- Q1. Our PMD Prior Authorization (PAR) request was non-affirmed because our documentation did not include a financial attestation statement. When a portion of the face-to-face examination is performed by a licensed/certified medical professional (LCMP), does this statement have to be included in the PAR documentation we submit?
A1. The Power Mobility Devices LCD states that, if the report of a licensed/certified medical professional (LCMP) examination is to be considered as part of the face-to-face examination, there must be a signed and dated attestation by the supplier or LCMP that the LCMP has no financial relationship with the supplier. When applicable, this statement must be submitted as part of the documentation for a PMD prior authorization request, an ADMC request or in response to any additional documentation request letter related to power mobility.
- Q2. According to the Power Mobility Devices LCD, in cases where the PWC request goes through the Advance Determination of Medicare Coverage (ADMC) process, there is an exception to the rule that delivery must be within 120 days following completion of the face-to-face examination. Does this exception also apply to PMD subject to the Prior Authorization Demonstration Project?
A2. No, this exception does not apply to power mobility devices subject to prior authorization. The equipment must be delivered within 120 days following completion of the face-to-face examination.
- Q3. It is my understanding that, for rental items, a supplier is entitled to a month’s rental even if the beneficiary is hospitalized for a portion of that month. We have a beneficiary whose monthly rental anniversary date is the 5th of the month. Recently this beneficiary was hospitalized on the 4th and discharged on the 6th. The RAC is recouping the payment for this month because we used the anniversary date of the 5th as the date of service. The RAC provided instruction that the date of service should have been changed to the 6th and remain changed for every month after that. Is this correct?
A3. You are correct that a full month’s rental is paid even if the item is used for only part of the month. However, that fact is not relevant or applicable to the scenario in your question. The reason is because your scenario crosses over the rental anniversary date. When a beneficiary is in a facility on the anniversary date of the rental, the supplier must not bill. Instead the supplier must wait until the beneficiary is discharged to continue billing the rental. The discharge date becomes the new billing anniversary date. Future months follow on the new schedule. Thus the RAC is correct that the monthly anniversary date should be changed to the 6th of the month.
Suppliers are required to monitor the beneficiary’s use of rental items and discontinue billing when use of the item occurs such as in the scenario described. There is no waiver because a supplier did not ask or was not notified.
In today’s heightened review environment, suppliers are strongly encouraged to be mindful of even the most seemingly minor requirements as they are likely to be stringently enforced.
- Q4. According to the “Numerical Rounding Rules for Medicare” article, suppliers are allowed to use standard numerical rounding rules when values are not reported as a whole number. We have a CPAP patient who, according to the compliance printout, used the PAP device an average of 3.8 hours per night during a consecutive 30-day period. Can we round this result up to 4?
- A4. Please note that the article states that rounding rules cannot be applied where Medicare policy makes it clear that a specified level is absolute. The PAP LCD states that compliance is met if the beneficiary uses the device a minimum of 4 hours/night for at least 70% of the nights during a consecutive 30-day period. The 4 hours/night minimum is an absolute value that is not eligible for the application of rounding rules.
- Q5. If a beneficiary receiving oxygen was originally a Group 2 qualifier and the retest required for recertification is not timely, but when the retest is done they qualify as Group 2, is a second recertification required in three months just as if they were a new Group 2 beneficiary?
- A5. Once the recertification occurs, regardless if that happens timely or is delayed, there is no requirement for any additional recertification. In other words, once the late retesting and re-evaluation occur, there is no further need for retesting again in another 61-90 days.
- Q6. If a beneficiary receiving oxygen was originally a Group 2 qualifier and the retest is not timely, but when the retest is done they qualify as Group 1, do they require a recertification in one year just like if they were a new Group I beneficiary?
- A6. No, only one recertification is required, regardless of the new test results required for recertification.
- Q7. We have created an order form for home blood glucose monitoring supplies. This form includes a list of multiple items and sometimes the treating practitioner will cross out items he/she does not wish to order. In this situation, is this order still considered valid?
- A7. When suppliers create order forms that contain a list of multiple items, some of which may not be applicable, the treating practitioner must designate which specific item(s) are to be dispensed. This may be accomplished by a check mark beside or circle around the desired item(s) or by striking through (removing) the undesired item(s).
In the event that the physician corrects, amends, or crosses out certain item(s) on the order, it must be done according to CMS guidelines. The proper method for correcting a record is for the treating practitioner to make a single line through the unwanted information (preserving the original text), inserting the correct information (if applicable) and then signing/initialing and dating each change/correction.
- Q8. We are seeing some medical records that have the encounter date at the beginning of the progress note. The note is signed by the treating practitioner but the signature is not dated. Are medical records acceptable if the author does not date his/her signature?
- A8. Chapter 3 of The Medicare Program Integrity Manual states that, if a relevant regulation is silent on whether or not a signature must be dated, the documentation must contain enough information for the reviewer to be able to determine the date on which the service was performed or ordered.
Chapter 5 specifically states that it is mandatory for the treating practitioner to date his/her signature on a detailed written order. It is, however, silent on the subject of medical records. So, unless a specific NCD or LCD lists such a requirement, it is not mandatory to date a signature on a medical record as long as there is an encounter date recorded in the document. It is, however, advisable to date the signature.
A Celerian Group Company
Medical Review FAQs – Spring 2013
March 27th, 2013