At an Ask-the-Contractor teleconference in May, Medicare representatives clarified that bypassing signature collection on direct-to-patient deliveries simply because the patient was not home at the time of delivery was not an acceptable use of the COVID-19 Public Health Emergency (PHE) signature waiver.

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Even during the PHE, delivery drivers still needed to confirm receipt through some type of real-time interaction with the patient or an authorized representative. The signature waiver never sanctioned indirect or asynchronous deliveries by supplier delivery personnel.

CMS implemented the signature waiver as a workaround for in-person deliveries where the patient refused to sign – or the supplier chose not to collect a signature – because of concerns about spreading COVID-19. Patient requests to “leave the item(s) on their porch” for convenience would not constitute a proper basis for invoking the signature waiver.

In the event of an audit for items delivered during the PHE, suppliers should take care to document the delivery interaction, and where applicable, the patient’s refusal to sign the delivery ticket or their own policy to forego signatures to avoid the spread of COVID-19 between employees and customers.