In the May 5 issue of its MLN Connects Newsletter, CMS quietly announced plans to discontinue all requirements for Certificates of Medical Necessity (CMNs) and DME Information Forms (DIFs) in 2023. While we are not surprised by the complete elimination, the future implementation date only fuels the ongoing drama surrounding current CMN requirements for oxygen.
The notice was exceptionally brief, clocking in at just 77 words, but it does include a statement that continues the disconnect between coverage and claims processing:
“Suppliers must continue to submit CMN and DIF information for claims with dates of service before January 1, 2023.”
As we detailed in February, Form CMS-484, the oxygen CMN, is incompatible with revisions the agency made to its Home Use of Oxygen NCD in September 2021. In fact, the first two questions will most certainly cause oxygen claims for patients with acute diagnoses - covered broadly under the NCD – to deny. In January, we explained why MACs, QICs, and ALJs will be forced to reverse erroneously denied claims on appeal.
To avoid the onerous burden that this administrative sinkhole places on suppliers, patients, and even the DME MACs, specific guidance is needed to address claims for services started or restarted:
CMS already issued a change request giving DME MACs until June 14 to process oxygen claims in accordance with the revised NCD. The change request also requires the DME MACs, upon supplier request, to reprocess denied claims that should have paid under the revised NCD. Still, these requirements do not speak to the incompatibility of the CMN or how suppliers should manage renewals for patients that started therapy before September 27.
There are a number of stop-gap measures the DME MACs can implement to remedy the issue until January 1, 2023:
The continued disparity in coverage and processing benefits no one, and unfortunately, the future elimination of the CMN doesn’t do much to solve the problem.
SOURCE LINKS
https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2022-05-05-mlnc#_Toc102553739
The notice was exceptionally brief, clocking in at just 77 words, but it does include a statement that continues the disconnect between coverage and claims processing:
“Suppliers must continue to submit CMN and DIF information for claims with dates of service before January 1, 2023.”
As we detailed in February, Form CMS-484, the oxygen CMN, is incompatible with revisions the agency made to its Home Use of Oxygen NCD in September 2021. In fact, the first two questions will most certainly cause oxygen claims for patients with acute diagnoses - covered broadly under the NCD – to deny. In January, we explained why MACs, QICs, and ALJs will be forced to reverse erroneously denied claims on appeal.
To avoid the onerous burden that this administrative sinkhole places on suppliers, patients, and even the DME MACs, specific guidance is needed to address claims for services started or restarted:
- Before the NCD revision (prior to September 27, 2021).
- During the implementation gap (September 27, 2021, to June 13, 2022).
- Between MAC implementation and CMN elimination (June 14, 2022, to December 31, 2022).
CMS already issued a change request giving DME MACs until June 14 to process oxygen claims in accordance with the revised NCD. The change request also requires the DME MACs, upon supplier request, to reprocess denied claims that should have paid under the revised NCD. Still, these requirements do not speak to the incompatibility of the CMN or how suppliers should manage renewals for patients that started therapy before September 27.
There are a number of stop-gap measures the DME MACs can implement to remedy the issue until January 1, 2023:
- Provide a pathway for suppliers to administratively complete the CMN in a manner that clearly identifies it as something other than a medical record prepared by the referring physician.
- Automatically add a “dummy” CMN to all oxygen claims to effectively bypass the obsolete processing logic.
- Adopt a modifier bypass similar in effect to the CR modifier and COVID-19 narratives used to bypass oxygen CMN requirements during the PHE.
The continued disparity in coverage and processing benefits no one, and unfortunately, the future elimination of the CMN doesn’t do much to solve the problem.
SOURCE LINKS
https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2022-05-05-mlnc#_Toc102553739
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