CMS accepts recommendations for PMD demo

ARLINGTON, Va., Aug. 29, 2021—In last minute changes to the Medicare Power Mobility Demonstration, the Centers for Medicare and Medicaid Services (CMS) has accepted AAHomecare’s recommendations that allow physicians to use a clinical medical necessity template when documenting the face-to-face exam with a Medicare beneficiary. AAHomecare had strenuously argued that without a guide to help physicians document the coverage criteria to support medical necessity, Medicare beneficiaries would not receive prescribed PMDs on a timely basis. Equally important, CMS will allow physicians to utilize a template to assist in documenting medical need. The demonstration is slated to begin on September 1 in the following states: California, Illinois, Michigan, New York, North Carolina, Florida and Texas.

According to the Operational Guide for the demonstration published recently, the agency wrote, “CMS does not prohibit the use of a template to facilitate recordkeeping. CMS also does not endorse or approve of any particular templates. A physician/LCMP may choose any template to assist in documenting medical information… If a physician/LCMP chooses to use a template during the patient visit, CMS encourages them to select one that allows for a full and complete collection of information to demonstrate that the applicable coverage and coding criteria are met.”

The association was also very concerned that if prior authorization was declined because of missing or incomplete information in the physicians’ record, the beneficiary would have to return to the physician for another face-to-face exam. CMS again accepted AAHomecare’s recommendations and clarified this issue stating that, “When [a PMD provider] is reviewing submitted documents, as long as a late entry (such as an amended order, or additional/correction to a progress note)… the DME MACs shall consider all submitted entries when making prior authorization determinations.”

Finally, CMS is working to allow PMD providers to use the Electronic Submission of Medical Documentation (esMD) program when submitting prior authorization medical documentation. While AAHomecare would have preferred that the demonstration would have started with this feature in place, we are pleased that CMS is working to have this capability up and running in the fall of this year.

Walter Gorski, AAHomecare’s vice president of government affairs said, “the association appreciates that CMS accepted many of the recommendations of our Complex Rehab and Mobility Council (CRMC). While we are concerned with the scope of the demonstration affecting 43 percent of all PMD claims nationwide and the ability of the DME MACs to process that many claims within the allotted timeframe, the changes adopted by the Agency are likely to help Medicare beneficiaries receive power mobility items and services in a timely basis. The Association will be closely monitoring the demonstration to ensure that the DME MACs are processing prior authorization requests in accordance with the instructions contained in the Operational Guide. We will make recommendations to CMS if the program does not operate effectively and efficiently.”

AAHomecare’s CRMC has developed a clinical medical necessity template for power mobility and will be revising the template in the next week to make sure it complies with CMS’ announced policies. The template will be available to AAHomecare members. More information is available at www.aahomecare.org.