SNF Part B Supply Billing: Regulatory Framework and Compliance Policy

Executive Summary SNF Part B Billing for Medical Supplies

Separate billing is authorized by statute. 42 U.S.C. § 1395x(s) expressly includes surgical dressings, prosthetic devices (ostomy, urological, tracheostomy), orthotic devices, and enteral nutrition. These are enumerated categories — not edge cases.
Consolidated billing is not a bar. SNF consolidated billing under 42 U.S.C. § 1395yy(e) applies only during a covered Part A stay. Long-term care residents with no active Part A benefit fall entirely outside its scope.
CMS has operationalized the pathway. Pub. 100-04, Ch. 7, §§ 10 and 60 authorize SNFs to bill the A/B MAC (A) directly using the institutional NPI on a UB-04. Revenue codes and bill types are specified. The infrastructure exists.
Documentation is the compliance variable. A Standard Written Order, contemporaneous medical record, and Proof of Delivery are required for every claim. Category-specific LCDs govern quantity limits and qualifying conditions. Compliance is deterministic: either the documentation is present or it is not.

Bottom Line

A significant portion of the supplies your facilities already provide to long-term care residents qualify for separate Part B reimbursement under existing Medicare authority. The statutory and manual framework is settled. The question is not whether the right exists — but whether the documentation infrastructure is in place to exercise it compliantly.

01 Statutory and Manual Authority

A. Statutory Foundation

The authority for separate Part B billing rests on Section 1861(s) of the Social Security Act, codified at 42 U.S.C. § 1395x(s), which defines the medical and other health services covered under Part B:

Citation	Coverage
§ 1395x(s)(5)	Surgical dressings, splints, casts, and devices used for fracture and dislocation reduction
§ 1395x(s)(8)	Prosthetic devices replacing all or part of an internal body organ, including colostomy bags and related supplies
§ 1395x(s)(9)	Leg, arm, back, and neck braces and artificial limbs
§ 1395x(s)(2)(D)	Enteral and parenteral nutritional therapy for patients with a permanent impairment requiring tube feeding

B. Consolidated Billing Does Not Apply to This Population

SNF consolidated billing under 42 U.S.C. § 1395yy(e) and 42 C.F.R. § 411.15(p) applies exclusively during a covered Part A stay. Long-term care residents with no active Part A benefit are not subject to consolidated billing, and the supply categories identified above are billable directly to Medicare Part B for that population.

C. CMS Manual Operationalization

Under these provisions, the SNF bills the A/B MAC (A) using its institutional NPI on a UB-04 (Form CMS-1450):

Manual Reference	What It Authorizes
Pub. 100-04, Ch. 7, § 10	Governs SNF Part B billing. Authorizes direct submission for residents whose Part A benefits are exhausted and for residents in a non-covered stay. Claims are processed as inpatient Part B using bill type 22X.
Pub. 100-04, Ch. 7, § 60	Distinguishes between prosthetic and orthotic devices — which the SNF may bill directly to the A/B MAC (A) — and Durable Medical Equipment, which requires separate DME MAC enrollment. Burst bills exclusively within the POS category. Burst does not bill DME.
Pub. 100-04, Ch. 7, § 60.1	Specifies UB-04 billing mechanics: bill type 22X (Part B inpatient), 23X (outpatient); Revenue Code 274 (prosthetics/orthotics); Revenue Code 623 (surgical dressings, A6000-series HCPCS codes).
Pub. 100-02, Ch. 15	Coverage definitions: § 100 (surgical dressings); § 120 (prosthetic devices — ostomy, tracheostomy, urological, enteral/parenteral nutrition); § 130 (braces and artificial limbs).

02 POS vs. DME — The Critical Distinction

The most common compliance misconception is classifying the supplies Burst bills as Durable Medical Equipment. They are not. This distinction determines the entire billing pathway.

Prosthetic & Orthotic Supplies (POS)

What Burst bills

Statutory basis: 42 U.S.C. § 1395x(s)(8) and (9)

Definition: Devices replacing the function of a missing or permanently impaired body part or organ.

Examples: Ostomy pouches, urological catheters for permanent urinary incontinence, tracheostomy supplies, surgical dressings, orthotic braces.

Billing route: A/B MAC (A), UB-04, bill type 22X, institutional NPI.

✓ Burst bills: YES

Durable Medical Equipment (DME)

What Burst does not bill

Statutory basis: 42 U.S.C. § 1395x(n)

Definition: Equipment that can withstand repeated use, primarily serves a medical purpose, and is generally appropriate for use in the home.

Examples: Wheelchairs, hospital beds, oxygen concentrators, CPAP machines, walkers, wound VACs.

