Region D DMERC sneers at snail mail

WASHINGTON - A sketchy proposal by CMS to modify the CMN process by licensing the DMERC's right to require “supporting documentation…to make appropriate claims determinations” is worrying HME industry insiders who fear that the proposed change could create even more confusion. Published Nov. 18 in the Federal Register, the proposed revision to the CMN would require suppliers and physicians to “supply additional routine supporting documentation” on an as-needed basis. CMS characterizes the likely frequency of the requests for more documentation as occasional. “They talk about additional documentation but they don't say what form or format,” said Steve Azia, counsel to the Power Mobility Coalition. “As a result, it could create the opposite of what is intended - a system that is less clear and less consistent.” The proposed revision will be out for public comment for 60 days, or until Jan. 17. The new CMN would be implemented upon approval by the Office of Management and Budget (OMB). The Federal Register notice was posted by a CMS officer who serves as a Paperwork Reduction Act team leader in the Medicare program. Since, on the surface, the notice looks like more paperwork for providers, reimbursement expert Jane Bunch wonders how the reduction part of the Paperwork Reduction Act factors in here. Additionally, she asks why providers should be expected to do more work without any payment increase? As vague as plans for the modifications are, reimbursement specialists are lining up in opposition to more paperwork. “There should be no need to have carriers going into physican records to determine medical necessity beyond the CMN,” said Terri Maggio, the executive directior of the Jersey Association of Medical Equipment Suppliers and president of DMEasy. CMS itself said as much earlier this year, when a May 1 program memorandum clarified a rule that says the DMERCs can't require providers to submit additional documentation for all power operated vehicle claims, except during audit or investigation. HME