Physician progress notes continue to plague providers
WASHINGTON - To the frustration of many in the rehab industry, CMS continues to view a physician’s progress notes as the key document when determining medical necessity during pre- and post-pay audits.
“It is standard practice to review progress notes to determine medical necessity, but the doctor doesn’t always document issues related to mobility, and that leaves the provider in a jam,” said Bryan Dylewski, president of Mobility Products Unlimited in Holly Hill, Fla. “If the medical reviewer is having a bad day and doesn’t like what he sees in the progress notes, the claim can be denied.”
Ideally, CMS would develop a single document that includes all the necessary information to satisfy medical necessity. Until that happens, letters of medical necessity, a physical therapist evaluation and other physician generated documentation should be considered equally when determining medical necessity, say Dylewski and others.
Restore Access to Mobility Partnership (RAMP), a coalition of organizations and companies representing power wheelchair providers and manufacturers, has lobbied to have that done - so far to no avail.
“They want the doctor’s notes, but we can’t tell the doctor what to write, and education efforts by the DMERCs and CMS have been ineffective,” said Tom Hood, vice president of regulatory affairs for The Scooter Store, which is a member of RAMP.
Because of the sensitive and controversial nature of medical review, Region B Medical Director Dr. Adrian Oleck declined to discuss it.
Region D Medical Dr. Robert Hoover, however, said his region considers all records when determining medical necessity, but gives greater weight to contemporaneous progress notes. The reason: Documentation written after the fact is subject to recall bias and potential error, he said.