Facility-side Part B supply billing is legal. Here is the regulatory proof.
If someone has told you that billing Medicare Part B for supplies under your facility's own NPI (your Medicare billing number) is complicated, risky, or a gray area — that information is wrong. The statutory authority has been in place since the late 1990s. CMS has operationalized the billing pathway. Burst helps your facility use it.
Pay-for-results fee structure, disclosed in full before you sign. If Burst doesn't collect, Burst doesn't get paid.
HIPAA BAA · 42 CFR 411.15(p)(2) · CMS Pub. 100-04 · LCD-compliant documentation
- Authorized by statute since 1997
- Audit-defensible documentation
- HIPAA BAA included
Facility-side Part B supply billing is authorized by 42 U.S.C. § 1395x(s) — the statute that defines prosthetics, orthotics, and supplies (POS) as a covered Medicare benefit. CMS Pub. 100-04, Ch. 7, § 10 operationalizes the billing pathway under the facility's own NPI. Consolidated billing rules introduced in the Balanced Budget Act of 1997 were designed to put the facility in control of this pathway.[42 CFR 411.15(p)(2)] The question has never been whether the right exists. The question is whether your documentation is in place to exercise it.
The four statutes and CMS provisions that authorize this billing model.
Each of the following citations is publicly verifiable. Compliance officers are encouraged to pull the source documents directly.
Defines prosthetics, orthotics, and supplies (POS) as a covered Medicare Part B benefit. This is the statutory foundation for the entire billing pathway. Ostomy supplies, catheters, wound care, and enteral nutrition are POS — not DME.
The consolidated billing exclusion that permits SNFs to bill Medicare Part B for POS supplies under the facility's own NPI. This is the specific regulatory carve-out that makes facility-side billing possible and legally distinct from DME billing.
The CMS Medicare Claims Processing Manual provision that operationalizes the Part B supply billing pathway. It specifies how claims are submitted, which MAC processes them, and what documentation is required to support each claim.
Introduced consolidated billing for SNFs and established the framework that was always intended to put the facility in control of Part B supply billing. The external supplier model that grew up around it was never the intended arrangement — it was a workaround that diverted facility reimbursements to third parties.
Medicare Part B already covers these supplies. Burst makes sure your facility is the one getting paid for them.
Three questions determine whether a claim is billable.
Every Part B supply claim follows the same eligibility logic. If all three conditions are met, the claim is supported. This is the decision framework Burst applies to every resident in your facility.
Is the resident in a non-Part A status?
Part B supply billing applies to residents who are not currently in a covered Part A stay. This includes residents on a Medicare Advantage plan, residents on a standalone Part B plan, and residents in a custodial or long-term care status. Consolidated billing rules do not apply to these residents for POS supplies.[42 CFR 411.15(p)(2)]
- No active Part A skilled nursing stay
- Medicare Part B coverage confirmed via eligibility verification
- Resident is receiving the supply as part of ongoing clinical care
Is the supply classified as POS — not DME?
The statutory classification controls the billing pathway entirely. Prosthetics, orthotics, and supplies (POS) are consumable items — used up in days to months — that replace or support a body function. They are billed to the A/B MAC under the facility's NPI. Durable medical equipment (DME) is reusable, has a lifespan greater than three years, and is billed to the DME MAC under a separate supplier number. Burst does not bill DME.[42 U.S.C. § 1395x(s)]
- Supply is consumable with a lifespan measured in days to months
- Supply replaces or supports a body function (prosthetic definition)
- Supply is covered under an applicable LCD (Local Coverage Determination)
Is the documentation complete?
A billable claim requires three documentation layers working together. Medical necessity must be established in the clinical record. A Standard Written Order (SWO) must be signed by the ordering physician. Proof of delivery must confirm the supply reached the resident. When all three are in place, the claim is supported and audit-defensible.[CMS Pub. 100-04, Ch. 7, § 10]
- Medical necessity documented in the clinical record
- Standard Written Order (SWO) signed by the ordering physician
- Proof of delivery confirming supply reached the resident
- LCD coverage criteria met for the specific supply category
The most common misunderstanding in Part B supply billing.
