The Typical Points of Failure for Reporting Medical Device Credits

SpendMend Team

Written By: Joe Heminger, Business Development Manager

The Office of Inspector General (OIG) performed a review of cardiac device credits to determine whether hospitals complied with Medicare requirements for reporting manufacturer credits associated with recalled or prematurely failed cardiac devices.

For every 3,233 of the 6,558 Medicare claims that were reviewed, hospitals likely did not comply with Medicare requirements associated with reporting manufacturer credits. That equates to a 49.3% rate of non-compliance.

The following list outlines the typical points of failure:

  1. Clinical Areas Product Collection

    • – Device discarded or given to the patient​
    • – Device improperly cleaned/sterilized​
    • – Device not recognized as requiring return​ under the warranty program
    • – Vendor rep wrongly indicates that the item is not under warranty
    • – Vendor rep takes the device and fails to properly initiate a claim​
    • – Non-standard workflows​

  2. Shipment Process

    • – Vendor box or kit used, but tracking number not captured​
    • – Vendor rejects item because it is past the 30-45-day return window for warranty
    • – Return Merchandise Form not completed

  3. Vendor Process

    • – Vendor unable to obtain sufficient information
    • – Device evaluation not requested​
    • – Product analysis report not requested​
    • – Vendor never processes warranty claim​

  4. Credit and Finance Process

    • – Patient name and device serial number not documented
    • – Credit memo is not detected as explant​ and applied to the outstanding invoice
    • – 50% rule not calculated correctly​
    • – Explant returns and credits not reconciled​
    • – Patient Accounts never notified of credit received​
    • – Patients claim not adjusted via the UB-04

For insights and advice on how to address these typical points of failure and construct a fully compliant process for reporting manufacturer device credits – contact SpendMend today.

Why Is Your Process For Reporting Medical Device Credits Falling Short?

SpendMend Team

Written by: Joe Heminger, Business Development Manager

So, why is your process for reporting medical device credits falling short?
The Office of Inspector General (OIG) performed a review of cardiac device credits to determine whether hospitals complied with Medicare requirements for reporting manufacturer credits associated with recalled or prematurely failed cardiac devices.
In November 2020 OIG issued a report detailing that for every 3,233 of the 6,558 Medicare claims that were reviewed, hospitals likely did not comply with Medicare requirements associated with reporting manufacturer credits for recalled or prematurely failed cardiac medical devices.
OIG concluded that hospitals would continue to struggle with compliance because of the following consistent areas of difficulty:

  • Billing Systems – Health billing systems are not consistently updated to reflect the changes from 2014 regarding new condition and value codes. Hospitals that have made updates to their systems are not using the code when updating the UB-O4 on original or resubmitted claims.
  • Lack of Written Policies and Procedures – Health systems either have inadequate or non-existent written policies and procedures or do not enforce the current policies that are in place.
  • Insufficient Communication – Health systems suffer from a lack of interdepartmental communication when receiving reportable claims. The audits show that hospitals are submitting25% of the credits on time from the original claim and 81% on the 90-day resubmission.
  • Inadequate Compliance Testing – Health systems lack internal resources and/or expertise.  In addition, they are far too inconsistent at collecting the data both from the facility and the vendors.
  • Vendor Involvement – Health systems relied upon the vendor to manage the device return and credit process which resulted in gaps.

For insights and advice on how to address these common areas of failure and construct a fully compliant process for reporting manufacturer device credits – contact SpendMend today.