Atlanta
With a number of new mobility policies set to take effect within the next year, many HME stakeholders say CMS should slow down and make some major revisions before moving forward.
More than 500 callers jammed the phone lines and 45 to 55 appeared in person last month at a three-hour Open Door session, which focused on the interim final rule that eliminates the power mobility CMN.
Implementation of the rule should be delayed until at least April 1, 2006, according to Dan Meuser, president of Exeter, Pa.-based Pride USA. “Folks, providers cannot adapt to this rapid change in this time period,” Meuser told CMS officials at the session, citing provider concerns about retooling billing systems to the new requirements, concerns the DMERCs will not be able to adjust their own claims processing systems and a widespread lack of education in the medical community about physicians' new role in the process. “We need for you to truly consider a delay so we transition again in an orderly way as opposed to a rush to disorder,” Meuser said.
CMS' response: The agency is “listening” to that request.
Another attendee said it is inappropriate to require providers who are not medically trained to gather patient medical records from physicians, and then to hold providers responsible for deciding whether that documentation will support medical necessity.
As “laymen,” non-clinician suppliers are not qualified to make these medical evaluations, said Doug Harrison, president of The Scooter Store, New Braunfels, Texas. “Imagine the outcome if pharmacists first requested physician's chart notes from a patient, then analyzed those notes, and finally, refused to fill the prescription based upon his or her reading of the chart notes,” he said. “Neither the patients nor doctors would tolerate that outcome at a pharmacy, nor should they in the instance of the prescription of power mobility devices.”
But CMS' Dr. Richard Lawler responded that the agency has no intention of changing the requirement. “We're not asking the supplier to make a diagnostic information or to write the prescription,” he said. “But you do have to find between the time the prescription is made and it is supplied an ability to translate that prescription into a physical piece of equipment. That's your business that you're in.”
Others at the meeting were concerned that the role of clinicians is not addressed in the policy language, leaving the burden on physicians who may — or may not — have the training necessary to prescribe appropriate equipment.
“It's not been my experience that there are a lot of physicians who feel confident to provide the detailed prescription that's necessary. They neither have the time nor the expertise in the [mobility assistive equipment] that's necessary in order to have the whole thing turn out right for the beneficiary in the end,” commented Ginger Walls, outpatient clinic director at National Rehab Hospital in Washington, D.C.
“It's been my experience that I've had to go back and try to fix more patients' problems who had improper devices prescribed for them,” she said.
To help educate physicians, the agency is planning meetings with physician groups, publishing Medlearns and using DMERCs to get the word out.
“Just like in any other health care provision, we expect providers who are going to order power mobility devices to be competent in ordering those power mobility devices,” said CMS' Steve Furrough. “We expect [physicians] to do the appropriate evaluation, answering those questions [as outlined in the NCD], and if they are uncomfortable doing that, then we certainly expect them to ask for some assistance.”
Proposed PMD Timeline:
| Oct. 25 | CMS' interim final rule on power mobility takes effect (suppliers still should submit a partial CMN); comment deadline on rule |
| Oct. 31 | Comment deadline on draft LCD |
| Nov. 15 | Revised Product testing deadline for manufacturers |
| Jan. 1, 2006 | Final LCD, 63 new PMD codes take effect; pricing to be determined |
| April 2006 | CMN requirement dropped entirely |
