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David McGill Blogger

Proof of Delivery Requirements per Stephanie Morgan Greene, Esq.

Posted by David McGill | April 29, 2016

​During a recent webinar discussing prosthetic documentation, I discussed some of the most common mistakes I see with Proof of Delivery (POD) forms. The common error that seemed to raise the most question was the missing delivery address.  Many attendees had the same comment – I had no idea we needed the delivery address on the form!

The POD requirements are outlined in numerous places, including the Program Integrity Manual, the Supplier Manual and the Local Coverage Decisions (LCD).  The four DME MACs each independently issue their own Supplier Manuals, resulting in four manuals with slightly different set up and wording.  While the Supplier Manual language may be a little different between the four DME MACs, the LCD language is exactly the same, regardless of the jurisdiction.  For this reason, I am going to point to the LCD requirements to explain why the delivery address must be included on your POD form.

The LCD includes the following POD elements for deliveries made directly to the patient: Suppliers may deliver directly to the beneficiary or the designee. In this case, POD to a beneficiary must be a signed and dated delivery document.

The POD document must include:

  • Beneficiary's name
  • Delivery address
  • Sufficiently detailed description to identify the item(s) being delivered (e.g., brand name, serial number, narrative  description)
  • Quantity delivered
  • Date delivered
  • Beneficiary (or designee) signature

(emphasis added) The LCD requires the POD to list the "delivery address," which may not always be the patient's address.  For instance, if the patient comes to a supplier's location be fitted for an orthosis or prosthesis, the delivery address is the supplier's address, not the patient's address.  Or, if the device is delivered at the hospital for fitting and training within 2 days of the patient's anticipated discharge to home, the delivery address is the hospital's address, not the patient's address.

Many electronic POD forms have a section that says "Bill To" with an address, and another section listing "Delivered To" with an address.  We often see both sections with the patient's address listed as the Bill To and Delivered To address. The "Delivered To" section must list the address where the product was delivered.  The only time the Bill To and Delivered To address would be the same is when the item is delivered to the patient's home. If the item is delivered at your office, your address must be listed in the Delivered To section.

Some manual POD forms do not have a predefined place for adding the delivery address. The manual POD form often only has a section for patient name and address.  If you are using a manual, hand-written POD form that does not have a specific location for "Delivery Address" please make sure to add a label or identification of "Delivery Address" next to the address of the location where the item was delivered.

During my presentation, I had a follow up question from a few attendees asking if the Header or Logo which listed the supplier's address would be sufficient to meet the POD requirement.  Unfortunately, it generally is not sufficient.  If the item is delivered at your location as the supplier, the DME MAC is looking for your address to be identified as the delivery address.  The DME MAC does not consider the header or Logo as appropriately identifying your address as the delivery address.

As you review and possibly update your POD forms, please remember that the POD form does not change the Place of Service listed on your electronic claim.  If the patient is going to be using the DMEPOS item at his/her home, the Place of Service remains the patient's home, or 12.  The delivery address on the POD form is not required to match the place where the patient will use the device.

Stephanie Morgan Greene, Esq.​
The Audit Team
Cell: 330-209-4543

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