RAMP wants the CMN and 'something else'
WASHINGTON -- The Restore Access to Mobility Partnership is urging policymakers to quickly establish a clear documentation policy centered on the CMN for the new power mobility NCD released in May.
A May 26 RAMP Report 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 determine medical necessity.
Providers have argued that this is the case under the current coverage policy. Recently, however, the DMERCs have turned to physician chart notes to determine coverage, leading to "widespread confusion over the coverage quideline," according to RAMP.
Court cases like Maximum Comfort in southern California and the Scooter Store's lawsuit against CMS have attempted to resolve the issue on the judicial level.
"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.
"It is unlikely that physicians will, as a matter of practice, document a beneficiary's medical condition in the medical records with the level of specificity that may be envisioned," the report stated. "This was a serious problem with the old policy, which was not nearly as complex."
RAMP further suggests that, in lieu of progress notes, a licensed clinician be able to evaluate and determine a beneficiary's need.
Bachenheimer called the suggestions "eminently reasonable," though how this plays at CMS is anyone's guess.
"The difficulty is that the folks hashing this out at Program Integrity have not responded to us, so we don't know how they feel," she said.
CMS's final decision on documentation guidance is expected to be established when the new CMN and face-to-face regulations are released.