Guides Checklist
Bill-only process readiness checklist: a self-audit from rep request to paid invoice
A printable self-audit for bill-only implant purchasing, covering rep access, the request, price checks, case reconciliation, device credits and month-end.
Version 1.1, last reviewed September 19, 2026
Printed with nothing answered, it is a blank form to work through on paper.
Answer for your hospital, not for us. Mark each item Yes, Partly or No, and note the evidence where you have it. A yes with no evidence noted counts as partly. Your answers are kept in this browser and nothing is sent to us.
Go to your tally and what to work on
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Run this self-audit before redesigning a bill-only process, after an audit finding, or yearly. Bring perioperative services, OR supply chain, purchasing, accounts payable, contracting and compliance, plus patient financial services for section 9. Score each item yes, partly or no, with the evidence beside it. A yes without evidence counts as partly.
Before the meeting
The sample
- Ten recent bill-only cases across several service lines, each traced from the clinical implant record to the paid invoice. Most answers come from this sample.
- Policy, request form, contract price file and last quarter’s exception report at hand.
Measure your baseline first
- Baseline measured on the same ten cases before anything changes: lines billed above contract price and the dollars involved, days from surgery to purchase order, and cases with implants documented but no request. The 90-day rerun repeats these measures.
Running the audit
1. Policy and ownership
- A written policy defining which items may be bought bill-only rather than from stock or consignment.
- A named process owner and a backup.
- A RACI for each step from the OR to accounts payable.
- Policy sent to every bill-only supplier, with acknowledgement on file.
2. Rep access
- Credentialing requirements defined: documents, training and health screening.
- Check-in tied to a scheduled case, and rep presence recorded in the intraoperative record.
- Only a rep checked in to the case may submit a request for it.
- Authorized rep list kept per supplier, with leavers removed promptly.
3. The request
- One structured request per supplier per case, entered once. Rekeying is where errors enter.
- The fields below required before submission.
- A submission deadline after surgery, a written reason required past it, and a later cutoff that escalates to the process owner.
- No PO number released on an incomplete request.
- Duplicate case numbers from the same supplier flagged before approval. Several suppliers on one case is normal.
| Field | Why it matters | Where it goes wrong |
|---|---|---|
| Case number and surgery date | Ties the request to one surgery | A scheduling number is entered instead |
| Patient identifier | Second match key | A spreadsheet drops the leading zeros |
| Catalog number | Key for price and case match | Punctuation differs across rep, contract and clinical record |
| Lot and serial | Recalls, explant credits, traceability | Chased by email after the PO |
| Price and unit of measure | Price check without a lookup | List price typed in, or a box priced as each |
4. End-of-case handoff
- The rep’s usage record checked against the circulator’s documentation before the rep leaves the room, with any difference assigned an owner.
- Opened-but-not-implanted, trial and sample items recorded with the reason and who pays, as agreed in advance.
- Explants recorded with the removal reason and whether the supplier wants the device back.
5. Price validation
- Every line checked against the contract price in effect on the date of surgery, including unit of measure.
- Construct or capitated prices tested at case level; line checks cannot see them.
- A price tolerance defined, with anything above it routed to review.
- Off-contract items flagged and routed to contracting or value analysis.
- Automatic approval, if used, only for requests fully on contract, within tolerance and matched to the case, never for late requests or duplicate case numbers.
For example, a construct priced at $6,000 covers up to eight components. Billed line by line, the same eight parts might total $7,500, which is $1,500 over the construct price, with no line looking wrong. On a case using two components worth $2,500, the construct costs more than the parts; check whether the contract applies the lower figure.
6. Approval and PO
- A second approver above a stated dollar threshold.
- Nobody approves a request they entered or edited, or one priced from a contract file they maintain.
- Rejected (returned to the rep to fix) and declined (closed, not paid) used consistently, each with a reason.
- PO sent to the supplier electronically, and the number returned to the rep without a phone call.
- A submission-to-PO turnaround target, measured monthly.
7. Invoice matching and exceptions
- Written match rules: catalog number, quantity and price, with accounts payable’s tolerance.
- A named owner and an aging target for the bill-only exception queue.
- A rule for invoice errors: return the invoice, or request a credit and rebill.
- Invoices without a PO held and traced to a case before payment.
8. Case reconciliation
- Clinical record, request, PO and invoice compared for every case, or a sample on a fixed schedule.
- Match keys agreed: case number, patient identifier, surgery date and supplier.
- Catalog numbers compared without punctuation, spaces or letter case, and quantities totalled per catalog number.