Many facilities — and many Part B supply companies — categorize ostomy pouches, catheters, and wound dressings as durable medical equipment. They are not. The classification matters because it controls the billing pathway, the MAC that processes the claim, and the compliance framework that applies.
Durable Medical Equipment
Equipment that can withstand repeated use, has a lifespan greater than three years, and is primarily used for a medical purpose. DME is billed to the DME MAC under a separate supplier number — not under the facility's NPI.
- Wheelchairs and power mobility devices
- Hospital beds and pressure-reducing mattresses
- Oxygen concentrators and CPAP machines
- Walkers, crutches, and canes
Prosthetics, Orthotics & Supplies
Consumable items that replace or support a body function. POS has a lifespan measured in days to months — used up in the course of clinical care. Billed to the A/B MAC under the facility's institutional NPI.
- Ostomy pouches and accessories
- Urinary catheters and drainage bags
- Wound care dressings and compression
- Enteral nutrition and feeding supplies
- Tracheostomy supplies
Why this matters: A catheter for a resident with permanent urinary incontinence is not equipment — it is a prosthetic device replacing normal bladder function. The statutory classification under 42 U.S.C. § 1395x(s) controls the billing pathway entirely. When Part B supply companies bill these items as DME under a separate supplier number, they are using the wrong billing pathway and removing the reimbursement from the facility that provided the clinical care.[42 U.S.C. § 1395x(s); 42 CFR 411.15(p)(2)]
Burst's model reduces waste and fraud by design — not by policy.
The external Part B supply company model has produced some of the highest improper billing rates in Medicare. That is not an accident — it is a structural outcome. Burst's model produces structurally different results for the same reason.
Retroactive billing eliminates waste
Burst bills retroactively — after supplies have been used and documented. There is no pre-shipment, no auto-refill, no inventory padding. Each claim follows an existing clinical record, so the workflow is structured to avoid the phantom-claim patterns that drive improper payment rates.
Documentation alignment reduces fraud
As facilities work through the Burst process, documentation practices improve progressively. Clinical records, SWOs, and proof of delivery become more consistent over time. The compliance posture strengthens with each billing cycle — not just at intake.
Facility-side billing is better for CMS
The facility has direct clinical visibility into what was used, by whom, and when. An external supplier billing remotely does not have that visibility. This is the structural reason why external supplier improper billing rates are so much higher — and why CMS's CRUSH initiative is targeting that model, not the facility-side model.
That is the improper billing rate CMS documented for external Part B suppliers in skilled nursing settings. The facility-side model Burst uses does not produce that outcome — because it cannot. The billing follows the documentation, not the other way around.
Find out what your facility is leaving on the table. Most of the work in this process happens inside Burst — not inside your business office.
Request a Compliance ReviewWhat happens when a claim is reviewed or audited.
An audit is not a crisis when the documentation is in place. Burst builds the audit defense into the billing process — not as an add-on, but as a structural requirement for every claim submitted.
Medical Necessity
Every claim is supported by a clinical record that establishes medical necessity for the specific supply. The record must reflect the resident's diagnosis, the clinical indication for the supply, and the ordering physician's clinical judgment.
- Diagnosis codes aligned to LCD coverage criteria
- Clinical notes reflecting ongoing need
- Physician documentation of medical necessity
Standard Written Order
A Standard Written Order (SWO) signed by the ordering physician is required for every supply category. The SWO must specify the supply, the quantity, and the duration of need. Burst reviews SWO completeness before submitting any claim.
- Physician signature and date confirmed
- Supply description and quantity specified
- Duration of need documented
Proof of Delivery
Proof that the supply reached the resident is required for every claim. For facility-administered supplies, this is typically the medication administration record (MAR) or the supply dispensing record. Burst verifies this documentation before billing.
- MAR or dispensing record reviewed
- Supply usage confirmed against clinical record
- Delivery date aligned to billing period
Burst Handles the Response
If a claim is selected for review — RAC, CERT, or MAC medical review — Burst prepares and submits the documentation response. Your business office does not need to manage the audit process. Burst's billing team handles it from the initial request through final determination.
- ADR (Additional Documentation Request) response prepared by Burst
- Redetermination and reconsideration filed if needed
- Facility staff involvement: minimal
“At first, I was skeptical — this sounded too good to be true. What changed my mind was how clearly they explained the compliance side. They made something that felt risky actually feel very controlled and legitimate. Our internal team didn't have the bandwidth for this, and they filled that gap seamlessly. Now it's just part of how we think about revenue optimization.”
