Georgie Blackburn

When it comes to obtaining mobility assistive equipment (MAE) through Medicare, nothing is more important than the information that is documented in the patient's medical record. Providers have heard this message since local coverage determinations (LCDs) were updated in 2002—indicating the basis on which a beneficiary qualifies for coverage is the documented medical record and not the CMN/order.

The record can reflect various sources: physician notes, PT or OT notes, home health notes, tests, and the list goes on. It sounds like a simple message. After all, we're talking about physicians and other clinical staff who document diagnostic history, which includes: how the patient presents; what type of MAE is needed and why it is needed; range of motion; upper and lower extremity strength; ambulation status; self-propulsion; and more.

Where it gets iffy

Physicians must enter MAE information in the same way that other patient information is normally charted. Therefore, provider-designed forms are not acceptable. Plus, consider that every professional documents the patient medical record differently—some in a cryptic manner, some with loads of extraneous information irrelevant to the mobility device, and many illegibly. A few physicians write everything on the prescription itself, and put nothing specific in the chart notes.

While policy requirements differ for manual and power mobility documentation, somewhere in the physician's notes there must be an entry stating the patient was seen for the purpose of mobility. The clinician or physician notes must also indicate why the beneficiary cannot safely use a lesser level of MAE.

Providers must be able to determine if the medical record information received meets policy mandates in advance of providing a product and billing Medicare. Don't forget that applying the KX modifier to a HCPC indicates a provider has information that the beneficiary qualifies for Medicare payment. Without the KX, the claim is not paid; with the KX, the expectation is that the medical record information is on file.

Industry consultants have hinted, suggested, encouraged, and ultimately directed providers to think smart and obtain the medical record information in advance of providing product. Savvy providers who operate in a defensive mode have determined where their greatest liability lies or instituted internal procedures to collect the needed information prior to delivery in all product lines. Those working with power mobility understand that we must obtain all information prior to delivery because it is noncompliant if we supply a power wheelchair or scooter without all the information in hand.

The power mobility device (PMD) policy even dictates a timeline for information to be collected—within 45 days of the face-to-face examination. And what constitutes a face-to-face examination? Remember, it is not always the date the physician sees the patient. Also, PMDs must be delivered within 120 days from the documented face-to-face date, or 180 days from the response date of an advance determination of Medicare coverage (ADMC) request. In audit, if the timelines are not evident, the money goes back.

The trick is training staff to know what information is required, then training staff to identify the information within the medical record, which, incidentally, differs with each referral source. How do providers make certain staff is adequately trained to recognize required MAE information? More importantly, how do we train staff to effectively communicate to referral sources what is missing without offending or agitating to the point that they order elsewhere? Don't forget, providers are attempting to service customers in a timely manner and maintain profitability amid the monumental e-mails, faxes, and phone calls to get the documentation right.

Since the onset of the national coverage decision in 2005, removing bed/chair confinement and establishing the mobility-related activities of daily living approach to warranting product, state associations and industry groups have presented an array of programs for providers. Remember, CMS advised providers to educate referral sources. We thought we understood, but recent K0823 audits initiated by TriCenturion highlight ongoing PMD documentation confusion.

The time has come for a national presentation to serve as a comprehensive resource for physicians, clinicians, and all others who enter information into the patient's medical record for all levels of MAE. The program needs to demonstrate a physician examination and clinical assessment, plus detail the role of the provider, and what we can and cannot do to facilitate the documentation process.

The American Association for Homecare and the University of Pittsburgh have designed such a program. Circle May 29, 2008, on your calendar and plan to attend in person or by webcast.

Georgie Blackburn is vice president of government relations and legislative affairs at Blackburn's, Tarentum, Pa. She serves as secretary of the American Association for Homecare and can be reached via e-mail through the HME Today editor: .