Ask the DMERC MDs
In the past few columns, the DMERC medical directors felt it would be useful to answer some of the common questions that have arisen about the Mobility Assistive Equipment NCD (NCD 280.3). This month, we continue with some additional questions on documentation.
Q. Why do we need to continue to complete a certificate of medical necessity (CMN) for power mobility devices now that a decision has been made to eliminate the form?
A. The common working file (CWF) requires a CMN in order to process claims for certain power wheelchair bases and power operated vehicles. Changes in the CWF to accommodate the elimination of the CMN are scheduled to be completed by April 2006. During this transition a partially completed CMN is needed to process these claims in the current system.
Q. The transition instructions seem overly complex. Why is that?
A. The elimination of a CMN affects many parts of the claims processing system. In addition to the impact caused by the CWF requirement, EDS billing software and VIPS claims processing systems are also affected. The instructions published in the September article, "Wheelchair CMNs - Transition Instructions," addresses the requirements of these other systems.
Q. My billing system creates a completed Section C, which I use, after it is signed by the physician, to document the detailed order. Can I still use the CMN for that purpose?
A. A CMN form that contains all of the required elements may continue to be used to document a detailed written order during this transition period. Refer to your supplier manual for information on the required elements of a detailed written order.
Q. Other payers use the answers in Section B for their own purposes. Can we continue to use the form?
A. Medicare doesn't take a position on the procedures used by other payers. If you continue to complete the existing form, remember that Section B will not be used for claims processing by the DMERC. Also note that the forms will be discontinued by April 2006.
Q. Explain the face-to-face examination requirement for physicians.
A. For a POV or power wheelchair to be covered, the treating physician must conduct a face-to-face examination of the patient to determine and document the medical necessity of the item. Coverage criteria for PMDs are found in the National Coverage Determination (NCD) for Mobility Assistive Equipment (NCD Manual Section 280.3), which became effective on May 5, 2005.
The treating physician must complete this examination before writing an order for the PMD. A copy of the examination report must be received by the supplier within 30 days after the examination is completed (Exception: If this examination is performed during a hospital or nursing home stay, the supplier must receive the report of the examination within 30 days after discharge).
Q. What needs to be documented during the face-to-face exam?
A. The examination must include pertinent elements of the patient's history, physical examination and functional assessment describing the patient's mobility limitation and his/her physical and mental ability to operate a PMD.
Q. What needs to be provided to the supplier on the order?
A. The supplier must receive from the treating physician a written order within 30 days after completion of the physician's face-to-face examination and prior to delivery of the device. This order must contain all of the following elements:
- Beneficiary's name.
- Description of the item that is ordered. This may be general - e.g., "power wheelchair" or "power mobility device" - or may be more specific.
- Date of completion of the face-to-face examination (See above).
- Pertinent diagnoses/conditions that relate to the need for the power mobility device.
- Length of need.
- Physician's signature.
- Date of physician signature.
The DMERCs have published several transition-related articles.
- "Power Mobility Devices - Documentation Requirements"
- "Wheelchair CMNs - Transition Instructions"
- "FAQs: Mobility Assistive Equipment (MAE)"
- "Power Operated Vehicles - Policy Clarification"
- "Transitioning to the Mobility Assistive Equipment National Coverage Determination"