Use forms at your discretion
A. One of the challenges that every DMEPOS supplier faces is obtaining medical records that properly document medical necessity. As a result, supplier generated forms have emerged in an attempt to gather the required information from the referral source. The most common supplier generated forms are the "prescription" and the "report of the face-to-face exam" that normally contain the DME supplier's name and address.
Although suppliers are not prohibited from creating "data collection forms" in order to gather medical necessity information, the DMERC will not rely solely on those forms to document medical necessity. There is a difference between a "data collection form" and "medical necessity documentation." If using a data collection form, the suppliers must also obtain actual medical documentation from the physician that supports the information on the "data collection form." The physician's normal documentation procedures are progress notes and chart notes. Many suppliers have created forms for physicians to complete. Even if the physician completes this type of form and puts it in the patient's chart, this supplier-generated form is not a substitute for the comprehensive medical record.
It's very important to point the physician back to the Local Coverage Determination, which lists the specific required documentation. The burden of proof always goes back to the medical documentation.
Physicians are not obligated to complete additional supplier forms. Suppliers are encouraged to help educate physicians on the type of information required to document a patient's need for DMEPOS items. I recommend the DMERC letters available via their websites.
Although some supplier generated forms have successfully been included as part of the medical record in the administrative law judge appeals process, I recommend refraining from the use of all supplier generated forms, including prescriptions.
Cheryl Ward is CEO of Agape Medical Management. She can be reached at 951-680-1640 or firstname.lastname@example.org.