Providers wary of re-supply change

Without guidelines, they risk running afoul of auditors, they say
Friday, June 22, 2012

WASHINGTON – The lack of clarity surrounding CMS’s new policy for re-supply orders could make it hard for HME providers to comply with documentation requirements, they say.

At issue: How do providers differentiate patients who need supplies from those who don't, and how do they prove it?

"They are throwing this out there in such a fashion that it's hard to get all hands on deck to make sure everybody understands what we need to do," said Patrick Clevidence, director of respiratory services for Greensboro, N.C.-based Advanced Home Care. "What questions will we ask patients? What’s going to be acceptable documentation?"

In a notice published June 8, CMS stated that providers can only replace items that need periodic replacement, like PAP and respiratory assist device supplies, when they are no longer functional, rather than every three months, as stated in the existing LCD for PAP.

With the rule, technically, already in place—the notice stated it was effective for dates of service on or after Aug. 2, 2011—all providers can do, at least for the time being, is ask patients questions like, is your tubing cracked or is your mask leaking, and document their answers, stakeholders say. But, without clear guidelines, providers risk running afoul of auditors, they say.

"The auditors are wide open and can make their own interpretations on these," said Eric Parkhill, vice president of clinical operations/corporate compliance for Home Medical Professionals in Gainesville, Ga. "I think we have to look at, it's not how we adhere to the rule, it's how it's interpreted by the auditors."

Although the rule encompasses earlier dates of service, stakeholders doubt existing claims will be targeted.

"No one was on notice that they needed to be doing any of this so I would be surprised,” said Elizabeth Jepson, an attorney with Brown & Fortunato. "But, going forward, what are we supposed to be doing? My guess is we are going to see some more clarification."






If you ask me this isn't such a bad idea.  Just a bit more paperwork, per usual.

This will hopefully save some money in the long run for Medicare, but as I said it is easily solved.  Simply make a questionnaire (the first thing I did this morning when I saw this story) and have your patients complete the questions when they need supplies.  These are questions we typically ask our patients anyhow, so now I have simply made a form to document such.  Until further information is released or a specified form is required, this is what I will be using in my office.

Feel free to use my format I have pasted below. :)



Medicare PAP Re-Supply Questionnaire


June 8 2012, Medicare passed a new guideline stating that when a patient is in need of a PAP re-supply (i.e. mask, headgear, tubing, filter or water reservoir) it must be documented that their current equipment is no longer functional and is in need of being replaced. 

Please take the time to complete the following questions regarding your equipment so that we may document the necessity for replacement of your supplies in your chart. 

Thank you for your time and cooperation in this matter.


1)      How long have you had your current supplies?                                             __________

2)      If you are replacing your mask; are you experiencing a mask “leak”?         Yes       No

3)      If you are replacing your headgear; is your current headgear worn and stretched out, therefore not fitting properly and causing issues with your mask fit?                                Yes       No

4)      If you are replacing your filter or tubing; are you worried there may be bacteria or other build up which may cause you to become ill from extended usage?                                     Yes       No

5)      If you are replacing your tubing; are you worried there may be a pinhole or other malfunction of the product which may cause you to not receive the proper therapy with continued usage, or is there an apparent hole or breakage within the current product?                              Yes       No

6)      Do you feel your health and PAP therapy would greatly benefit from a re-supply of your current PAP supplies today?                                                                                               Yes       No



_______________________________________                                          __________________

Patient Name                                                                                                 Patient ID


_______________________________________                                          __________________

Patient/Caregiver Signature                                                                                    Date

This policy is counterproductive. We all know that CPAP/BiPap non-compliance leads to many co-morbities. We also know that the national average of compliance on PAP therapy is around 50%. A third point we know is that patients that follow a strict replenishment regiment are approximately 90% compliant on their PAP therapy.

Part of the instructions given by my respiratory department when they set up new PAP therapy is stressing the importance of adhering to the guidelines about supply replacement that CMS had published. This new policy (which is poorly constructed) puts the owness on the patient to decide when the mask has lost its integrity, when the headgear no longer fits to allow a proper seal (is a patient supposed to know that in the middle of the night, due to an improperly fitting mask, they are experiencing "large leaks" and this should be replaced?). Is a patient supposed to culture the tubing to see if there is a buildup of bacteria?

We are supposed to be instructing patients on what is "best practices" and make recommendations. Left to the patients to make these decisions, we will be back to the days when a patient says "I need a new mask because the duct tape is no longer holding" or "take back this machine as it is not working." This will lead to a decrease in compliance and an increase in the co-morbities associated with non-compliance.