Supply categories Burst bills, the applicable LCDs, and the billing pathway.
Local Coverage Determinations (LCDs) define the coverage criteria for each supply category. Every claim Burst submits is reviewed against the applicable LCD before submission.
| Supply Category | Classification | Applicable LCD | Billing MAC | Coverage Status |
|---|---|---|---|---|
| Ostomy Supplies | POS | L33820 | A/B MAC under facility NPI | Covered |
| Urological Supplies (Catheters) | POS | L33822 | A/B MAC under facility NPI | Covered |
| Surgical Dressings (Wound Care) | POS | L33828 | A/B MAC under facility NPI | Covered |
| Enteral Nutrition & Supplies | POS | L33829 | A/B MAC under facility NPI | Covered |
| Tracheostomy Supplies | POS | L33831 | A/B MAC under facility NPI | Covered |
The people behind Burst have spent their careers inside this industry.
Burst was founded because its founder watched Part B supply companies divert reimbursements that belonged to nursing homes — and decided to build a model that corrected it. The three founding executives bring more than 50 years of combined experience in senior care.
Years of combined senior care experience across the three founding executives
Years of long-term care experience for the founder, beginning as a nursing aide and medication aide
States where Burst currently operates, with active expansion underway
Started as a nursing aide and medication aide in long-term care. Moved to the vendor side, working with some of the largest diagnostic companies in senior care. Founded Burst after seeing firsthand how Part B supply companies were diverting reimbursements that belonged to the facilities providing the clinical care.
Spent his career at the two largest vendors in the senior care space. Previously served as Director of Marketing at a skilled nursing facility. Brings a direct understanding of how both the vendor side and the facility side of this relationship operate.
A licensed nursing home administrator. Understands compliance, operations, and regulatory requirements from the inside — not from a billing company's perspective. Ensures that Burst's processes are built around how facilities actually work.
Burst's founder has submitted formal public comments to CMS on the CRUSH initiative, making the case that facility-side Part B supply billing — not external supplier billing — is the model CMS's own consolidated billing framework was designed to support. Burst operates at the policy level, not just the billing level. The company's position is that reducing fraud, waste, and abuse in the Part B supply space requires returning billing authority to the facilities that provide the clinical care.
From facilities that have been through this process.
These are real outcomes from facilities that completed the Burst compliance and billing process.
“Before using Burst Billing, we partnered with a medical supply company who would bill Part B plans as the provider and keep the revenue for themselves. After exploring other options, Burst Billing not only met but exceeded our expectations and truly opened our eyes to the benefits of a revenue share model. Their professional billing team works seamlessly behind the scenes to significantly boost our Medicare B revenue. From the transparency and confidence of their leadership to the expertise of their billers, working with Burst Billing has been an overwhelmingly positive experience.”
Common questions about Part B supply billing compliance.
These are the questions compliance officers, CFOs, and administrators ask most often when evaluating this billing model.
- Yes. 42 U.S.C. § 1395x(s) defines POS as a covered Part B benefit, 42 CFR 411.15(p)(2) is the consolidated billing exclusion that permits SNFs to bill these items under their own NPI, and CMS Pub. 100-04, Ch. 7 § 10 operationalizes the pathway. The framework has been in place since the Balanced Budget Act of 1997.
Request a compliance review for your facility.
Burst will review your facility's current billing setup, identify which residents and supply categories are eligible, and walk you through the documentation requirements — at no cost and no obligation.
- Burst reviews your current Part B supply billing setup and identifies gaps
- You receive a clear picture of which residents are eligible and which supply categories apply
- Burst walks through the documentation requirements specific to your facility
- No cost. No obligation. No commitment required to receive the review.
- HIPAA BAA executed before any resident data is accessed
- Review is conducted by Burst's compliance and billing team — not a sales representative
Turn Missed Opportunities Into Real Profit.
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Talk to the Burst compliance team directly.
If you have a specific compliance question — about a claim, a documentation requirement, an audit, or the regulatory framework — call the number below. You will reach someone who knows the answer.
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