Subcontracting

The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) requires contract suppliers to disclose to the Centers for Medicare & Medicaid Services (CMS) information regarding their subcontracting relationships. This information must be provided within 10 business days after the supplier’s contract becomes effective. For subcontracting arrangements entered into after the contract becomes effective, contract suppliers must provide the required information no later than 10 business days after the date the contract supplier enters into a subcontracting arrangement. The required disclosure of subcontracting relationships must be completed in Connexion, the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program’s secure portal.

The DMEPOS Supplier Standards limit Medicare-enrolled suppliers’ subcontracting arrangements to:

1) purchase of inventory;
2) delivery and instruction on the use of Medicare-covered items; and
3) maintenance and repair of rented equipment.

Services such as intake and assessment, coordination of care with the physician, submitting claims on behalf of the beneficiary, ownership and responsibility of equipment furnished to the beneficiary, and ensuring product safety must be provided by the contract supplier.

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