PMD Documentation: Fight the Temptation to Cut Corners
- By Jim Stephenson
- Apr 01, 2010
When it comes to gathering power mobility device (PMD) documentation, how many times do you hear from a physician, “Well, so-and-so was in here yesterday, and all I had to do for them was sign a form — why are you asking me for so much more information”?
The guidelines for PMD documentation are extremely overwhelming to a physician, especially when he or she is getting confl icting information from different suppliers. In a perfect world everyone would play by the same rules and help alleviate the massive amount of confusion that is being infl icted upon the physician community. Medicare has left the burden of educating physicians about face-to-face examinations, seven-element orders and detailed product descriptions up to us as an industry. Finding an opportunity where you are afforded enough time to make sure the physician understands the complex nature of documenting for a PMD can be difficult.
Understanding Face-to-Face & Forms Policies
Physicians are busy and have a huge amount of responsibility for their patients, so any way to save time by simply signing a form is particularly appealing to them. It’s human nature: We all want to take the easy route as often as we can. Unfortunately, taking the easy route with PMD documentation can become quite expensive for a supplier when Medicare comes looking for medical records to conduct a post-payment audit.
What many physicians don’t realize is there are several statutory requirements they must meet in order for their patient to receive Medicare reimbursement for a PMD. They have to conduct a face-to-face examination. They must record the results from the exam in the patient’s medical record. They cannot write the prescription until a face-to-face exam has occurred. And they must provide this information to the supplier within 45 days. By simply signing off on a supplier-generated form or document, they are not in compliance with these statutes.
The next issue that many of you will encounter is the use of forms to document the face-to-face examination. Some suppliers provide forms for the physician to complete, giving the false impression that these documents are a sufficient record of the in-person visit and medical evaluation. Even if the physician completes this type of form and includes it in the patient’s medical record, it does not provide sufficient documentation of a comprehensive assessment of the patient’s mobility needs.
It is essential the physician be aware of this, because if they complete a form, it is still expected that there be notes about the visit in the patient’s medical records to substantiate the information on the form. So to be compliant with the policy, those suppliers using forms would be asking the physician to document the face-to-face exam twice, once on the form and once in the medical record — talk about extra work! We all know this does not happen, but that is the only way a form can be used within the guidelines.
To keep it simple and consistent, the physician should document the results of the face-to-face exam in the same format that he or she uses for other entries in their patient medical records.
Recognizing Errors, Developing Solutions
It can be tempting to cut corners when there is the potential loss of a referral on the line, but in the long run, standing your ground and obtaining the necessary information will help you keep your money. Use of forms, incomplete documentation and missing key information are among the top reasons for Medicare to deny PMD claims. With the recent reimbursement cuts for power mobility devices, you cannot afford overpayments or the time required to defend yourself in an audit. It is always better to do it right the first time.
So, how do you respond to a physician who has been led to believe incorrect information? First, let the physician know that you realize his/her time is valuable and that you are only requesting information that is absolutely necessary to qualify their patient. Remind them that Medicare created the documentation guidelines, that you understand the rules are very labor intensive, but you are simply trying to follow the policy.
Ultimately, there is no black-and-white answer to this question, but there are a few tools you can keep handy to ensure that the physician will recognize it’s not just you asking for more than what you need to do your job.
Keep a complete copy of the PMD local coverage determination (LCD) on hand with the documentation requirements highlighted. There is also a letter written by the medical directors from each of the Medicare Administrative Contractors (MAC) outlining the requirements for documenting and prescribing PMD that you can leave behind as a reference. This letter is available on each of the DME MAC Web sites.
The most important thing to keep in mind is there are no short cuts to this process; the policy is what it is. With a little luck, Medicare will start clamping down on those who are misleading the physician community and creating headaches for those who are painstakingly playing by the rules.
This article originally appeared in the April 2010 issue of Mobility Management.
Jim Stephenson is Reimbursement & Coding Manager for the Rehab Department
of Invacare Corp.