CMS offers 120 day Documentation Grace Period

CMS has implemented a 120-day grace period for obtaining documentation for CPAP devices and supplies in areas included in Round 2 of competitive bidding, officials announced during an Open Door Forum July 9.

The move is in response to contract suppliers notifying CMS of their difficulty obtaining the required medical necessity documentation, which includes the doctor’s order for a sleep study and a copy of the study.

“Today, I would like to announce a transitional policy to facilitate and assist this process,” said Tangita Daramola, competitive acquisition ombudsman. “This has been a collaboration with CMS and suppliers.”

Round 2 of competitive bidding, which went into effect July 1, has forced a plethora of Medicare beneficiaries to switch from non-contract to contract suppliers, sending those contract suppliers on a wild goose chase to collect documentation to continue service.

During the Q&A portion of the forum, Kim Brummett, senior director of regulatory affairs for AAHomecare, asked Dr. Robert Hoover, the medical director for the Jurisdiction C DME MAC, who participated in the form: What about documentation that doesn’t meet the criteria?

“The grace period is a period to obtain the documentation,” Hoover said. “Whatever documentation you would need after Nov. 1, we would begin enforcing for audits.”

Brummett followed up: “So if I service a patient in August, get all the documentation in September and realize the study is not certified by a board certified doctor, I’m still exposed?”

Hoover responded: “That would be correct.”

A similar grace period was in effect during Round 1 of competitive bidding, Hoover said.

“We’ll be working on developing additional educational articles with more details,” he said.

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