DMEPOS Mini-Series #3 – Diabetic Test Strips

If you are a Medicare Part B supplier, then you have likely had an audit on diabetic test strips. Billing Medicare Part B is quite different than other payors, and consequently, can be very challenging for pharmacies. Being able to produce all the required documentation upon an audit, and making sure that the documentation meets Medicare Part B requirements, is a daunting task. Follow the tips below to be prepared in case of a test strip audit.

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Standard Written Order (SWO)  

The SWO must include the following six elements:

  • Beneficiary’s name or their Medicare Beneficiary Identifier (MBI)
  • Date of the order
  • General description of the item(s) – HCPCS code, a HCPCS code narrative, or a brand name/model number
  • Quantity to be dispensed
  • Practitioner’s name or NPI
  • Practitioner’s signature
  • While frequency is no longer a required order element, the SWO does require Quantity to be Dispensed for those items where more than one (1) item is dispensed or where dispensing occurs on a periodic basis (e.g., dressings, drugs, supplies, etc.). Note also that while the SWO has a limited number of required order elements, suppliers/providers are permitted to add elements that may provide clarity for issues such as length of need, frequency of use, dosage form/strength, refills frequency, etc.

Medical Records

  • Best practice would be to obtain medical records prior to billing to ensure:
    • A covered diagnosis
    • Testing frequency
    • Continued need and use
    • Signed by the treating practitioner


  • Bill only the “Medicare/Medicaid” version of strips
  • Verify the NDC being billed is for the correct package size
  • Attach the correct modifier whether patient is on insulin (KX) or not on insulin (KS)
  • Attach the “CR” modifier (catastrophe/disaster related) and “COVID-19” in the claim narrative if any of the following apply:
    • A signature is not able to be obtained on a proof of delivery
    • Clinical indications are not met for respiratory, oxygen, infusion pump and CGM
    • There is not a face-to-face in person encounter
    • Billing more than a 30 days’ supply for immunosuppressives, oral anticancer, IVIG and enteral nutrition

Dispensing/Proof of Delivery

  • Must include the following six elements:
    • Beneficiary name
    • Delivery address
    • Detailed description of the item(s)
    • Quantity delivered
    • Date delivered
    • Signature of beneficiary or representative
  • Date of delivery should match the date of service billed


  • When delivering or mailing test strips to Medicare beneficiaries, the pharmacy must have a proof of refill request (PORR) from the beneficiary or their representative which includes the beneficiary’s name, representative’s name and relationship to the beneficiary, item description and quantity left on hand
  • This ensures that the patient has exhausted their current supply and that the pharmacy is not auto-filling or auto-dispensing

Advanced Beneficiary Notice (ABN)

  • If you have reason to believe the strips will not be covered by Medicare, consider obtaining a signed ABN prior to dispensing
    • This allows the transfer of financial liability back to the patient in the event the claim is denied
    • Ensure the ABN is completely and appropriately filled out with a very specific reason Medicare may deny the claim
    • The ABN must be completed and signed on or prior to the date of service

Be sure to utilize all the tools and resources available on your local DME MAC website to ensure you are compliant with Medicare’s billing and documentation rules. Below are some past Newsline articles to help you comply as well:

Jennifer Ottman, CPhT