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January 31, 2022

Reminders for Recalled Equipment Usage and Billing

This article provides reminders for suppliers when equipment is no longer being used by the beneficiary or in the case of recall, has been submitted for repair or replacement.

Billing for equipment or supplies not being used by a beneficiary is inappropriate billing. It is the supplier’s duty to ensure that equipment is being used before billing for the monthly rental.

In addition, before sending supplies to a beneficiary, the supplier must meet the refill requirements, as outlined below:

  • For items that the beneficiary obtains in-person at a retail store, the signed delivery slip or a copy of the itemized sales receipt is sufficient documentation of a request for refill.
  • For items that are delivered to the beneficiary, documentation of a request for refill must be either 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. A retrospective attestation statement by the supplier or beneficiary is not sufficient.

The refill record must include:

  • Beneficiary’s name or authorized representative if different from the beneficiary,
  • A description of each item that is being requested,
  • Date of refill request,
  • For non-consumable supplies i.e., those more durable items that are not used up but may need periodic replacement (e.g., PAP and RAD supplies) the supplier must assess whether the supplies remain functional, providing replacement (a refill) only when the supply item(s) is no longer able to function. The supplier must document the functional condition of the item(s) being refilled in sufficient detail to demonstrate the cause of the dysfunction that necessitates replacement (refill).
  • For consumable supplies i.e., those that are used up (e.g., ostomy or urological supplies, surgical dressings, etc.) the supplier must assess the quantity of each item that the beneficiary still has remaining to document that the amount remaining will be nearly exhausted on or about the supply anniversary date.

This information must be kept on file and be available upon request.

Lastly, suppliers are reminded that once the machine has been repaired or replaced, monthly rentals will resume, but a new capped rental period will not begin. This period of non-usage is considered a break-in-billing.


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