RAMP to CMS: Clear up PWC documentation

Thursday, June 30, 2005

WASHINGTON -- The Restore Access to Mobility Partnership in June urged policymakers to quickly establish a clear documentation policy centered on the CMN for the new power mobility NCD released in May.
A RAMP Report dated May 26 was circulated to decision makers at CMS and on Capitol Hill to educate them on the importance of documentation in solving the problems that have engulfed the mobility industry in recent years.
"Without such directives, suppliers will not be able to provide medically necessary items because there will be no guidance regarding what types of information will be necessary to substantiate medical need," said Mal Mixon, Invacare's chairman and CEO, in the RAMP Report.
RAMP suggests that the revised CMN, which is expected for release this summer, be the main document used to determinemedical necessity.
The DMERC's reliance on physician chart notes to determine coverage leads to "widespread confusion over the coverage guideline," according to RAMP.
"RAMP's position is 'a CMN plus something else,' and that something else can be, well, it's multiple choice," said Cara Bachenheimer, Invacare's vice president of government relations. "It could be progress notes or the medical records, but our feeling is that those will never contain the level of detail needed."
RAMP argues that the complexity of the new coverage policy, which involves an algorithm of all available mobility devices, requires a simple documentation policy.