RAMP: CMS Must Resolve Mobility Documentation Issue

BALTIMORE–In establishing new coverage criteria for mobility
equipment, CMS must detail what documentation requirements will be
accepted as a “definitive determinant of medical necessity” before
implementing new coverage policy.

That’s according to a statement released last week by the
Restore Access to Mobility Partnership, a coalition of mobility
industry stakeholders commenting on Medicare’s new
coverage-criteria proposal for mobility equipment.

As part of its overall effort to revamp the Medicare mobility
benefit, CMS released a draft National Coverage Determination for
mobility devices earlier this year. The agency’s initiative also
includes changes in supplier quality standards and new coding for
power wheelchairs and scooters.

RAMP–whose members include the American Association for
Homecare, Invacare Corp., The MED Group, Mobility Products
Unlimited, Pride Mobility and Sunrise Medical–said “one of the
biggest flaws in the Medicare reimbursement process is a
documentation policy that is too open to interpretation, resulting
in DMERC claim processors increasingly insisting that physician
chart notes are solely to be used to determine medical
necessity.”

The group explained that “physicians will not, as a matter of
practice, document the beneficiary’s medical condition with the
level of specificity envisioned in the new coverage policy.”

Further, RAMP’s comments explained that “documentation
requirements must be tied directly to the coverage policy and
clearly outline the required information, who is responsible for
providing the information and how the information must be
documented.”

The group urged CMS to base those documentation requirements on
an expanded Certificate of Medical Necessity. Using an expanded CMN
“is far superior to collecting and interpreting vague and
incomplete physician chart notes,” the coalition said.

CMS said it plans to issue a final NCD within the coming weeks.
For more information and to view the coverage-criteria document,
visit the CMS Web site by clicking
here.