Recognizing the wisdom of CDC advice to limit all in-person, face-to-face contact, CMS waived requirements for in-person encounters included in NCDs, LCDs, and policy articles for the duration of the public health emergency (PHE). The waiver does not, however, mean Medicare will pay for products and services that are not medically necessary. The distinction continues to confuse many patients, practitioners, and suppliers.
Even during the PHE, the medical records for every DME item still require some form of support for medical necessity. Practitioners need to observe, monitor, and survey patients to the fullest extent possible. When in-person encounters are not practical, medical practitioners should substitute virtual visits wherever possible.
Minimum Requirements
The DME MACs summarize nicely in a joint article the minimum criteria to support claims submitted during the PHE. To pass future audits, supplier records need to:
Federal law mandates a documented face-to-face visit for powered mobility and therapeutic shoes. The IFRs cannot suspend or override these federal mandates, so suppliers must ensure the treating practitioner documents either an in-person or a virtual telehealth visit before delivering either product type.
Suppliers can actively initiate and control many of these required variables. While suppliers must continue to request spontaneous medical records created by outside healthcare practitioners, CMS’s temporary waiver of in-person encounters allows suppliers to provide service to beneficiaries safely by using a wider range of medical records to support services during the PHE.
SOURCE LINKS
https://cgsmedicare.com/jc/pubs/news/2020/06/cope17942.html
https://www.govinfo.gov/content/pkg/FR-2020-04-06/pdf/2020-06990.pdf
https://cgsmedicare.com/jc/pubs/news/2020/05/cope17333.html
Even during the PHE, the medical records for every DME item still require some form of support for medical necessity. Practitioners need to observe, monitor, and survey patients to the fullest extent possible. When in-person encounters are not practical, medical practitioners should substitute virtual visits wherever possible.
Minimum Requirements
The DME MACs summarize nicely in a joint article the minimum criteria to support claims submitted during the PHE. To pass future audits, supplier records need to:
- Contain a compliant standard written order (SWO).
- Establish services are reasonable and necessary.
- Support medical necessity, continued medical need, proof of delivery, and correct coding.
- For powered mobility devices (PMDs) and therapeutic shoes, document the practitioner performed an in-person or telehealth visit no more than six months prior to ordering.
- Nurses’ notes.
- Home health assessments.
- Transcribed phone calls between the practitioner and the patient.
Federal law mandates a documented face-to-face visit for powered mobility and therapeutic shoes. The IFRs cannot suspend or override these federal mandates, so suppliers must ensure the treating practitioner documents either an in-person or a virtual telehealth visit before delivering either product type.
Suppliers can actively initiate and control many of these required variables. While suppliers must continue to request spontaneous medical records created by outside healthcare practitioners, CMS’s temporary waiver of in-person encounters allows suppliers to provide service to beneficiaries safely by using a wider range of medical records to support services during the PHE.
SOURCE LINKS
https://cgsmedicare.com/jc/pubs/news/2020/06/cope17942.html
https://www.govinfo.gov/content/pkg/FR-2020-04-06/pdf/2020-06990.pdf
https://cgsmedicare.com/jc/pubs/news/2020/05/cope17333.html
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