More PMD Paperwork

In mid-July, the DMERCs posted an article designed to provide more information regarding the documentation that suppliers must obtain from prescribing physicians in conjunction with orders for power mobility devices.

This information was issued after almost a year of demands from the industry and physicians that CMS provide much more clarity regarding the types and scope of documentation necessary to substantiate medical need under the new National Coverage Determination and the new face-to-face examination regulation.

The DMERC policy does provide more information regarding documentation, but it also places significant new burdens on the prescribing physician and suppliers. And the unanswered question remains whether prescribing physicians will actually provide the scope and depth of information that the DMERCs expect. The information the DMERCs are asking physicians to document in the beneficiary's medical record is far beyond the scope and depth of information they typically provide and will require suppliers to provide extensive physician education.

Of enormous concern is the language that states that Medicare's coverage of a wheelchair is determined solely by the patient's mobility needs within the home and, therefore, that the examination must clearly distinguish the patient's abilities and needs within the home from any additional needs for use outside the home. Does this mean that beneficiaries will essentially be confined to their homes because Medicare will only cover PMDs that are appropriate in the home and not practically usable in the long term outside the home?

Following are key components of the guidance:

• Orders: The physician order and report of the face-to-face exam must be received by the supplier within 45 days of the exam and prior to delivery of the device (unless the exam is performed during a hospital or nursing home stay). To document receipt, suppliers must use a date stamp or equivalent on the order and the exam report when they are received.

• Delivery: For claims with dates of service on or after Aug. 24, 2006, the delivery must be within 120 days of the face-to face exam. (For power wheelchairs that receive an affirmative determination through the Advance Determination of Medicare Coverage process, delivery must occur within six months of the determination.)

• Face-to-Face Examination: New information regarding issues the physician should address in the report of the face-to-face exam include:

  What is this patient's mobility limitation and how does it interfere with the performance of activities of daily living?