BALTIMORE--In establishing new coverage criteria for mobility equipment, CMS must detail what documentation requirements will be accepted as a "definitive determinant of medical necessity" before implementing new coverage policy.
That's according to a statement released last week by the Restore Access to Mobility Partnership, a coalition of mobility industry stakeholders commenting on Medicare's new coverage-criteria proposal for mobility equipment.
As part of its overall effort to revamp the Medicare mobility benefit, CMS released a draft National Coverage Determination for mobility devices earlier this year. The agency's initiative also includes changes in supplier quality standards and new coding for power wheelchairs and scooters.
RAMP--whose members include the American Association for Homecare, Invacare Corp., The MED Group, Mobility Products Unlimited, Pride Mobility and Sunrise Medical--said "one of the biggest flaws in the Medicare reimbursement process is a documentation policy that is too open to interpretation, resulting in DMERC claim processors increasingly insisting that physician chart notes are solely to be used to determine medical necessity."
The group explained that "physicians will not, as a matter of practice, document the beneficiary's medical condition with the level of specificity envisioned in the new coverage policy."
Further, RAMP's comments explained that "documentation requirements must be tied directly to the coverage policy and clearly outline the required information, who is responsible for providing the information and how the information must be documented."
The group urged CMS to base those documentation requirements on an expanded Certificate of Medical Necessity. Using an expanded CMN "is far superior to collecting and interpreting vague and incomplete physician chart notes," the coalition said.
CMS said it plans to issue a final NCD within the coming weeks. For more information and to view the coverage-criteria document, visit the CMS Web site by clicking here.
