Ask the DMERC MDs
This month we are back to a favorite subject, power mobility. After several months of relative quiet, CMS has issued a final rule implementing provisions in the Medicare Modernization Act on power mobility devices. As you remember, CMS issued an interim final rule (IFR) in 2005 that took effect Oct. 25, 2005. Subsequent legislation prohibited CMS from using any funds to implement the IFR until April 1, 2006. This final rule is effective June 5, 2006.
Q. What are the key features of the final rule?
A. There are several. The rule:
- Describes the responsibilities of prescribers in ordering power mobility equipment;
- Expands prescribers to include physician's assistants, nurse practitioners or clinical nurse specialists;
- Eliminates the specialist requirement for power operated vehicles;
- Provides guidance on the documentation required to support a claim;
- Provides payment to the ordering physician for providing necessary medical information to support a claim; and
- Allows 45 days for the supplier to obtain a written prescription and the necessary supporting information from the face-to-face exam.
Q. Is anything different in the face-to-face requirements contained in the IFR?
A. Basically the requirements are the same except for the extension of the timeframe to 45 days. The final rule requires that the equipment be prescribed by a physician or other treating practitioner who has conducted a face-to-face examination of the beneficiary. A beneficiary who has had a face-to-face examination during an inpatient hospital stay will not need a separate face-to-face examination, as long as it is prescribed within 45 days after the date of discharge. The face-to-face examination requirement does not apply when only accessories for PMDs are being ordered.
The prescription requirements are likewise unchanged. The physician must submit a written prescription for the PMD to the supplier. This prescription must be received by the supplier within 45 days after the face-to-face examination, or in the case of a recently hospitalized beneficiary, within 45 days after the date of discharge from the hospital. The written prescription must include the beneficiary's name, the date of the face-to-face examination, the diagnoses and conditions that support the claim for the PMD, a description of the specific type of PMD required, and the expected length of time the beneficiary will need the equipment. The prescription must be signed and dated.
Q. What needs to be in the information from the face-to-face exam?
A. This documentation should include relevant parts of the medical record that clearly support the medical necessity for the PMD in the beneficiary's home, which may include the history, physical examination, diagnostic tests, summary of findings, diagnoses and treatment plans. It may also include information from other examinations, as well as relevant reports from consultants and practitioners. This combination of a written prescription and supporting documentation replaces the CMN that was previously required in ordering such equipment.
Q. What can I tell prescribers to help guide them about what information to provide?
A. The parts of the medical record selected should be sufficient to:
- Outline the history of events that led to the request for the PMD;
- Identify the mobility deficits to be corrected by the PMD;
- Establish that other treatments do not eliminate the need for the PMD and the beneficiary lives in an environment that supports the use of the PMD; and
- Show that the beneficiary or caregiver is capable of operating the PMD.