What one doc has to say about new rule
PITTSBURGH - A prime concern that providers have with CMS's proposal to use prescriptions for power wheelchair claims is their ability to get supporting documentation from physicians. While providers don't need to submit supporting documentation with their claims, they need to have that information on file, in case of further review or a post-payment audit. Michael Boninger, a physician and executive director of the University of Pittsburgh's Center for Assistive Technology, part of UPitt's medical center, sat down with HME News in September to provide a physician's perspective on the interim final rule.
HME News: Do physicians already collect the required documentation or is it a new burden?
Michael Boninger: It depends on the physician. If you talk about your average post-surgical follow-up visit with a surgeon, it won't contain any of the required information. If I were sent someone with a mobility problem, then my evaluation would be very similar to what's required. Aside from that specific type of referral, this type of documentation won't commonly be in the medical record. It would be rare.
HME: How do you see providers and physicians working together under this new rule?
Boninger: I don't believe this process will effectively work for dealers if they have to get every single clinician who currently refers to them to follow these regulations. There's too much to this process; there's too much that the docs have to sign. Let's say there's a dealer out there who currently gets a prescription from a patient that says wheelchair on it and that prescription is from a family practitioner, a neurologist, surgeon, anybody. Normally, what they'll do is take a look at the patient, and maybe there'll be a therapist involved or maybe there won't, and they'll send a CMN back to the physician, get it signed, and it's out the door. If that group tries to follow that same model but now tries to make sure all of the documentation is in the physician's medical record and forwarded back to them appropriately, I think they'll fail.
HME: What needs to happen?
Boninger: What I would do if I were a dealer is identify within the docs that normally refer to them, two or three that keep up with their paperwork the best and seem to have the most knowledge about wheelchairs. I think it's in their best interest for that to be a specialist in geriatrics or rehab medicine or neurology - some specialty that a general practitioner or surgeon would feel comfortable referring to. Then what happens, if they get a script for a wheelchair, they call that doc and they tell that doc, 'Here is the process you have to follow if you want to be the one to prescribe this wheelchair or you can refer them to this other doc.' I would say 97% of the offices will say 'No problem, here's the referral.' The patient goes to see the other doc, and the other doc is already educated in the process. They, working with the therapist preferably, can put together the necessary documentation and get it to the dealer. What they're doing is developing a little team.
HME: If dealers don't do this, how hard will it be for physicians to follow the rule?
Boninger: Impossible. They're a mass of people to move, and this is so low on the radar screen of your average doc. Dealers will have to educate those two or three docs, probably specialists in this rehab realm, and educate them and form a team. That they can do. It may actually lead to better care because, hopefully, that same doctor is looking at the patient and saying, maybe they don't need a wheelchair. Maybe they'd benefit from physical therapy or something else.
HME: How do physicians feel about the possibility of having more liability?
Boninger: It doesn't bother me, because it's what I do. When dealers call doctors and they say, "Hey listen, these are the reasons you may want to think about a referral," liability goes into that, especially if those physicians attempt to bill for those additional funds.
HME: Anything else?
Boninger: I don't think October is enough time. The other thing is it's really hard for me to comment without seeing what the local rules are going to be. This all goes down to the local rules. Also, the 30-day timeframe could have been handled differently. I can envision a situation where a doc sees a patient, does all of the documentation they need to do but feels like a therapist needs to be involved and exceeds that window.