Features
7 Good Questions
I was visiting with an HME client recently and, while talking about the challenges her company faced, she expressed a feeling of isolation. She said she felt all alone in her little HME world in Rural Town USA. She wondered if other HME companies faced similar challenges and had similar feelings, and asked what others would do in her situation.
Of course, I know her feelings and questions aren't unique. After all, I spend my life traveling to all corners of this country consulting with all types of HME providers, and I get the same questions everywhere I go.
No matter where you are, or what kind of company you have, many of the challenges you face are the same as those of your peers. Here's a list of the most common questions providers ask me and the answers that can help.
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What should I do about additional documentation for Medicare patients? What about chart notes? How much is enough?
According to Medicare, “neither a physician's order nor a CMN nor a DIF nor a supplier-prepared statement nor physician attestation by itself provides sufficient documentation of medical necessity, even though it is signed by the treating physician or supplier.
“There must be information in the patient's medical record that supports the medical necessity for the item and substantiates the answers on the CMN (if applicable) or DIF (if applicable) or information on a supplier-prepared statement or physician attestation (if applicable).
“There must be clinical information in the patient's medical record which supports the medical necessity for the item and substantiates the answers on the CMN (if applicable), or information on a supplier prepared statement, or physician attestation (if applicable).”
Medicare goes on to say: “The patient's medical record is not limited to the physician's office records. It may include hospital, nursing home, or home health agency records and records from other professionals including, but not limited to, nurses, physical and occupational therapists, prosthetists, and orthotists.”
This really places you in a vulnerable position since Medicare can arbitrarily decide in a post-payment audit that the medical necessity information you gathered is simply not enough. If the auditors don't believe the patient's medical record substantiates the patient's need for the item(s), they can recoup your money. (You can't ask the patient to pay unless you have a valid ABN.)
