Legislator: CMS failed to consider paperwork 'burden'
WASHINGTON - When CMS published new documentation requirements for power mobility devices in April, the agency did not "seriously evaluate" the additional paperwork burden it would impose on providers and physicians, a legislator stated in a letter to CMS in mid-May.
CMS's final rule for power wheelchairs and scooters, which went into effect June 5, 2006, replaced CMNs with physician prescriptions and medical records. The agency's interim final rule (IFR) went into effect Oct. 25, 2005.
"The reality that suppliers now must collect both the prescription and additional documentation on all of its claims is not the same burden as the form requirement of a one-page CMN," stated U.S. Rep. Candice Miller, R-Mich. "Despite the obvious conclusion that the burden on the supplier would likely increase, it is not apparent from the record that CMS conducted any further analysis of the increased burden on suppliers."
Miller is chairwoman of the Government Reform Committee's Subcommittee on Regulatory Affairs. One of the subcommittee's charges is ensuring compliance with the Paperwork Reduction Act (PRA).
Based on a sampling of its members, the Power Mobility Coalition (PMC), which has been working with the subcommittee to address paperwork concerns, estimates that meeting the new documentation requirements requires more than four hours for providers and just over an hour for physicians.
The PMC hopes Miller's letter will catch the attention of the Office of Management and Budget (OMB). Because the subcommittee's power is strictly procedural, it's looking to the OMB to put pressure on CMS to develop guidelines that establish "clear and concise documentation for providers and physicians," said Eric Sokol, spokesman for the coalition.
If those guidelines take the shape of a "template," all the better, the PMC contends.
Attached to her letter, Miller included several templates that the industry has generated to help providers and physicians comply with the new requirements. She asked CMS to consider these "alternative collection methods."
Miller also asked CMS to conduct a proper analysis of the paperwork burden on providers and physicians.
The representative's letter isn't the PMC's first attempt to involve the OMB in its fight to improve documentation guidelines. The coalition filed a petition with the OMB last August, even before the IFR went into effect, charging CMS with violating the PRA by requesting documentation beyond the CMN in its audits. The OMB dismissed the PMC's complaint, however, saying the PRA doesn't apply to a collection of information "during the conduction of an administrative action or investigation." hme