The Centers for Medicare and Medicaid Services (CMS) has published a draft document on its website that, in its words, “will assist physicians with documenting the physician notes that substantiate the need for a Lower Limb Prostheses.” AOPA believes that the draft template, in its proposed form, actually represents imposition by CMS of a serious new hurdle to Medicare beneficiaries in receiving prostheses and prosthetic components that are necessary to restore their function and facilitate necessary physical rehabilitation.
The draft template contains four pages of information that physicians are requested to document ranging from the primary complaint of the beneficiary, to a complete patient history, to a listing of potential co-morbidities that may or may not have any bearing on the patient’s ability to properly wear and function with a particular prosthesis.
AOPA is very concerned that physician failure to complete the documentation requested in the proposed template will lead to further denial of legitimate prosthetic claims by AOPA members who are effectively meeting the functional needs of their prosthetic patients.
CMS has announced that they will hold several open door forum conference calls to solicit feedback on the proposed template from the Medicare supplier community. AOPA plans to attend all of these forums in order to ensure the proper representation of its members concerns regarding the proposed template but is also encouraging individual members to join these calls and provide feedback as well. The first open door forum is scheduled for Tuesday, May 28, 2013 from 1:00-2:00 p.m. EDT.
The first link is to the draft template that CMS has published on its website. This second link contains the dial-in information for the open door forum call scheduled for May 28, 2013. This final link is to the CMS site where all of this information may be found in a consolidated manner.
AOPA is preparing and will soon release a response to CMS underscoring some significant concerns about and shortcomings of the proposed template. The response, once available, may be viewed here.