose to continue to rent the item and leave the
supplier with the title to the item. You must follow applicable state and
federal laws when transferring the title for the item to the beneficiary.
This transfer must occur on the first day after the last rental month.
This provision does not affect parenteral (or enteral) nutrition (PEN)
pumps, because PEN is not considered to be capped rental DME, but rather is
covered under the prosthetic benefit.
You say, "You must notify the patient that ownership of the equipment has
been transferred to them as of the 13th month." So, I do need to send something out and have something on record? This is what I was originally referring to. I could have sworn, that no matter what, a letter had to be sent.
Yes, my understanding is that it is mandatory to notify a patient (who has paid the 13 months of rental on a capped item) that the title has been transferred to them. Not an option for capped rental items. But, Medicare has made it clear that the patient may do whatever she wishes with that equipment at that time. I've been wondering if that might include "sell it back to the infusion provider" since most patients are not likely to even want a pump that they are "finished using". Also, what sort of provider would even consent to use an "old" pump some time in the future, from a previous provier..the patient has been storing it and not likely maintaining it. This is my current puzzle!
Thanks.
__________________
Keith Jackson, PharmD
Supervisor
Parkview Home Infusion Services
Fort Wayne, IN
Purchase Option Letters
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