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February 3, 2026

Widespread Pre-Payment Service Specific Medical Record Review Announcement – Urological Supplies

CGS will conduct a medical record pre-pay review of claims for Group 1 Urological Supplies codes submitted by new suppliers.

The Urological Supplies policy group continues to rank high in Comprehensive Error Rate Testing errors for Jurisdictions B and C. Additionally, a February 2025 Office of Inspector General report documents improper payments for urological supplies, including intermittent urinary catheters. CGS has also observed unusually high utilization of urological supplies billed by new suppliers across DME Jurisdictions B and C.

CGS will review medical records for selected claims before payment. This review will target new suppliers.

CGS will send Additional Documentation Requests (ADR) for these claims. It is important to respond to ADR letters. Federal law (Social Security Act, Sections 1815(a), 1833(e), and 1862(a)(1)(A)) authorizes the collection of this information. Suppliers are in violation of Supplier Standard #28 when, upon request, they fail to provide requested documentation to a Medicare contractor like CGS.

Failure to provide records may result in a claim denial and referral to the National Provider Enrollment (NPE) contractor and/or UPIC.

The ADR letter will request the following information to support payment of the claim:

  1. Treating practitioner's written order.
  2. Relevant medical records that support it is medically necessary to perform intermittent catheterization.
  3. Any other pertinent documentation.
  4. Copy of Advance Beneficiary Notice (ABN) if one was obtained.
  5. Additionally, for sterile intermittent catheter kits, medical records must document that the beneficiary meets one of the coverage criteria listed in the Urological Supplies Local Coverage Determination specific to sterile intermittent catheter kits.

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