I woke up with great expectations, excited to see some long-time friends from the profession, obtain clarification on billing and coding questions that come up in the office, and meet some new people. I was attending a full-day Medicare seminar on durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS), and I walked away with an article topic.
The day started with a PowerPoint presentation that was simply a line-by- line reading of the Local Coverage Determination (LCD) for Lower Limb Prostheses. When the presenters read the passage about the Centers for Medicare & Medicaid Services (CMS) requiring patients to be ambulatory for Medicare to consider a device reasonable and necessary, a man from the audience asked, “What is Medicare’s definition of ambulatory? How far must a patient walk in order for Medicare to consider a patient ambulatory— is a stand pivot transfer adequate, five feet, ten feet, 100 feet?” The experts did not have an answer, and the audience discussed it among ourselves while the seminar presenters seemed to just listen in. Another question was, “Can you obtain a verbal Advance Beneficiary Notice of Noncoverage (ABN) over the phone?” The experts answered no, they were unaware of any regulation allowing us to obtain an ABN over the phone. I then corrected them, citing the policy that states CMS allows a provider to obtain a verbal ABN if it is followed up with a written one. Additional general questions posed to the CMS “experts” during the session were answered incorrectly—and were then corrected with policy cited by audience members.
During the audits and appeals section of the seminar, the presenters referred to an old, outdated Administrative Law Judge form that was replaced a few months prior.
Some questions were asked and answered by audience members because the expert panel was struggling and did not know the answers. In response to one of the billing questions, one panelist replied, “I don’t know; we don’t bill.”
I began to feel sorry for the CMS representatives because they were not prepared and/or trained to answer the variety of questions about real-life DMEPOS billing scenarios. They also appeared to have little success getting information to address audience concerns via instant message with supervisors at their central office.
I was left feeling that they were unable to interpret policy and were only able to cite LCDs verbatim. At that point I realized that we, the providers, must be the experts. Ultimately, it is up to us to interpret the LCDs, keep up to date with policy changes, and apply the regulations to our everyday situations.
I cannot emphasize this enough. We must not only know the policies, but we need to be aware of updates and changes as they occur.
I recommend that you assign someone in your practice to be a CMS policy expert. Task that individual with keeping up to date so he or she can ensure your practice is on the forefront of CMS policy changes. To do so, I suggest signing up for listservs, enrolling in webinars, and regularly reading policies and proposed policy changes. The following are useful sources for finding this information:
- CGS Listserv Notification Service: www.cgsmedicare.com/medicare_dynamic/ls/001.asp
- Noridian Medicare Email Lists: https://med.noridianmedicare.com/web/jddme/fees-news/email
- Noridian Online Training: https://med.noridianmedicare.com/web/jddme/dmepos/orthotics-and-prosthetics
- The Medicare Learning Network (MLN) information, listserv, and web-based training: www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNGenInfo/Index.html.
Erin Cammarata is president and owner of CBS Medical Billing and Consulting.She can be contacted at erin@cbsmedicalbilling.com.
