CMS eases resupply requirements, but questions remain

YARMOUTH, Maine - Recent revisions to the documentation requirements for CPAP resupplies are a “huge win,” but industry stakeholders want further clarification.

CMS will now assume that medical necessity has been established for replacement of accessories for beneficiary-owned CPAP and RAD devices.

Still, stakeholders would like to see the agency clarify—in writing—what documentation HME providers still need to get paid for accessories.

“You need a detailed written order because you need one for everything, but what else do you need,”said Kim Brummett, vice president of regulatory affairs for AAHomecare. “My interpretation is you'd also need some sort of contemporaneous documentation from the chart that speaks to medical necessity and the ongoing use of the supplies.”

The revisions help to address situations where beneficiaries change providers—they moved, or their supplier closed or they simply wanted to go elsewhere—and it's difficult for the new provider to obtain the sleep study.

Competitive bidding further complicated this situation, forcing thousands of beneficiaries to switch from non-contract to contract suppliers.

“Some providers had thousands of spreadsheets with thousands of patients they just didn't have documentation for,” said Brummett. “This is so much easier to handle.”

While the guidance doesn't mean a reprieve from audits, it does streamline the process somewhat, say stakeholders.

“Suppliers really shouldn't relax their protocols for vetting accessories-only claims, but this scales back the number of documents the contractors are going to ask for,” said Andrea Stark, a reimbursement consultant with MiraVista.

Provider Ron Evans plans to keep doing what he's always done, regardless of the recent revisions.

“We have good guidelines on what we need to be able to bill for supplies,” said Evans, owner of Phoenix-based Valley Healthcare Group. “We are still going to attempt to obtain everything, but this could give us some potential help if we've exhausted all our efforts to still be able to provide supplies and make sure Medicare pays for them.”