Q&A: Self-reporting device credits

Wednesday, April 18, 2018

Q: Over the last few weeks, there have been quite a few articles in various newsletters about device credits. I’m not sure we have the best process in place to identify recalls and under-warranty replacements so I took a look. In the first account I reviewed, I found an item from a St. Jude recall. When I shared my findings with my compliance officer, the response was, “Why are you looking?”

Should I not look? I always thought it was better to self-report these issues than to let Medicare find them.


A: Device credits are always a hot topic. Yes, you should look and, yes, they should be billed and reported properly from both a compliance and billing standpoint. These can be difficult to monitor due to the lag that can happen with receiving the credit. I suggest working with your accounting department as they are sometimes notified of the credit as well as the clinical areas (e.g., cath lab, operating room). I also recommend putting device credits on an annual internal compliance audit to ensure all credits that were received are accounted for as a device replacement as required by Medicare and to make any necessary adjustments to the bills. It is highly suggested that you develop internal policies and procedures outlining the device recall process. This will assist in standardizing the process and involve all those that have a hand in the device replacement notification. Your thoughts are correct that it is better to self-report than to have Medicare audit. It is not an easy task and not everything will qualify as a replacement, but it is better to be as proactive as possible to capture device credits timely and accurately.

Note: This question can be found in the reimbursement & payment methodologies section on the NAHRI Forums where you can find answers to questions on a variety of topics from billing and claims to compliance to reimbursement. This question was answered by Lisa Longo, CPC, CPC-I, revenue cycle analyst, Middlesex Hospital, Middletown, Connecticut.