Billing route: DME MAC, National Supplier Clearinghouse enrollment required.

✗ Burst bills: NO

The Misclassification Risk

An ostomy pouch is not equipment — it is a prosthetic device replacing the function of a resected bowel. A catheter for a patient with permanent urinary incontinence is not equipment — it is a prosthetic device replacing normal bladder function. The statutory classification controls the billing pathway in its entirety. In nearly every case, the item Burst bills is a POS under § 1395x(s)(8) or (9) — qualifying for the Part B billing pathway — not DME.

Decision Logic — When Part B Billing Is and Is Not Permitted

The boundary is a bright-line rule determined entirely by one factor: whether the resident has an active covered Medicare Part A stay.

Situation	Rule	Burst's action
Resident has active Part A stay	Consolidated billing applies. No separate Part B claim permitted.	Burst does not submit a claim.
No active Part A stay	Separate Part B billing authorized for qualifying supply categories (Pub. 100-04, Ch. 7, §§ 10, 60).	Burst stages the claim for submission.
Supply is prosthetic device or surgical dressing	SNF bills A/B MAC (A) on UB-04, bill type 22X, institutional NPI.	Burst submits under your NPI.
Supply is DME	Cannot be billed under institutional NPI. DME MAC enrollment required.	Burst excludes at intake.
SWO, medical record, and POD are complete	Claim is billable. Documentation retained 7 years per 42 C.F.R. § 424.57(c)(12).	Burst submits the claim.
Documentation incomplete or missing	Claim is not billable.	Burst does not submit. Waits until documentation is complete.
Dual-eligible resident	Must confirm supply not already covered under Medicaid per diem. Duplicate billing is impermissible.	Burst confirms payer status before staging any claim.

03 Documentation Requirements

A. Four Universal Requirements — Every Claim, No Exceptions

Per CMS Policy Article A55426, these four elements are required for every claim and must be retained for seven years from the date of service per 42 C.F.R. § 424.57(c)(12):

01 Standard Written Order (SWO)

A written order communicated to the supplier by the treating practitioner prior to claim submission. Must contain: beneficiary's name or MBI, order date, item description, quantity if applicable, treating practitioner's name or NPI, and original signature. Signature and date stamps are not permitted.

02 Medical Record Documentation

Contemporaneous medical record documentation sufficient to establish that the item meets the reasonable and necessary criteria in the applicable LCD or NCD. May include records from the nursing facility, treating practitioners, hospitals, and other healthcare professionals. Must support the type, quantity, and frequency of items ordered.

03 Proof of Delivery (POD)

Documentation confirming supplies were delivered to the facility and received by or on behalf of the beneficiary. Suppliers and their employees may not sign as a designee on the beneficiary's behalf. Retained seven years per 42 C.F.R. § 424.57(c)(12).

04 Refill Documentation

For recurring supplies: affirmative confirmation from the beneficiary or caregiver documenting continued need, prior to shipment. Contact for refill purposes must occur no sooner than 30 days prior to the expected end of the current supply. Delivery must occur no sooner than 10 days prior to the expected end. Retrospective documentation is not acceptable.

B. Category-Specific LCD Requirements

Category	LCD	Key Quantity Limits	Additional Requirements
Surgical Dressings	L33831 A54563	Clinically determined by wound type and dressing change frequency	Monthly wound evaluation required; weekly for nursing facility residents or heavily draining wounds. Qualifying surgical procedure or debridement must be documented.
Ostomy Supplies	L33828	Per-code monthly or 6-month maximums per LCD; one-month max dispensed at a time for nursing facility residents	Liquid barrier: use either spray/liquid (A4369) OR wipes/swabs (A5120) — not both concurrently.
Urological Supplies	L33803 A52521	One catheter/month routine; up to 200 units/month intermittent cath; three-month max dispensed at a time	Specialty catheters (A4340, A4344) require documented clinical indication. External catheters denied if indwelling catheter also in use; denied for bedridden beneficiaries.
Tracheostomy Supplies	L33832 A52492	Per-code monthly maximums per LCD; one-month max at a time for nursing facility residents	Tracheostomy care kit (A4625) not covered after two weeks post-operatively.
Prosthetics & Orthotics	Ch. 7, § 60	Per LCD by device type	Revenue Code 274; bill type 22X; A/B MAC (A) on UB-04.

04 Sample Compliance Policy Framework

Built to the OIG Compliance Program Guidance for Nursing Facilities. The following provides a compliant, standardized process for billing Medicare Part B for eligible medical supplies.

