Prosthetists criticize proposed template

BALTIMORE - A proposed clinical template for lower limb prostheses overlooks the way care is delivered, say industry stakeholders.

“They still don't seem to want to allow the prosthetists to have as much input as they probably should have in terms of documenting medical necessity,” said Ryan Ball, director of state policy for VGM & Associates.

CMS has posted a draft of the template on its website. The template features a series of prompts that would help physicians understand documentation requirements for prosthetic devices.

And that's the problem, say stakeholders.

“The physician is not as knowledgeable as the prosthetist,” said Kelly Wolfe, president of Regency Billing and Consulting. “That's their specialty, they should be able to fill out the template.”

Traditionally, physicians have relied on the prosthetist's expertise in determining what's best for the patient, but in 2012, CMS said that the prosthetist's notes are no longer considered part of the medical record—they must be included within the physician notes.

The template itself is overly lengthy and complicated, say stakeholders who criticized CMS for not seeking input from the prosthetic community.

“If CMS insists on creating a template, I would encourage CMS to ask current certified and practicing prosthetists to assist in the design and creation of the template,” said Wendy Miller, director of facility accreditation for BOC. “I would also suggest that CMS allow the prosthetist to complete the template during an evaluation of the beneficiary and then have the ordering physician review, corroborate and sign off on the recommended treatment plan.”

During a May 28 Open Door Forum, CMS official Melanie Combs-Dyer told listeners that the agency believes a template will help reduce high error rates for the devices.

“Often, the documentation does not substantiate the need for the lower limb device that is provided to patients,” said Combs-Dyer, deputy director of the Provider Compliance Group at CMS.

A similar template for power mobility devices has met with success, but CMS is wrong if it thinks it is appropriate to treat prosthetics in the same manner, says the American Orthotics and Prosthetics Association in a letter to CMS Administrator Marilyn Tavenner.

“I fear we can never make any progress toward solving the present problem so long as agency personnel want to re-tread purported solutions for power wheelchair over-utilization to the completely different and unrelated world of artificial limbs,” stated Tom Fise, executive director. “If a person is an amputee, the need for an artificial limb is pretty obviously a medical necessity.”