Coverage:
Don't Expect New PME Rule To Cure Documentation Woes
Published on Mon Aug 01, 2005
CMS lets the chaos continue, industry groups charge. Power mobility equipment suppliers should brace for ongoing confusion over medical necessity documentation requirements, despite a new interim rule on the matter from the Centers for Medicare & Medicaid Services.
Industry groups including the Washington-based Power Mobility Coalition and the Restore Access to Mobility Partnership are criticizing the recently unveiled regulation for failing to provide the documentation clarity they have long sought.
"The PMC is concerned that the new rule appears to essentially preserve the chaos and ambiguity of the status quo because the new rule does not set objective and reliable documentation standards that can help avoid second-guessing of physicians," says PMC Director Eric Sokol.
While the PMC agrees that the treating physician is best qualified to assess the need for a POV, it is concerned that physicians may not be fully aware of the analytical standards that will be applied to claims - "let alone which of the 49 new product codes most appropriately meets beneficiary needs," PMC Counsel Stephen Azia notes.
PMC is also concerned that the reimbursement add-on for physicians might not adequately compensate them for the additional administrative burden. Suppliers could face denials if physicians fail to chart properly.
Furthermore, the 30-day timeframe for submitting documentation after a face-to-face exam is inadequate, the PMC charges. In its comments on the proposed rule, the organization suggested a 90- to 120-day timeframe. Rule Could Impede Access to Mobility Meanwhile, RAMP cautions that the magnitude of changes in the interim rule means it will take much longer than the planned Oct. 25 implementation deadline for stakeholders to fully grasp the new requirements.
In addition, the elimination of the certificate of medical necessity along with a lack of guidance on documentation to establish medical necessity could lead to subjective decisions on claims, RAMP fears. While CMS is developing additional information on documentation, such guidance must provide "significantly more clarity" than currently exists and must be released well before the interim rule is implemented, the organization says.
The new rule also places "undue and inappropriate" responsibilities on physicians, RAMP charges. "Without a very significant physician outreach plan and a guide to help physicians understand the new process, the doctors likely will not write prescriptions, will not adequately document, and may not prescribe the most appropriate equipment for the patient," the organization cautions.
RAMP is calling on CMS to allow 90 days rather than the proposed 30 days for the Medicare beneficiary's treatment team to prescribe the right mobility equipment for the patient. The organization is also calling on CMS to delay the new rule implementation until April 1, 2006, which is when the durable medical equipment regional carriers expect to update their systems to accept the information required.
