Home Health & Hospice Week

Prediction: Change could mean more audits in the future. Home medical equipment suppliers could soon have an easier time ensuring Medicare patients get needed oxygen supplies.

But some industry insiders are scratching their heads over why the simplification effort wasn't extended to all HME items - and others worry the change will invite closer regulatory scrutiny down the road.

The Centers for Medicare & Medicaid Services has proposed revising the certificate of medical necessity for oxygen (CMS Form 484) by allowing physicians to use a signature and date stamp rather than having to supply that information by hand.

"To allow the physician stamp is certainly a step in the right direction," says Wayne Stanfield, executive director of the Home Care Alliance of Virginia. "[The change] would mean a tremendous improvement in turnaround time."

The draft CMN, published in the Jan. 25 Federal Register, also strikes the need to supply the name and address of the physician or other provider performing the qualifying tests for the oxygen benefit.

The proposed revisions - efforts to implement the Paperwork Reduction Act of 1995 - are part of a larger trend to cut red tape by allowing electronic and fax signatures in health care. CMS does not specify when HME suppliers would begin implementing the change.

Though Stanfield recognizes the benefits the simplified CMN process would bring to HME suppliers and their patients, he is still somewhat perplexed by CMS' proposal. The agency's decision to allow signature and date stamps on oxygen CMNs but not on CMNs for other items doesn't make sense, he says.

This double standard "creates an anomaly we'll be forced to police," he says. "It will irritate physicians beyond all belief." He plans to submit comments detailing those concerns.

Miriam Lieber of Lieber Consulting in Van Nuys, CA also sees a downside to the simplification effort. "We're entering the danger zone at this point," Lieber warns. "This means they're going to come and audit CMNs more closely. It could make things operationally more difficult."

In the same Federal Register notice, CMS proposes completely eliminating CMNs for hospital beds and support surfaces (CMS Forms 841 and 842, respectively). CMS also makes revisions to CMN forms for items including osteogenesis stimulators, electrical nerve stimulators and seat lift mechanisms.

Editor's Note: The Federal Register notice is at http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/05-1319.htm. Comments are due Feb. 24.