- Each documented item claimable by only one request.
- Mismatches tracked by category: price, quantity, billed not documented, documented not billed, case not found.
- Cases with documented implants and no request listed by age.
- A clinical record corrected after approval triggers a review, not a silent edit.
9. Device credits and replacements
The CMS fact sheet on cardiac device credits says Medicare reduces payment when a replacement device comes at no cost, at reduced cost, or with a credit of 50% or more of its cost. The claim must carry condition code 49 or 50, with the credit under value code FD. A 2020 OIG audit found likely non-compliance on 3,233 of the 6,558 claims it reviewed. The memo arrives in supply chain; the claim lives in billing.
The fact sheet covers cardiac devices, but the inpatient rule in the Medicare Claims Processing Manual (chapter 3, section 100.8) applies by MS-DRG, from a list set in the IPPS final rule. This is a summary, not billing advice: ask your reimbursement and compliance teams which cases and credits it covers.
- Warranty, recall and explant returns logged against the case, with the return authorization.
- Every credit memo matched to the original and replacement cases.
- Every credit, and every device received at no cost (warranty, recall, clinical trial or free sample), sent to patient financial services with the credit amount and device cost, and the billing outcome confirmed back.
- Returns with no credit or denial after a set period followed up.
Measuring and follow-up
10. Period end and reporting
- Month-end accrual for implants used but not yet billed, from the cases with no request or PO.
- Monthly metrics: surgery-to-PO days, first-pass price match rate, requests returned to reps, exceptions per 100 cases, unreconciled dollars.
- Price variances and off-contract items fed back to contracting by supplier and category.
- Late and returned requests reviewed with each supplier, so both sides fix the pattern.
Scoring and next steps
Fix compliance exposures first: device credits, requests from reps not checked in, missing lot or serial numbers. Then price validation: an unchecked line is paid before anyone looks. Cycle time last, since speed at the wrong price only moves the error sooner. Give every no an owner and a date, then rerun the sample in 90 days and compare it with your baseline.
What good looks like
- Every sampled case traces from clinical record to paid invoice without a gap, and the 90-day rerun agrees.
- No PO was issued on a request missing a case number, lot or serial.
- Every approved line is at contract price, inside tolerance, or carries a recorded exception.
- No case with documented implants sits more than a few days past the submission deadline without a request.
- Every device credit of 50% or more, and every no-cost device, has a confirmed billing outcome within a time limit agreed with patient financial services.
Your tally
Your answers
You have answered 0 of 48 items.
As the checklist says, a yes with no evidence noted is counted as partly.
| Section | Yes | Partly | No | Not answered |
|---|---|---|---|---|
| Before the meeting | ||||
| The sample | 0 | 0 | 0 | 2 |
| Measure your baseline first | 0 | 0 | 0 | 1 |
| Running the audit | ||||
| 1. Policy and ownership | 0 | 0 | 0 | 4 |
| 2. Rep access | 0 | 0 | 0 | 4 |
| 3. The request | 0 | 0 | 0 | 5 |
| 4. End-of-case handoff | 0 | 0 | 0 | 3 |
| 5. Price validation | 0 | 0 | 0 | 5 |
| 6. Approval and PO | 0 | 0 | 0 | 5 |
| 7. Invoice matching and exceptions | 0 | 0 | 0 | 4 |
| 8. Case reconciliation | 0 | 0 | 0 | 7 |
| 9. Device credits and replacements | 0 | 0 | 0 | 4 |
| Measuring and follow-up | ||||
| 10. Period end and reporting | 0 | 0 | 0 | 4 |
| All items | 0 | 0 | 0 | 48 |
What to work on
Nothing yet. Each item you answer No or Partly is listed here, with what addresses it.
Gaps Implant Control addresses
Each note names what the product does and where your team still decides.
Policy sent to every bill-only supplier, with acknowledgement on file.
Administrators publish policies, procedures and terms to vendor users in the portal, with a history of what was sent. Collecting each supplier’s acknowledgement stays with you.
Authorized rep list kept per supplier, with leavers removed promptly.
Administrators add vendor users one at a time or in bulk, limit each to named hospitals and vendors, and deactivate a login when a rep leaves. Knowing that a rep has left still depends on you and the supplier.
One structured request per supplier per case, entered once. Rekeying is where errors enter.
The rep enters the request once, in a structured form tied to the surgery: date, hospital, department, surgeon, procedure, case number and cost center.
The fields below required before submission.
