CMS released an update to the Standardized Documentation Language template in October of 2014. This template is used to populate the Documentation section of the Local Coverage Determinations (LCDs). The template was first implemented in February of 2012 to bring uniformity and consistency to the LCDs.
Most of the changes in the October update stem from previously posted clarifications and updates released by the DME MACs primarily related to the Face-to-Face rule. By periodically incorporating the updates into the LCD they ensure that providers can rely more heavily and consistently on the one-stop shop known as the LCD and policy article. However, there was a significant change to the documentation requirements for Proof of Delivery in instances where equipment is retained from a prior payer (the patient switches to Medicare for the first time).
CMS has always educated that at the time of transition, it is the supplier’s responsibility to evaluate the coverage criteria to determine the beneficiary meets Medicare guidelines. It is also expected the supplier will secure an updated proof of delivery document and simultaneously determine that the equipment is in operational order and should last the patient five years from the date they enter the Medicare program. In this update, however, CMS takes this assessment to a whole new level. Suppliers are now to be required to obtain an attestation statement from the beneficiary (or their designee) that stipulates the supplier has examined the equipment, it is in good working order, and meets Medicare requirements.
The directive stipulates, “For the purposes of reasonable useful lifetime and calculation of continuous use, the first day of the first rental month in which Medicare payments are made for the item (i.e., date of service) serves as the start date of the reasonable useful lifetime and period of continuous use. In these cases, the proof of delivery documentation serves as evidence that the beneficiary is already in possession of the item.”
These changes will be incorporated into future LCDs and policy article revisions, which we will likely see published over the course of the upcoming months. To see the CGS notice including the full text of the updated language click here.