I

Policy Step I

Payer Status Verification

Before any claim is staged, verify and document that the resident was not in a Medicare Part A-covered stay on the date of service. Verification must be contemporaneous — retroactive payer status determinations are not sufficient. For dual-eligible residents, additionally confirm the supply is not already covered under the Medicaid nursing facility per diem rate.

II

Policy Step II

Supply Classification

Confirm the ordered supply falls within a permissible Part B carve-out category and is not classified as DME. Confirm the applicable HCPCS code corresponds to the correct revenue code: Revenue Code 274 for prosthetic and orthotic devices; Revenue Code 623 for surgical dressings (A6000-series).

III

Policy Step III

Standard Written Order and ABN

No claim may be submitted without a completed SWO on file, communicated prior to delivery. For items requiring a Written Order Prior to Delivery (WOPD), the signed SWO must be received before the item is delivered. If Medicare payment is expected to be denied, confirm a valid Advance Beneficiary Notice of Non-coverage (ABN, Form CMS-R-131) was issued to and signed by the beneficiary before delivery.

IV

Policy Step IV

Medical Necessity Review

Review the medical record to verify the presence of contemporaneous clinical documentation sufficient to satisfy the applicable LCD's reasonable and necessary criteria. This is a documentation verification function — staff confirm that required documentation is present and complete; they do not make independent clinical medical necessity determinations.

V

Policy Step V

Proof of Delivery Verification

Verify that POD documentation is on file confirming supplies were delivered to the facility and received by or on behalf of the beneficiary. Quantities delivered and used must justify the quantity billed. Suppliers and their employees may not sign as a designee on the beneficiary's behalf. Retained seven years per 42 C.F.R. § 424.57(c)(12).

VI

Policy Step VI

Refill Protocol

No refill may be dispensed or billed without a documented affirmative response from the beneficiary or caregiver confirming continued need. Automatic shipments on a pre-set schedule are not permitted. Contact for refill purposes must occur no sooner than 30 calendar days prior to the expected end of the current supply. Delivery must occur no sooner than 10 calendar days prior to the expected end. Setting-specific dispensing limits apply: one month at a time for ostomy and tracheostomy; three months at a time for urological supplies.

VII

Policy Step VII

Auditing and Monitoring

Conduct quarterly audits of a random sample of Part B supply claims, reviewing for: (1) documented payer status verification on the date of service; (2) correct supply classification and revenue code assignment; (3) a complete, timely SWO with original practitioner signature; (4) medical record documentation sufficient to satisfy the applicable LCD; (5) proof of delivery matched to the billed quantity; and (6) for recurring supplies, a documented refill request prior to dispensing. If an audit identifies a claim for which payment was received but was not owed, report and return the overpayment within 60 days per 42 U.S.C. § 1320a-7k(d).

REF References

Centers for Medicare & Medicaid Services. Medicare Claims Processing Manual (Pub. 100-04), Chapter 7. cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c07.pdf
Centers for Medicare & Medicaid Services. Medicare Benefit Policy Manual (Pub. 100-02), Chapter 15. cms.gov/regulations-and-guidance/guidance/manuals/downloads/bp102c15.pdf
Centers for Medicare & Medicaid Services. SNF Consolidated Billing. cms.gov/medicare/coding-billing/skilled-nursing-facility-snf-consolidated-billing
Centers for Medicare & Medicaid Services. Standard Documentation Requirements — Policy Article A55426. cms.gov/medicare-coverage-database/view/article.aspx?articleid=55426
Centers for Medicare & Medicaid Services. Surgical Dressings — LCD L33831 and Policy Article A54563.
Centers for Medicare & Medicaid Services. Ostomy Supplies — LCD L33828.
Centers for Medicare & Medicaid Services. Tracheostomy Supplies — LCD L33832 and Policy Article A52492.
Centers for Medicare & Medicaid Services. Enteral Nutrition — LCD L38955.
Centers for Medicare & Medicaid Services. Urological Supplies — LCD L33803 and Policy Article A52521. cms.gov/medicare-coverage-database/view/article.aspx?articleId=52521
OIG Compliance Program Guidance for Nursing Facilities. oig.hhs.gov/compliance/compliance-guidance/docs/nursing-facilities-cpg.pdf
Burst Medical Billing. CMS Public Comment — CRUSH Initiative. regulations.gov/comment/CMS-2026-0826-0507

Disclaimer: Information in this document is for general informational purposes only and does not constitute legal advice. It does not guarantee reimbursement, claim approval, or audit outcomes. Results may vary based on facility documentation, resident eligibility, payer rules, and applicable Medicare requirements. Facilities should consult qualified legal counsel before implementing any billing program.

SNF Part B Supply Billing: Regulatory Framework& Compliance Policy