In recent years, medical device credit payments have been closely examined by the Centers for Medicare & Medicaid Services, as many hospitals have been found non-compliant with reporting requirements. For instance, the Office of Inspector General released a report in 2018 highlighting more than 200 health systems in the United States that did not fulfill Medicare regulations for reporting cardiac device credits. Based on that information, Medicare contractors mistakenly paid providers $7.7 million for cardiac device replacement claims instead of about $3.3 million, if reported correctly.
To avoid compliance issues, organizations like Tufts Medical Center have established robust credit reporting processes and checkpoints internally. Tufts Medical Center is a 415-bed academic medical center in Massachusetts. HBI recently spoke with Maureen Cappola, director of cardiovascular center operations, about Medicare reporting processes for cardiac device credits at Tufts Medical Center and best practices that hospitals can adopt to be compliant.
Medicare Reporting at Tufts Medical Center
To track devices efficiently, Tufts Medical Center has an automated inventory management system that monitors supplies. Additionally, each device that comes into the hospital has an RFID sticker that helps in tracking the device within the hospital and also when the device is scanned to be used for a patient.
At Tufts Medical Center, most cardiac devices are implanted and explanted in the Electrophysiology Lab. The devices are tracked by Electrophysiology Lab technologists in a separate medical device tracking database. When a pacemaker or an implantable cardioverter-defibrillator is replaced, relevant information such as the patient’s admission date and demographic data, replaced device name, serial number, and cost of the device is recorded in the database – both for the old device and new device – for easy accessibility.
Once the patient receives a new device, the old device is sent to the manufacturer or vendor to be reviewed. If the old device is under warranty, the vendor may provide Tufts Medical Center with a device credit. Supply chain and accounts receivable team members validate device credits received from the vendor and record that information in the medical device tracking database. The billing team is then notified to re-issue a claim to Medicare, deducting the credit amount that Tufts Medical Center received for the replaced device.
“It’s a heavily administrative process involving interdepartmental coordination between compliance, supply chain, cardiovascular center administration, clinicians, and finance,” says Cappola, who oversees Medicare reporting for cardiac devices at Tufts Medical Center.
Cappola suggests that hospitals should appoint a point person to oversee Medicare reporting for device credits and ensure that all departments involved in the process capture and validate accurate information. She interacts with the leadership of compliance, billing, supply chain, and clinicians on a monthly or quarterly basis (depending on device credit volumes) to resolve concerns and monitor reporting performance. To improve Medicare reporting, Cappola also collaborates with cardiac device vendors and receives monthly reports on device credits.
Hospitals should be aware that it is pertinent to establish a Medicare reporting process for device credits and assign leadership positions to oversee processes that can aid organizations in being compliant. Identifying a single role to take ownership of this multidisciplinary effort is key to success.