IFR delay: What do we do now?
Q. Now that the interim final rule (IFR) has been delayed, what do I need to properly document power mobility devices?
A. On Dec. 30, 2005, President Bush signed into law the Labor-HHS appropriations bill (H.R. 3010), which includes language prohibiting CMS from implementing the IFR on power mobility devices before April 1, 2006. The provision instructs CMS to issue a new final rule and hold 45-day comment and transition periods.
We have answers to some questions but not all. At this point, regarding the impact of this delay, CMS has not yet issued guidance. Now that the bill has been signed into law, the rules immediately prior to Oct. 25, 2005 should be in effect. Those rules required suppliers to submit a partially completed CMN and have documentation on-hand from the physician to substantiate medical need.
The IFR rules are only being suspended for a short period of time. Suppliers should continue to make sure the beneficiary has had a face-to-face examination by the prescribing physician and use the delay to develop processes that incorporate the new examination, prescription and documentation requirements.
This is an opportunity to better educate physicians and clinicians on the changes under the IFR and the kinds of documentation that they will be required to provide. The documentation should address the nine questions in the national coverage determination (NCD) for mobility assistive equipment.
CMS will be publishing additional guidance to explain what information is necessary during this bridge period; however, we expect that the new rule will be substantially similar to the one issued last August. hme
Jim Stephenson is a rehab reimbursement specialist for Invacare. Reach him at (800) 333-6900 or firstname.lastname@example.org.