CMS Is Not PRA Compliant On Power Mobility Devices

The documentation collection associated with the final rule entitled
Medicare Program; Conditions for Payment of Power Mobility Devices,
Including Power Wheelchairs and Power-Operated Vehicles, CMS is seeking
re-approval of the collection of information requirements associated
with the final rule, CMS-3017-F (71 Fed. Reg. 17021), published on April
5, 2006.

The final rule eliminated the Certificate of Medical Necessity (CMN), a
form used by physicians to certify the medical necessity of power
mobility equipment and replaced it with a prescription and undefined set
of patient medical records. In addition, CMS contractors also require
an additional two-page detailed product description to be developed by
the supplier and completed by the physician. It is my understanding
that this detailed product description document was never submitted to
OMB for approval.

CMS has provided little, if any, guidance to physicians as to what
specific documentation will be needed to establish medical necessity,
unnecessarily increasing the paperwork burden on already busy medical

The current documentation standard, moreover, is contrary to the Obama
Administration priorities of increasing health care efficiencies,
utilizing health information technologies, and increasing utilization of

Unless CMS creates clear, fair, and objective documentation
standards,the uncertainty and subjectivity resulting from the current
implementation of the rule harms Medicare beneficiaries by making it
more difficult to get medically necessary equipment, undercuts the
ability of physicians to prescribe medically necessary equipment, and
unfairly increases the burden and cost to Medicare participants as well
as the Medicare program.

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