Comment period closes for PWC rule

Sunday, November 27, 2005

BALTIMORE - The comment period for CMS's plan to replace CMNs with physician prescriptions for power mobility devices came and went Nov. 25, one month after the plan went into effect.

CMS's widely criticized interim final rule (IFR) also requires physicians to conduct face-to-face examinations and provide suppliers with documentation within 30 days of exams.

Various manufacturers and providers of power wheelchairs and scooters, as well as rehab industry groups, submitted comments to CMS. Common themes: further clarity in documentation and additional physician education.

"[CMS] needs to do a better job educating physicians," said Sharon Hildebrandt, executive director of the Washington-based National Coalition for Assistive and Rehab Technology (NCART). "What they have done hasn't filtered down. They have to look at other avenues other than a Web site, because that's just not doing it."

Since the IFR was released in late August, CMS has developed a link on its Web site that serves as a one-stop-shop for information on power mobility devices. It has also published a Medlearn Matters article and conducted Open Door forums on the subject.

The Restore Access to Mobility Partnership (RAMP) recommended CMS educate physicians not only through the Internet but also through newsletters (state and national professional societies) and in-person education programs.

To clarify documentation requirements, RAMP recommends CMS provide physicians with a standard set of requirements that they're expected to address when documenting the mobility needs of their patients.

"While the requirements for the written prescription are specific and defined, the requirements for the supporting medical documentation are wholly undefined," a statement from the groups reads.

The requirements for supporting documentation could be as easy as developing questions that would help physicians understand what CMS expects of them. Examples: What is this patient's mobility limitation and how does it interfere with the performance of activities of daily living; and why can't a cane or walker meet this patient's mobility needs in the home?

Other industry concerns detailed in submitted comments:
- The IFR could result in suppliers who are increasingly denied payment and beneficiaries who are increasingly denied access--through no fault of their own.
- The lack of clarity in documentation requirements could lead to increased fraud and abuse.

"The IFR appears to open the door to fraud, since providers no longer need to provide a physician-signed document with a claim for the PMD," reads a Nov. 14 letter signed by Pride Mobility Products and Invacare and sent to CMS officials. "Illegitimate providers, though few, now have an opportunity to submit on a claim to receive payment for the PMD."