Device credits

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.

--Anonymous NAHRI member


  • 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 and I suggest working with your accounting department, as they are sometimes notified of the credit as well as the clinical areas (cath lab, operating room).  I also recommend putting this 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 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 these timely and accurately.
  • I was shocked to see a compliance officer suggest that the questioner not look for these device credits. That's absurd and sad. 
  • We have recently engaged with a vendor to help us manage this topic since we weren't always informed from the vendor.  This has also resulted in areas of additional billing from their findings. The regulations puts the burden on the provider to initiate the credit to Medicare, regardless of the vendor communication.
  • I am a new director to my facility and just implemented this. This is a big to do lots of education needed in the surg departments, coding, and to the billers. There was an OIG audit I guess that sparked this. There is also a FAQ from CMS out there that is helpful.
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