CMS taps CPAP, oxygen for documentation pilot

WASHINGTON - The ears of HME providers perked up during last week's AAHomecare Washington Legislative Conference, when CMS's Melanie Combs-Dyer said the agency was working on a documentation requirement lookup service for prescribing providers.

Combs-Dyer, the acting deputy director of the Center for Program Integrity, said CMS plans to pilot the service, which allows prescribing providers to look up documentation requirements at the time of service from their EHR or practice management system, in late 2018 or early 2019.

“This is wonderful news,” said Georgie Blackburn, vice president of government relations and legislative affairs at Blackburn's in Tarentum, Pa., from the audience.

What's more, looking at its pool of claims for high levels of utilization, errors and appeals, Combs-Dyer said CMS has tapped CPAP devices and oxygen therapy for two of the three pilots it will conduct.

As for the third? It probably won't be DME-related, Combs-Dyer said.

“The other payers felt like I did, that DME was a good place to start,” she said. “But I have a feeling they're going to want to move into other provider types, maybe home health or skilled-nursing, or maybe a certain hospital procedure.”

Asked why CMS is focusing the service on just prescribing providers, Combs-Dyers said, “They're the ones whose documentation is at fault in a situation where we deny a claim. It's rarely the (DME provider's) documentation.”

Based on a schematic that Combs-Dyer shared, an exchange based on Fast Healthcare Interoperability Resources or FHIR will connect the prescribing provider's EHR or practice management system with “rules libraries” built by payers—not only Medicare, but ideally, some Medicare Advantage plans and private payers, as well.

“We're hopeful (this will improve documentation),” she said.

Making required paperwork easier to find is one of a number of strategies CMS has for reducing the burden on provider compliance, Combs-Dyer said. Others: simplifying paperwork (“There's some stupid stuff that's out there and we're really trying to eliminate that stuff,” she said) and improving the audit process (“I believe the Targeted, Probe and Educate Program is quite promising,” she said).