RAMP Asks for Clarity on PMD Documentation

WASHINGTON–CMS is not gathering enough input from stakeholders
as it develops documentation guidance for power wheelchairs and
scooters, the Restore Access to Mobility Partnership said in a
statement issued on Wednesday.

The coalition of power mobility manufacturers and suppliers said
CMS did a good job “reaching out” to the industry in drafting the
national coverage determination last year, “but since then the
regulations related to the new coverage policy, as well as other
new rules and regulations, are being finalized without
recommendations from suppliers, manufacturers and physicians being
seriously considered.”

“We felt that there was a healthy working relationship during
the NCD process,” Mal Mixon, chairman and CEO of Elyria,
Ohio-based Invacare Corp., said in the statement. “But since then,
it has been back to business as usual. Regulations are being drawn
up in a vacuum without being shaped by the practical, real-life
experiences that the stakeholders can provide. The result is that
the regulations are often ambiguous and confusing, and make it more
difficult for qualified Medicare beneficiaries to receive mobility
equipment.”

RAMP said one of its biggest concerns is that CMS is rushing to
implement the new changes to mobility policy. “The latest example
is the new documentation requirements for power mobility
equipment,” according to the statement. RAMP said it recommends a
90-day period to implement the changes outlined by the DME Program
Safeguard Contractors in July (see HomeCare Monday, July 17).

“Currently, suppliers and physicians have no way to know if
their documentation is sufficient,” RAMP said. “They have been
attempting to comply with the provisions of the interim final rule
and the final rule, but there are now new changes that leave key
questions unanswered. There is also an overriding problem:
suppliers are attempting to obtain information from the physicians,
but have no consistent vehicle to reasonably do this.”

According to RAMP, the following issues in the documentation
guidance need to be addressed:

• The entire report of the face-to-face physician examination
  should not be required to be transcribed directly into chart
  records. “Physician notes in patient records are usually not very
  detailed,” the statement noted, and “the six questions and 16
  bullet points of information asked for” are not typically found in
  chart notes. While questionnaires and forms don’t replace the
  comprehensive medical record, RAMP said, CMS should acknowledge
  such supporting documentation as long as it is placed in the
  patient’s chart.
• The guidance states that for certain diagnosis codes for COPD,
  heart failure and arthritis, “the major emphasis will be on
  symptoms and history of the progression of their condition rather
  than on the physical examination.” But RAMP said that statement
  conflicts with the rule stating that patient information collected
  at the face-to-face examination is sufficient. “Is CMS setting up a
  two-tiered system whereby patients with COPD, heart failure and
  arthritis have a more difficult time qualifying for mobility
  equipment?” RAMP questioned.
• As product manufacturer/model changes are made at the time of
  delivery, will suppliers be able to amend the detailed product
  description at the time of delivery or have to postpone delivery
  until they can get a physician to re-sign a description with a new
  manufacturer/model listed?
• Will CMS or equipment suppliers have to obtain the additional
  documents required under the new guidance from physicians? If CMS’
  collection attempts are unsuccessful, will claims be denied?
• If medical documentation states that the equipment will be used
  outside of the home as well as in the home, will that disqualify
  the patient?

Commenting in the statement, Dan Meuser, president of Pride USA,
Exeter, Pa., said many of the problems could be resolved if CMS
“would just have an open ear” before regulations are finalized.
“It’s unfortunate because we all have the same goal: the
stakeholders and CMS want a policy and process that allows
qualified beneficiaries to obtain mobility equipment. But by not
considering industry recommendations, it is likely to produce the
exact opposite result. We will have confusing regulations and
delays in equipment deliveries.”

In a transmittal issued Friday, CMS did make one clarification to
its new power mobility requirements: The face-to-face
physician exam necessary for prescription of a power mobility
device is not required when only PMD accessories or PMD
replacements are being ordered. However, the agency said,
the PMD must be the same device as previously ordered. If a
beneficiary currently has a scooter and would like to replace it
with a power wheelchair, he or she must have a face-to-face exam.