'Risky' paperwork changes OK'd
WASHINGTON - Say goodbye to CMNs for beds, support surfaces, parenteral and enteral nutrition, and hello to changes in other documentation.
In March, the Office of Management and Budget (OMB) approved the following changes:
- DMERC information forms (DIFs) will replace some CMNs, including a combined enteral and parenteral DIF and another for external infusion pumps.
- A revised CMN for oxygen no longer requires the name and location of where a patient's qualifying test was performed. Instead, the CMN will state the test result and whether the test was performed on an inpatient or outpatient basis.
Kim Brummett, vice president of contracting and reimbursement for Greensboro, N.C.-based Advanced Home Care, said while many providers are happy to drop some CMNs, the change will probably mean they'll have to be more vigilant in collecting adequate documentation.
"The supplier is taking liability that what's on the statement is what's in the medical record," said Brummett. "I think a lot of providers, when it's a written order versus a CMN, tend to get more documentation."
Because DIFs require only a supplier's signature, providers are questioning, who, exactly, is qualified to sign?
"I always have trepidation when they start letting providers sign things," said Bruce Brothis, president of Allegient Billing & Consulting in Chandler, Ariz.
The CMNs for beds and support surfaces have not been replaced by a DIF, leaving only a written order to serve as documentation.
"It's a riskier move," said Brummett. "How are you going to qualify someone for a bed?"
Another possibly risky change is the revised oxygen CMN.
Providers will want to cover their bases, said Lisa Smith, an attorney with Brown & Fortunato in Amarillo, Texas.
"In the event of an audit down the road, they're not going to know who performed the test," said Smith. "It's best if suppliers go ahead and get a copy of the test results upfront."
Gearing up for the changes should keep providers busy, said Brummett. In addition to physician and staff education, Brummett needs to get her software systems and vendors up to speed, and create processes for DIFs and written orders.
"It's going to be a wild fall," said Brummett.