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April 14, 2020Revised 04.03.23

Signature Requirements on Proof of Delivery During the COVID-19 Pandemic

On February 9, the Department of Health and Human Services (HHS) announced the Public Health Emergency (PHE) for COVID-19 will end on May 11, 2023External Website. This flexibility will no longer apply for dates of service on or after May 12, 2023. For additional information, refer to Durable Medical Equipment, Prosthetics, Orthotics and Supplies: CMS Flexibilities to Fight COVID-19External PDF.

In response to the COVID-19 pandemic CMS is waiving signature requirements on proof of delivery (POD) documentation, for Dates of Service (DOS) within the Public Health Emergency (PHE) for the COVID-19 pandemic. Given the nature of the pandemic and the inability to collect signatures during this time, CMS will not be enforcing the signature requirement.

Items of DMEPOS that are delivered directly to the beneficiary by the supplier (Method 1) typically require a beneficiary's (or designee) signature on the delivery document. During the PHE, suppliers should document the appropriate date of delivery and that a signature was not able to be obtained because of COVID-19.

Suppliers are reminded to append a CR modifier and include a narrative of "COVID-19" to all claims that are affected by the COVID-19 PHE, including situations like that described above where a signature is not able to be obtained on a POD document. The narrative should be entered into the NTE 2400 (line note) or NTE 2300 (claim note) segments of the American National Standard Institute (ANSI X12) format, field 390-BM of the National Council for Prescription Drug Program (NCPDP) format, or Item 19 of paper claims.

Method 2 proof of delivery via shipping or delivery service does not require a signature from the beneficiary or designee; however, it does require evidence of delivery. Please review the Standard Documentation Requirements for All Claims Submitted to DME MACs (A55426)External Website Policy Article for complete information on proof of delivery documentation requirements.

For the latest DMEPOS-specific COVID-19 information, visit the CGS COVID-19 page.

Publication History

April 3, 2023 Added language about the end of the COVID-19 PHE
May 21, 2020 Added language to include the use of the CR modifier and COVID-19 narrative if the claim is affected by the COVID-19 PHE
April 14, 2020 Originally Published


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