With so many changes scheduled for our industry in 2006 and 2007, it is vital that we truly understand them and know how we are going to implement each of them into our businesses.
Since the hospital bed Certificate of Medical Necessity and the Group III CMN will be eliminated on Oct. 1, it is important that you obtain the documentation to prove medical necessity per the CMS policy for both. Read each policy carefully and make sure you implement a Physician Order for each that will ask questions to determine if the patient qualifies before this equipment is delivered. It is much easier to know what is required when we have CMNs than it will be when CMNs are eliminated.
Other CMN modifications that take effect Oct. 1 will change what you have become accustomed to when receiving these CMNs back from the treating physician. Since they have become somewhat familiar with the old CMNs, you will need to set up educational sessions with your referring physicians to teach them what the changes are and how this affects the coverage of items for Medicare beneficiaries — and for those insurance company patients who follow Medicare guidelines.
Make an educational book including the Medicare policies and CMN changes to hand out. Also, take the time to educate your staff about these changes. Make the same educational materials available for your employees, and make tests to give them to verify that they understand the changes.
CMN changes are as follows for lymphedema pumps and oxygen:
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Lymphedema pumps are now called “pneumatic compression devices,” and the CMN changes from a DMERC 04.03B to a MAC 04.04B form.
Questions 4 and 5 on the old CMN have been eliminated, and two questions have been added to the new CMN. Question 2 on the new CMN asks, “If the patient has venous stasis ulcers, have you seen the patient regularly over the past six months and treated the ulcers with a compression bandage system or compression garment?” Question 5 on the new CMN asks, “Has the patient had lymphedema since childhood or adolescence?”
To make things even more confusing, Question 1 on the new CMN was Question 3 on the old CMN; Question 3 on the new CMN was Question 2 on the old CMN; and Question 4 on the new CMN was Question 1 on the old CMN. In Section A, recert has been added; the supplier's National Provider Identifier number or Legacy number is requested; and the physician's NPI or UPIN number is required. It is now a CMS-846 (09/05) form.
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For oxygen, Form 484.2 changes to DME MAC 484.03, Form CMS-484 (09/05). On the new CMN, we have nine questions instead of 10. Question 4 on the old CMN, which asked for the name and address of the facility where the test was performed, has been eliminated. The requirement for the height and weight to be entered in Section A also has been eliminated (thank goodness!).
The wording on Question 1 has changed slightly, but nothing significant. The answer for Question 2 has been changed to a “1,” “2” or “3” instead of “yes” or “no.” Question 2 now asks, “under any other circumstances?” This is new to the question. Question 3 is the same on the new CMN; Question 4 asks if the patient requires portable oxygen within the home (this was Question 5 on the old CMN); Question 5 asks for liters per minute (this was Question 6 on the old CMN). Question 6 on the new CMN was originally Question 7 on the old CMN, requiring patients on more than 4 lpm to be tested on 4 lpm to receive 1.5 times allowable with appropriate modifiers.
Questions 7 through 9 on the new CMN now only have to be answered if the beneficiary is a Group II oxygen patient. On the old CMN, these were questions 8, 9 and 10 and were required to be answered. The questions did not change in substance, though. In Section D, note that it no longer states that signature and date stamps are not acceptable.
Make sure you understand the questions and what answers must be present on new these CMNs for your patients to qualify per Medicare policy. Make copies of the new CMNs and train everyone in your company who has any part in the documentation/payment process.
Jane Bunch is vice president, HME consulting, for Atlanta-based CareCentric. A reimbursement specialist, Bunch delivers educational seminars worldwide, helps develop corporate compliance plans and serves as a consultant for fraud and abuse cases. She can be reached at 678/264-4495 or via e-mail at jane.bunch@carecentric.com.
