CMS releases documentation guidance

Friday, August 31, 2007

WASHINGTON - TriCenturion, the Program Safeguard Contractor for jurisdictions A and B, in July posted a bulletin on its Web site that addresses several questions concerning evaluations and documentation for power mobility devices (PMDs). Here's an edited version of the bulletin:
Can a form that is developed by an entity other than the supplier, and that is completed and signed by the physician and included in the patient's chart be considered sufficient documentation of the required face-to-face examination for PMDs?
No. Physicians must document the face-to-face exam "in a detailed narrative note in their charts in the format that they use for other entries." If a form is used, there must be documentation in the patient's medical record that corroborates the information on the form and verifies that the coverage criteria have been met.
A supplier pays a physical therapist (PT) or occupational therapist (OT) to do wheelchair evaluations of non-Medicare patients. The PT or OT also performs an evaluation on a Medicare patient, but the supplier does not pay for that evaluation. Does Medicare consider that therapist to have a "financial relationship" with the supplier in the context of the PMD policy?
Yes. Even though the supplier does not pay the therapist for the evaluation of the Medicare patient, the evaluation cannot be considered part of the required face-to-face exam for all PMDs or the required specialty evaluation for PMDs in groups 2, 3 and 4.
Can a physical therapy assistant (PTA) or an occupational therapy assistant (OTA) who is a RESNA-certified Assistive Technology Practitioner (ATP) provide the specialty evaluation that's required for certain PMDs provided on or after April 1, 2008?
No. As with all professional services, the evaluation must be within the scope of practice of the healthcare provider as defined by state professional practice laws. Independent evaluations are not within the scope of practice of PTAs and OTAs.