Another reminder!
O&P Physician Documentation
NAAOP ALERT: Participate In CMS Open Door Forum on Physician “Template”
When: Tuesday, May 28, 2013 from 2:00 to 3:00 p.m., EST Dial-In Number is:
800-837-1935; Conference ID # 75391152
In response to persistent advocacy from the O&P profession to fix the
physician documentation problem, CMS is unfortunately moving toward the
development and implementation of a physician documentation “template” to be
used by physicians in prescribing lower limb prosthetic care. NAAOP believes
this electronic template is another misguided DME solution for an O&P
problem, creates unrealistic documentation burdens on physicians, and will
lead to denials of claims based on the existence of specific medical
conditions in patients.
NAAOP strongly encourages all of its members to actively participate in an
Open Door Forum conference call this coming Tuesday afternoon. We must
demonstrate widespread disagreement with this proposed approach. If you have
good relationships with your referring physicians who might be willing to
also participate in the call, please alert them. A copy of the four-page
template can be downloaded by clicking the following link:
http://www.cms.gov/Research-Statistics-Data-and-Systems/Computer-Data-and-Sy
stems/ESMD/Lower-Limb-Prosthesis-Electronic-Clinical-Template.html
The following points illustrate NAAOP’s position but participants on the
call should speak their minds on this issue:
1. A template designed for physicians misses the point that the
prosthetist’s clinical records are part of the medical record for purposes
of determining medical necessity. Prosthetists are professionals under
Medicare law. (MIPPA Section 154)
2. In the alternative to a template, CMS should state publicly that
prosthetists’ clinical notes are part of the medical record and should
finally regulate BIPA Section 427 which establishes federal requirements to
link practitioner qualifications with the ability to be paid by Medicare.
3. If CMS insists on a clinical template for lower limb prostheses, it
should be directed at the essential elements that must be recorded by the
appropriately credentialed O&P practitioner for physician review,
corroboration, and approval.
4. The proposed 4-page physician template asks numerous, detailed questions
that will take physicians significant time to complete with no additional
reimbursement.
5. The template is full of information that suggests that Medicare
beneficiaries that have certain diagnoses will no longer be eligible for
coverage of advanced prosthetic components. Just because a beneficiary has a
medical condition (e.g., heart disease or impaired vision) does not make
them ineligible for advanced prosthetic components.
Paul E Prusakowski, CPO,LPO, FAAOP
President
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