The Typical Points of Failure for Reporting Medical Device Credits

Written By: Joe Heminger, Business Development Manager

The Office of Inspector General (OIG) performed a review of medical 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 for reporting medical device credits:

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 medical device credits – contact SpendMend today.