What CMS Means by “Access to Documentation”
Providers and suppliers who furnish durable medical equipment (DME), clinical laboratory services, imaging services, or home health services to patients on Medicare should be aware of a clarification the Centers for Medicare & Medicaid Services (CMS) has made to ordering and certifying documentation maintenance requirements.
CMS has clarified the term “access to documentation” in the Program Integrity Manual (PIM), chapter 15, section 15.18.
DME suppliers and providers who furnish DME are required to maintain documentation for seven years from the date of service and, upon the request of CMS or a Medicare contractor, provide access to that documentation.
“Documentation” includes written and electronic documents (including the National Provider Identifier of the ordering physician or other qualified healthcare professional).
The term “access to documentation” means that the documentation is actually provided or made available in the manner requested by CMS or a Medicare contractor, CMS clarifies in MLN Matters® MM9112.
It is the responsibility of the ordering provider/supplier to provide that documentation.
For example, if a Medicare contractor requests copies of all orders for wheelchairs from an ordering physician for all Medicare patients with dates of service from November 1, 2014 through November 10, 2014 the ordering physician must provide the copies, in full, according to the specific request. If copies cannot be provided because the physician did not personally maintain the records, then the requirement to maintain access to this documentation will not have been met and the physician may be subject to revocation.
Providing only a portion of the requested documentation will be considered an insufficient response, as will providing similar documentation that does not contain the order or certification requested or providing other documents not requested.
Source: MLN Matters® Article MM9112, Change Request 9112, released April 17, 2015, effective July 20, 2015
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