Providers to CMS: Yes, please drop CMNs

BALTIMORE - CMNs/DIFs are a burden HME stakeholders would like to see eliminated, they told CMS officials during an Open Door Forum last week.

“There was a time and place for CMNs,” said Ronda Buhrmester, a reimbursement specialist for The VGM Group, during the forum. “Providers already have to gather that info in the progress notes and it is redundant. It's time to eliminate CMNs.”

Currently, CMNs are required for oxygen, pneumatic compression devices, osteogenesis stimulators, TENS devices, seat lift mechanisms, and section C continuation forms. DIFS are required for external infusion pumps and enteral and parenteral nutrition. CMNs were eliminated several years ago for power mobility devices and hospital beds.

During the forum, CMS officials wanted to hear from HME providers about eliminating them altogether.

“CMNs were developed to provide evidence of medical necessity and we've found that CMN information often conflicts with the medical record itself,” said an official from the CMS Provider Compliance Group. “What is the impact (on providers) of eliminating the forms?”

Overwhelmingly, callers to the forum were in favor of dumping CMNs/DIFs, citing them as time-consuming and frustrating for both providers and physicians.

“The CMN is really a huge chore to get the physician to even fill it out,” said provider Lori Corey. “The amount of time we spend trying to get the CMN right does us no good in the end if our documentation was not in a row to begin with.”

However, callers were also quick to say that CMNs do offer objective criteria to establish medical need. Could the criteria be incorporated into the written order prior to delivery? Or, could the CMN be replaced with an electronic template, they asked?

“The concept of an electronic template has some logic built in,” said one caller. “It could make a world of difference in terms of being more meaningful and timely.”

In fact, CMS is considering electronic templates for PMDs, oxygen concentrators and lower limb prostheses, said Melanie Combs-Dyer, director of the Provider Compliance Group.

“There are more templates that we would like to develop in the future,” she said. “We are working to begin pilot testing some of those e-clinical templates.”