The request form requires the surgery date, hospital, surgeon, procedure, cost center, case number and medical record number, and contracted lines are picked from your price list at your price. Lot and serial have a place on every line but are not forced, so a missing one is for the approver to send back.
A submission deadline after surgery, a written reason required past it, and a later cutoff that escalates to the process owner.
You set the number of days after surgery when a late request needs a written justification, and a later day count after which it is refused. Escalating to the process owner stays with you.
No PO number released on an incomplete request.
Only approved requests are sent to your ERP as a requisition. A request an approver rejects back to the rep for missing detail never reaches purchasing.
Duplicate case numbers from the same supplier flagged before approval. Several suppliers on one case is normal.
A case number already on another active request is flagged as a duplicate, and quantity one request has claimed from the case is not available to the next.
Opened-but-not-implanted, trial and sample items recorded with the reason and who pays, as agreed in advance.
Wasted, trial and explanted lines are flagged on the request. Who pays for them is a contract term to agree in advance.
How Implant Control handles thisRead how to handle items opened but not implanted
Every line checked against the contract price in effect on the date of surgery, including unit of measure.
Contracted lines are picked from your price list at your price, and the approver sees contract price, quantity and requested amount on every line, with any difference highlighted.
How Implant Control handles thisRead the line-level checking rules
Construct or capitated prices tested at case level; line checks cannot see them.
Apply a capitation to the lines it covers and the request bills the flat amount, shows the saving against line pricing, and warns when a capitation covers nothing or costs more than the parts it covers.
How Implant Control handles thisRead about construct pricing
A price tolerance defined, with anything above it routed to review.
Each line’s unit price is also compared with the surgical case record within a tolerance, and a request with a difference is not pre-approved. The tolerance your policy allows against contract price is your decision.
Off-contract items flagged and routed to contracting or value analysis.
An item not on contract is entered as a separate line and flagged Non-contract on the request and in the queue. Routing it to contracting or value analysis is your routine.
Automatic approval, if used, only for requests fully on contract, within tolerance and matched to the case, never for late requests or duplicate case numbers.
Automatic approval is off unless you turn it on, happens only at submission on a clean match, and can be barred for requests with an off-contract line or a duplicate case number. Late requests are governed by the justification and refusal rules instead.
Rejected (returned to the rep to fix) and declined (closed, not paid) used consistently, each with a reason.
Reject sends a request back to the rep to fix and Decline closes it, and the rep is emailed either way. Notes can be internal or visible to the vendor, with standard replies for common reasons.
PO sent to the supplier electronically, and the number returned to the rep without a phone call.
Approved requests go to your ERP as a requisition file. When the ERP returns the purchase order number it is matched back and emailed to the rep. Sending the order to the supplier stays with your ERP.
Clinical record, request, PO and invoice compared for every case, or a sample on a fixed schedule.
Every request is compared with the surgical case record, and the purchase order number is tied back to it. Comparing the invoice stays in accounts payable.
Match keys agreed: case number, patient identifier, surgery date and supplier.
You choose which fields identify a case: case number, medical record number with leading zeros ignored, surgery date and supplier.
Catalog numbers compared without punctuation, spaces or letter case, and quantities totalled per catalog number.
Catalog numbers are compared with dashes, dots, spaces and letter case ignored, and quantities are summed per catalog number on both sides.
Each documented item claimable by only one request.
Quantity one request has claimed from the case is not available to another, and is released if that request is rejected, declined or deleted.
Mismatches tracked by category: price, quantity, billed not documented, documented not billed, case not found.
Each validation run lists what differs, field by field, and reports a missing case as a result rather than passing it. The case dashboard shows which fields most often cause a difference.
How Implant Control handles thisRead what each mismatch pattern signals
Cases with documented implants and no request listed by age.
The case dashboard lists surgeries still waiting for a bill-only request by age: on time, running late or overdue.
A clinical record corrected after approval triggers a review, not a silent edit.
When corrected case data arrives, pending requests are validated again on their own, and approved ones are flagged as changed after approval, with a note, instead of being rewritten.
Month-end accrual for implants used but not yet billed, from the cases with no request or PO.
The case dashboard lists surgeries with no request yet, which is the starting list for the accrual. Booking it stays with accounting.
How Implant Control handles thisRead about implants used but not yet billed
Gaps that are policy or process
Software does not fix these. Each needs a decision, an owner or a routine. Where a product check sits next to one, the note says so.
Ten recent bill-only cases across several service lines, each traced from the clinical implant record to the paid invoice. Most answers come from this sample.
Pulling and tracing the sample is your team’s work, and most other answers rest on it.
