Your DME: Where & When

I remember passing a sign along the highway in a very rural part of a southern state many years ago. It advertised an antique shop “a mile from the highway at the next exit in the big red barn”. No name, no address, no hours of operation. Just a promise that if you hop off the highway at the next exit and drive a mile, you can’t miss it. I didn’t try to find it, and I most likely would have been able to if I tried, but it struck me as kind of short sighted on the part of the proprietor to not list more specific information to guide the potential customer to their shop.If you own a DME that does business with CMS, you’ll need to be more specific than that when it comes to identifying where your company is located and when its open for business. Medicare requires, through their DMEPOS SUPPLIER STANDARDS, specificity with regards to where your store is located and when its open.

The Supplier Standards, which serve as a base of rules for DME organizations, list thirty requirements, which are essentially law and regulation for anyone that wants to do DME business with CMS. Let’s look at a few that outline requirements for your location and when its open for business.

Supplier Standard 7: A supplier must maintain a physical facility on an appropriate site and must maintain a visible sign with posted hours of operation. The location must be at least 200 square feet and contain space for storing records. So, yes, there is a minimum number of square feet; a minimum size requirement. Specific guidance in the expanded standards states that the store/branch/DME must be accessible and staffed during posted hours of operation. They also specify that the sign is visible and in plain view.

Supplier Standard 29: A supplier is prohibited from sharing a practice location with other Medicare providers and suppliers. This requirement prevents DME organizations from operating in the offices of other Medicare providers. For instance, a DME cannot operate in the corner of a sleep lab—at least if they are billing Medicare. Some exceptions are noted in the expanded standards. Exceptions include physician offices whereby the practice provides DMEPOS (for instance, an orthopedic surgeon providing orthotic braces) and also PT and OT clinics, which sometime provide DMEPOS from the clinic.

Supplier Standard 30: A supplier must remain open to the public for a minimum of 30 hours per week except physicians, physical or occupational therapists, or a DMEPOS supplier providing custom made orthotics and prosthetics. The DME can choose what days/hours to open for business, but the minimum number of hours open per week is consistent and companies must adhere to the requirement that they are open at least 30 hours/week. The same exceptions listed in Standard 29 are in place here: exceptions for physicians, PT/OT clinics, and providers of custom orthotics and prosthetics.

These are important requirements which Medicare makes all new providers aware of at the time they apply for any Medicare numbers. And because it’s a Medicare requirement, your accrediting body will enforce the requirement as well. Be sure to pay close attention to the standards and do a deeper dive by reviewing the expanded standards. They are available to review here:

https://www.cms.gov/medicare/provider-enrollment-and-certification/medicareprovidersupenroll/downloads/dmepossupplierstandards.pdf

The general (quick version) of the standards are available here:

https://dominoapps.palmettogba.com/palmetto/providers.nsf/files/DMEPOS%20Abbreviated%20Supplier%20Standards.pdf/$FILE/DMEPOS%20Abbreviated%20Supplier%20Standards.pdf

The supplier standards are fairly straightforward requirements. However, some companies struggle with compliance.

The two biggest issues of noncompliance with these specific guidelines include:

• Signage that does not comply with the standards. When organizations move into an industrial park or business complex, it can be cumbersome to place adequate signage. Some companies miss the fact that a phone number and the hours of operation need posted as well. Also, some companies are under the false impression that they are exempt if the location is not open for retail business.
• No staff available during posted hours of operation. Several times each quarter, a Medicare inspector (or an accreditation agency surveyor) shows up at a location for a visit during posted hours of operation and finds no one home. This is a serious issue that can cause the loss of Medicare billing privileges.

When opening a new business or branch, think through the location. In terms of size, does it comply with the standard? Will it be possible to post adequate signage with the company name and address, a phone number, and hours of operation. And importantly, can you staff the location during the posted hours of operation?

Besides being an absolute requirement, these particular standards are “good business” as well as regulatory rules. Think of a business that doesn’t list their hours of operation or what days they are open. Think of a place that doesn’t have signage and how frustrating finding those places can be. Adhere to the requirements because you want to follow the rules, but also because it just plain makes sense.