DMERCs release power mobility guidance

Sunday, July 16, 2006

WASHINGTON - The DMERCs last week published additional guidance for power wheelchair and scooter documentation, including a new provision that will mean even more paperwork for providers and physicians.

The new provision, which goes into effect Aug. 24, 2006, requires providers to prepare a detailed product description and have it signed and dated by a physician before delivery.

"It's another paperwork burden and, probably, another contact with the physician's office," said Seth Johnson, vice president of government affairs for Pride Mobility Products and chairman of AAHomecare's rehab council.

For each item billed the product description must include a HCPCS code, the manufacturer make and model, a provider's charge and the Medicare allowable.

Much of the guidance, however, just rehashes provisions already outlined in previous policy, including a final rule that went into effect June 5, 2006. The final rule requires physicians to supply providers with documentation--prescription and medical records--within 45 days of a face-to-face exam.

The rehab industry has always been skeptical of whether physicians are ready and willing to complete the amount of paperwork now required for power mobility devices. The new provision may be the proverbial straw that breaks the camel's back, said Cara Bachenheimer, vice president of government relations for Invacare.

"We've had customers tell us that their physicians are telling them this is a two-hour exercise," she said. "That's the problem, and it's a problem that CMS has never understood."

The guidance also includes a new provision requiring providers, beginning Aug. 24, 2006, to deliver power mobility devices within 120 days of a face-to-face exam.

Industry sources don't expect that provision to trip up providers, largely due to an exception that gives them six months to make deliveries if they have approval through the advanced determination of Medicare coverage process.

There was a glaring omission from the guidance, industry sources said: Additional information on what physicians should include in their medical records.

"This provides some additional information, but it does not provide all the information we're looking for," Johnson said. "We want more specific criteria on what they'll be looking for in the event of a post-payment audit."

The guidance also stated:
- Providers must date stamp all physician documentation.
- Physicians must document evaluations in detailed narrative chart notes--they can't just complete a provider-generated form.
- Physicians may refer patients to licensed/certified medical professionals, but the LCMPs can't be employed by a provider.