WASHINGTON, D.C. – As many of us are planning and taking vacations this summer, it is important to remember that Licensure Compliance for DMEPOS providers never takes a vacation.
Oftentimes during winter and summer vacations, our beneficiaries contact us about getting their supply refills that will fall into times that they may be away from their service address that is on file with Medicare. This is often the case with C-PAP and CGM supplies. Unlike pharmacy refills, we have a small window where beneficiaries are eligible for DME refills.
Pharmacies can request an exception for travel from the PBM for supplies that they provide after a bene contacts them to say that they will be away during a time they will need a refill. This “travel exception” can be made for both prescription meds and supplies.
Both the DME and pharmacy supplier need to be cognizant of the licensure requirement in each state. A supplier may not provide a product to a state where a license to provide that product in that state where they are not currently licensed, even though the beneficiary is already an established client. Additionally, the supplier must also be accredited to provide that product in that state.
In reviewing the licensure requirement for each individual state, the supplier starts with the DME Licensure Database Search on National Provider Enrollment West (NP West) website, (Palmetto GBA) at: https://dominoapps.palmettogba.com/palmetto/npewest.nsf/DID/P4LF7PNQM8?Open=. This licensure website is updated to cover all of the United Staes and the US territories. You simply click on the state in question and it brings up a page of all of that state’s information and whether a license is required for a specific product and the state department’s web addresses.
Anyone who has used this website in the past 20 years will tell you to start with the website but to confirm your information with the specific state licensure office. The state website for that office is listed on that page as the source of the information for that state site. Often the information has not been updated and may not have the correct listing as to which products do and do not require a state license. For example, you will find some states that do not require a license to provide CGM’s (categorized under Blood Glucose Monitors and Supplies) and other states that do require licensure.
There are some states (TX and PA) that do not have a state licensure requirement for DME, but you may find that some third-party payors (some Medicaids and Blue Cross plans) who have requirements for bricks and mortar (physical presence) in a specific state, although bricks and mortar are not a licensure requirement (for example MA). There are also states that require you have bricks and mortar in the state to obtain a DME license (for example GA), but there are exceptions to that requirement.
Make sure you are not providing supplies to beneficiaries who travel to another state where you are not currently licensed. If you have any questions or need help, please reach out to your DME attorney, who will confirm the requirements, or to a consultant who does.
Mary Ellen Conway is president of the Capital Healthcare Group, Washington, D.C.
