decisionhealth Newsletters, Coder Pink Sheets - 2009 Issue 10 (October)
Take stock of your DME ‘consignment closet’ deals
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Article Overview
This article reviews upcoming Medicare policy changes for practices that keep durable medical equipment in a consignment closet or stock-and-bill setup. It is relevant to physicians, practice managers, and billing staff who need to understand the general compliance impact of CMS transmittals, DME supplier enrollment, surety bond requirements, and related Stark law considerations. The article also notes the distinction between Medicare and privately insured patients and points readers to official CMS resources.
Why This Topic Matters
Practices that rely on consignment-style DME arrangements may need to adjust business operations, billing workflows, and compliance processes to remain aligned with Medicare requirements. Understanding the broad scope of these changes helps organizations assess whether to enroll as suppliers, discontinue certain arrangements, or separate Medicare from private-pay workflows.
Article Sections
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Overview of consignment closet changes
Introduces the Medicare policy shift affecting practice-based DME stock arrangements and the general compliance implications for medical practices.
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CMS transmittals and effective date
Summarizes the CMS communications referenced in the article and identifies the implementation timeframe discussed.
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Supplier enrollment and operational requirements
Describes the broad administrative and operational hurdles practices may face if they continue offering DME under Medicare.
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Stark law and in-office ancillary considerations
Reviews the article’s discussion of physician self-referral concerns and the categories of items addressed in that context.
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Private insurance and Medicare alternatives
Notes the distinction the article makes between handling privately insured patients and Medicare patients under these arrangements.
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Official resources
Lists the CMS reference materials cited at the end of the article for further review.
What You Will Learn
- The general Medicare compliance issues surrounding practice-based DME inventory arrangements
- How CMS transmittals are used to communicate policy changes affecting DME workflows
- Why practices may need to reassess supplier enrollment and related operational requirements
- How the article frames Stark law considerations for in-office ancillary services
- What distinction the article draws between Medicare and privately insured patients
Who Should Read This
- Physicians
- Practice managers
- Medical billing staff
- Compliance personnel
- Durable medical equipment suppliers
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