Ask the DMERC MDs

Monday, July 31, 2006

It seems as if the theme for this past year has been, "All Wheelchairs, All the Time." Over the last several months we've had a new mobility assistive equipment NCD, LCD revisions, the elimination of CMNs, proposals for new HCPCS codes, revisions to new codes, a draft power mobility LCD, an interim final rule and a final rule, and loads of explanatory material about all these events.
The medical directors have used this space as an avenue for education and to provide insight into this process. This month we continue that tradition. Recently, we released articles discussing the documentation for power mobility devices (PMD) and advance determination of medicare coverage (ADMC) requests.
Q. What is this article all about?
A. This article discusses updates to power mobility documentation based upon the recently published final rule, including a new 45-day period for the face-to-face exam. It summarizes instructions previously published in the LCDs for power wheelchair (PWC) bases and power operated vehicles (POVs) and policy articles. In addition, it adds some new documentation requirements and provides additional documentation guidance based on claim review experience by the DME PSCs.
Q. The information in the article is different from the policy revisions published in June 2006. Which do I follow?
A. The DME PSCs released revisions of the PWC and POV policies as part of the June 2006 policy update. Those revisions incorporate the new 45-day period. However, they did not include the new documentation requirements described in the article. The information in the article supersedes the policies. This information will be included in a future revision of the medical policies.
Q. How should we document that the order and the face-to-face visit occurred within the required timeframe?
A. In order to document that the order was received by the supplier within 45 days after the date of the face-to-face examination, the supplier must use a date stamp or equivalent on the order when it is received.
Q. Are there other items that we need to document?
A. Yes. Once the supplier has finalized the specific power mobility device that will be provided to the beneficiary, the supplier must prepare a written document (termed a detailed product description) that lists the specific base (HCPCS code and manufacturer name/model) and all options and accessories that will be separately billed. For claims with dates of service on or after Aug. 24, 2006, the supplier must list his charge and the Medicare fee schedule allowance for each separately billed item. If there is no fee schedule allowance, the supplier shall enter "not applicable." The physician must sign and date this detailed product description and the supplier must receive it prior to delivery of the PWC or POV. A date stamp shall be used to document receipt date.
Q. Are there any timeliness requirements besides the 45 days to get the face-to-face and order documentation?
A. For claims with dates of service on or after Aug. 24, 2006, the delivery must be within 120 days following the face-to-face examination.
Q. Are there any exceptions to the 120-day delivery requirement?
A. Yes, for PWCs that go through the ADMC process and receive an affirmative determination, the delivery must be within six months following the determination.
Q. How should the face-to-face exam be documented?
A. Physicians shall document the evaluation in a detailed narrative note in their charts in the format that they use for other entries. The note must clearly indicate that a major reason for the visit was a mobility evaluation.
Q. Can a supplier-created form be used to document the medical need for power mobility equipment?
A. Many suppliers have created forms that they send to physicians and ask them to complete. Even if the physician completes the form and puts it in his/her chart, this is not a substitute for the comprehensive medical record as noted above. We encourage suppliers to help educate physicians on the type of information that is needed to document a patient's mobility needs.
Q. Who else can assist the physician in evaluating the patient?
A. The physician may refer the patient to a licensed/certified medical professional (LCMP) who has experience and training in mobility evaluations to perform part of the face-to-face examination. This person may not be an employee of the supplier or have any financial relationship with the supplier. (Exception: If the supplier is owned by a hospital, an LCMP working in the inpatient or outpatient hospital setting may perform part of the face-to-face examination.)