Policy, request form, contract price file and last quarter’s exception report at hand.
Preparation for the meeting, not something software does for you.
Baseline measured on the same ten cases before anything changes: lines billed above contract price and the dollars involved, days from surgery to purchase order, and cases with implants documented but no request. The 90-day rerun repeats these measures.
Your own measurement, and the figure a business case rests on. Take it before anything changes, software included, so the 90-day rerun has something to compare with.
A written policy defining which items may be bought bill-only rather than from stock or consignment.
A policy decision. Software can enforce your submission rules once the policy exists, but it cannot decide what may be bought bill-only.
A named process owner and a backup.
An ownership decision only your organization can make.
A RACI for each step from the OR to accounts payable.
A process design decision.
Credentialing requirements defined: documents, training and health screening.
A policy decision for compliance and perioperative leaders. The bill-only workflow does not credential reps.
Check-in tied to a scheduled case, and rep presence recorded in the intraoperative record.
An OR practice. The bill-only workflow does not record who was in the room.
Only a rep checked in to the case may submit a request for it.
Each rep sees only the vendors and hospitals on their account, and every request is matched to the surgical case record. Nothing checks who was checked in, so this link is a process control.
The rep’s usage record checked against the circulator’s documentation before the rep leaves the room, with any difference assigned an owner.
An OR practice at the end of the case. Every request is later compared with the surgical case record line by line, which catches what the handoff missed, but it does not replace the check in the room.
Explants recorded with the removal reason and whether the supplier wants the device back.
A line can be flagged as explanted, but the removal reason and the return decision belong in your clinical and returns records.
A second approver above a stated dollar threshold.
Approval is a single step in the product, with a separate mark for reviewers who audit. A second approver above a threshold is a process to run outside it.
Nobody approves a request they entered or edited, or one priced from a contract file they maintain.
Roles keep the rep who enters a request apart from the approver, and one permission table enforced on the server decides who may change lines at each status. Who holds which role, including who maintains price files, is your segregation-of-duties decision.
A submission-to-PO turnaround target, measured monthly.
Setting the target is yours. The dashboard shows how long requests have waited in the queue against a target; the full time from submission to purchase order is not a live report today.
Written match rules: catalog number, quantity and price, with accounts payable’s tolerance.
Invoice matching stays in your ERP or accounts payable system; the bill-only workflow ends when the purchase order number comes back. What changes is that the order it matches against was built from an approved, contract-priced request.
A named owner and an aging target for the bill-only exception queue.
An ownership decision in accounts payable, outside the bill-only workflow.
A rule for invoice errors: return the invoice, or request a credit and rebill.
An accounts payable policy.
Invoices without a PO held and traced to a case before payment.
An accounts payable control. When tracing one, the cases workspace shows which surgeries have implants documented and no request yet.
Warranty, recall and explant returns logged against the case, with the return authorization.
Returns and return authorizations are tracked in your own process. A line can be flagged as explanted on the request, and that is as far as the bill-only workflow goes.
Every credit memo matched to the original and replacement cases.
A matching routine between supply chain and accounts payable. Credit memos are outside the bill-only workflow.
Every credit, and every device received at no cost (warranty, recall, clinical trial or free sample), sent to patient financial services with the credit amount and device cost, and the billing outcome confirmed back.
A handoff between supply chain and patient financial services, with a compliance question behind it. No software here reports credits to billing for you.
Returns with no credit or denial after a set period followed up.
A follow-up routine with an owner and a date.
Monthly metrics: surgery-to-PO days, first-pass price match rate, requests returned to reps, exceptions per 100 cases, unreconciled dollars.
Choosing and publishing the measures is yours. The live reports cover queue age, approvals, and spend by vendor, surgeon, procedure and site, with export; the time from surgery to purchase order is not a live report today.
Price variances and off-contract items fed back to contracting by supplier and category.
A feedback routine with contracting. Off-contract lines are flagged on every request and usage reports export by vendor and product, which gives you the list to bring.
Late and returned requests reviewed with each supplier, so both sides fix the pattern.
A supplier review routine. Late requests carry the rep’s written justification and returned requests carry the notes sent with them, so the record for the conversation already exists.
Want a second opinion on the gaps? Talk it through with us. Your answers stay on this page either way.
Where this is built in
Implant Control builds many of these checks into the everyday work instead of a yearly audit. Vendor reps submit bill-only requests online, every line is checked against contract price and the surgical case, and approved requests go to your ERP for a purchase order.
What changed in version 1.1
- Grouped into phases, added a step to measure your baseline first, and made every item answerable on this page.