Transitioning from a facility to home can be challenging for Medicare beneficiaries and their families because there are many details, instructions, and changes to navigate. Pre-planning for reasonable and necessary DMEPOS for a beneficiary to use when he or she goes home may relieve some of that transition-tension. Beneficiaries can locate a supplier to deliver the covered item, fit the item (as necessary), and train the beneficiary on the item, up to two days before the beneficiary leaves the facility. Medicare payment to the supplier includes re-delivery of the item to the beneficiary’s home. Medicare rules allow delivery, fit, training, and re-delivery to prepare the beneficiary for a smoother transition from facility to home. Beneficiaries can research suppliers that will accommodate the pre-discharge process by using a zip-code to look-up the required item(s) at https://www.medicare.gov/medical-equipment-suppliers/.
The Conditions That Must Be Met for Pre-Discharge Delivery
The Centers for Medicare and Medicaid Services (CMS) presume that the pre-discharge delivery of DME or other item (prosthetic or orthotic, but not supplies) to a facility that does not qualify as a patient’s home, is appropriate when the following nine conditions are met, as stated in the Medicare Claims Processing Manual, Chapter 20, Section 110.3.1:
- The item is medically necessary for use by the beneficiary in the beneficiary’s home.
- The item is medically necessary on the date of discharge, i.e., there is a physician’s order with a stated initial date of need that is no later than the date of discharge for home use.
- The supplier delivers the item to the beneficiary in the facility solely for the purpose of fitting the beneficiary for the item, or training the beneficiary in the use of the item, and the item is for subsequent use in the beneficiary’s home.
- The supplier delivers the item to the beneficiary no earlier than two days before the day the facility discharges the beneficiary.
- The supplier ensures that the beneficiary takes the item home, or the supplier picks up the item at the facility and delivers it to the beneficiary’s home on the date of discharge.
- The reason the supplier furnishes the item is not for the purpose of eliminating the facility’s responsibility to provide an item that is medically necessary for the beneficiary’s use or treatment while the beneficiary is in the facility. Such items are included in the Diagnostic Related Group (DRG) or Prospective Payment System (PPS) rates.
- The supplier does not claim payment for the item for any day prior to the date of discharge.
- The supplier does not claim payment for additional costs that the supplier incurs in ensuring that the item is delivered to the beneficiary’s home on the date of discharge. The supplier cannot bill the beneficiary for redelivery.
- The beneficiary’s discharge must be to a qualified place of service (e.g., home, custodial facility), but not to another facility (e.g., inpatient or skilled nursing) that does not qualify as the beneficiary’s home.
CMS Identifies Coverage Dates of Pre-Discharge Delivery for DME, Prosthetics and Orthotics
For DMEPOS, the general rule is that the date of service is equal to the date of delivery. However, pre-discharge delivery of items intended for use upon discharge are considered provided on the date of discharge. The following three scenarios demonstrate both the latter rule (when the date of service is the date of discharge) and related exceptions.
- If the supplier leaves the item with the beneficiary two days prior to the date of discharge, and if the supplier, as a practical matter, need do nothing further to effect the delivery of the item to the beneficiary’s home (because the beneficiary or a caregiver takes it home), then the date of discharge is deemed to be the date of delivery of the item. Such date must be the date of service for purposes of claims submission. (This is not an exception to the general DMEPOS rule that the date of service must be the date of delivery. Rather, it recognizes the supplier’s responsibility – per condition five above – to ensure that the item is delivered to the beneficiary’s home on the date of discharge.) No one may bill for the days prior to the date of discharge.
- If the supplier fits the item to the beneficiary, or trains the beneficiary in its use while the beneficiary is in the facility, but thereafter removes the item and subsequently delivers it to the beneficiary’s home, then the date of service must be the date of actual delivery of the item, provided such date is not earlier than the date of discharge.
- If the supplier leaves the item at the facility and the beneficiary does not take the item home, or a third party does not send it to the beneficiary’s home, or the supplier does not otherwise (re)deliver the item to the beneficiary’s home on or before the date of discharge, the date of service must not be earlier than the actual date of delivery of the item, i.e., the actual date the item arrives, by whatever means, at the beneficiary’s home.
Facility Responsibilities During the Transition Period
- A facility remains responsible for furnishing medically necessary items to a beneficiary for the full duration of a beneficiary’s stay. The DRG and PPS rates cover such items.
- A facility may not delay furnishing a medically necessary item for the beneficiary’s use or treatment while the beneficiary is in the facility. A facility may not prematurely remove a medically necessary item from the beneficiary’s use or treatment on the basis that a supplier delivered a similar or identical item to the beneficiary for the purpose of fitting or training.
- A facility may not, through a stratagem of relying upon a supplier to furnish such items, improperly shift its costs for furnishing medically necessary items to a beneficiary who is a resident in the facility to Medicare Part B. Nevertheless, beginning two days before the beneficiary’s discharge, a facility may take reasonable actions to permit a supplier to fit or train the beneficiary with the medically necessary item that is for subsequent use in the beneficiary’s home. These actions may include the substitution of the supplier-furnished item, in whole or in part, for the facility-furnished item during the beneficiary’s last two inpatient days provided the substitution is both reasonable and necessary for fitting or training and the item is intended for subsequent use at the beneficiary’s home.
- For prosthetic and orthotic (P&O) items, the above restrictions apply to residents in a covered Part A stay. For DME, the above restrictions apply in a covered Part A or a Part B stay.
Planning for a safe and appropriate discharge from any type of inpatient facility (Acute Care Hospital, Long-Term Care Hospital, Inpatient Rehabilitation Facility, Inpatient Psychiatric Facility, Critical Access Hospital, Skilled Nursing Facility) to home is critical to ensure the transition success for Medicare beneficiaries. This includes having all the necessary equipment, prosthetics and/or orthotics available prior to discharge, properly fit, and with training completed on how to use the item completed, when possible.
For additional information and resources on this topic, see the CMS Medicare Learning Network article Medicare DMEPOS Payments While Inpatient (MLN#1541573) (cms.gov)
December 2, 2021 – K. Holt
 Id., pages 64-65.
 Id., page 65.