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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.

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.
  • 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.

See what your contracts already owe you

Bring one supplier contract and a purchase extract. In a working session we load it, run the numbers and hand you the statement: earned, received, owed.