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Good morning,
Last month, Eric Hansen from Burst Billing walked us through the CRUSH initiative and why the "old way" of outsourcing your Part B supply billing is costing facilities hundreds of thousands of dollars. If you missed it, read it here first.
That piece revealed a pattern. Nearly every operator who read it had the same reaction: "Okay, but if the Part B supplier handles the billing, then any audit trouble lands on them — not on me. Right?"
It's a fair question. But it misses the forest for the trees. Eric is back today to walk through why. If you run a building, read this one twice.
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Your facility is the evidence file for every Part B claim submitted under your residents’ Medicare numbers — and you don’t see a single one of those claims before it goes out the door.
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A few months ago, an administrator asked me a question I’ve heard versions of for two years. She said, “If something goes wrong with this supplier’s billing, that falls on them, right? Not on me?”
I told her what I’m about to tell you. Technically yes. Practically, no.
Here is how the current model actually works. An external supplier bills Medicare Part B for supplies your team stores, manages, and administers. You do all of the work. The supplier processes the claim. They carry the surety bond and the legal responsibility for the billing. If a MAC opens a Targeted Probe and Educate review tomorrow, the letter goes to the supplier — not to you. The 45-day clock to produce documentation runs against them.
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The Problem
That sounds like insulation. It isn’t. The supplier doesn’t own a single piece of the evidence. Every clinical record supporting every claim originates in your EHR — and it lives in your building.
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The MAR, the treatment record, the wound assessment, the order, the consumption log: all of it lives in your building. When the supplier gets that 45-day documentation request, there’s a good chance they’ll need your team to help pull charts. Under their clock. With their priorities. Whatever your team produces is what gets submitted to CMS as evidence of what happened in your building.
The legal exposure is downstream. The operational exposure is on your team. Here are three places that exposure shows up.
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F-842
Record Accuracy Deficiencies
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OIG
Active Review OEI-02-24-00310
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Feb 2026
CRUSH Enrollment Moratorium
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F-tag 842 exposure.
Under 42 CFR §483.70(h)(1), your facility has to maintain complete, accurate, and accessible resident records. Surveyors have cited buildings under F-tag 842 for records that couldn’t be produced on request. If a supplier billing under your residents’ Medicare numbers gets investigated and the documentation pulled from your charts doesn’t reconcile with what was billed, the gap is in your records. The supplier walks away from that gap. The chart belongs to you.
The OIG is actively looking.
Project OEI-02-24-00310, announced in June 2024, is OIG’s current review of DMEPOS fraud schemes and CMS safeguards. The first product under that project is specifically examining DMEPOS billing in Medicare Advantage by suppliers not enrolled in traditional Medicare. A meaningful share of suppliers servicing nursing homes today fits that description. When that report lands, the suppliers named in it will be reaching for your residents’ records to defend themselves. Your team may be the one pulling them.
The CRUSH moratorium changed the math.
In February 2026, CMS imposed a nationwide moratorium on new DMEPOS supplier enrollment. Existing suppliers stay in place. New ones can’t get in. Every existing supplier is now operating in a tighter scrutiny environment, with more documentation requests coming faster. The administration has been explicit that the strategy is prevention, not pay-and-chase. Prevention runs on documentation. Documentation lives in your EHR.
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None of this requires the MAC to come for your building directly. The exposure is structural.
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So here’s the honest question for any administrator reading this. If your DON had to pull every Part B supply chart from the last 12 months tomorrow, against an external supplier’s 45-day clock, would the documentation line up with what was billed?
If you don’t know, that’s the exposure. If you’ve never seen the claims being submitted on your residents’ behalf, that’s the exposure. If your visibility into Part B supply billing is whatever your supplier tells you in a quarterly check-in, that’s the exposure.
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The Burst Model
Facility bills Part B under its own NPI → Claim generated from the clinical record after care is documented → Billing trail and care trail are the same trail → Nothing for an auditor to find that you didn’t already see
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Facility-side billing fixes this by putting the billing where the documentation already is. When the facility bills Part B under its own NPI, the claim comes from the clinical record after the care is documented. The billing trail and the care trail are the same trail. Nothing for an auditor to find that you didn’t already see.
The legal authority to bill Part B for your long-term care residents already belongs to your facility. The statute says so. The risk isn’t that the audit letter has your name on it. The risk is that your records are the evidence in every audit letter that goes to your supplier.
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The question that administrator asked me back in the spring is the question I want every operator asking before CRUSH starts landing on buildings in earnest.
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Want to understand exactly how your building’s Part B documentation holds up under CRUSH scrutiny?
Feel free to reach out to me on LinkedIn or visit our website for more details.
Thanks for having me again, Kevin.
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Kevin Goedeke, Publisher and Founder
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