Face-to-face adds to documentation burden

CMS's proposed rule requires physicians to document, among other things, 'proper usage instructions'
Friday, August 24, 2012

A plan to require face-to-face evaluations for an array of home medical equipment could make it harder for providers to get paid, say stakeholders.

In a proposed rule published in the Federal Register July 30, CMS said it plans to require a face-to-face evaluation within 90 days for certain high-cost DME, like TENS units and hospital beds. That means more arm-wrestling with doctors over documentation.

“Many physicians either cannot or are not willing to go through every single point that CMS would like addressed,” said Sylvia Toscano, owner of Professional Medical Administrators. “The beneficiary wants the equipment and there may be a need there, but if it isn’t documented correctly, the supplier isn’t eligible to be paid.”

That correct documentation includes a lot of tiny details as outlined in the proposed rule, including a written order with the beneficiary name, item of DME ordered, prescribing practitioner national provider identifier and signature, date of the order, beneficiary diagnosis and proper usage instructions.

It’s a fine line to walk when it comes to getting physicians to document the way CMS wants them to because they are usually set in their ways.

“Physicians are used to charting in a certain way,” said Sarah Hanna, vice president of ECS Billing & Consulting. “That is, they observe, they test, and they think this (equipment) would (help) in their opinion. They don’t have the LCDs and NCDs that say you need this, this and this.”

Face-to-face evaluations have been in place for some time for CPAP and power mobility devices. Although providers of those products have adjusted, it has forced them to revamp their business models, says consultant Kelly Wolfe.

“They are not getting paid as much and they have to work twice as hard,” said Wolfe, CEO of Regency Billing and Consulting. “They are having to hire more people. It’s difficult for everybody.”