Weigh in on Eliminating CMN and DIF Documentation Forms
On May 27th 2015, the Centers for Medicare & Medicaid Services (CMS) conducted an “Open Door Forum” to discuss the possibility of eliminating the Certificate of Medical Necessity (CMN) and Durable Medical Equipment (DME) Information (DIF) forms as required documents to determine medical necessity. Participants were asked for their recommendations and how eliminating the forms would impact them.
The forms addressed in the forum include:
846 Pneumatic Compression Devices
847 Osteogenesis Stimulators
848 Transcutaneous Electrical Nerve Stimulators
849 Seat Lift Mechanisms
854 Section C Continuation Form
10125 External Infusion Pumps
10126 Enteral and Parenteral Nutrition
Initially, participants expressed reluctance to give up the long tradition of using these documents. They also seemed concerned about the “trickle down” effect on other documentation that requires information from CMNs and DIFs. Callers pointed out that, without CMNs and DIFs, these “downstream” documents, such as LCDs, would also need to be revised, or something else would have to fulfill the requirements currently met by CMNs and DIFs.
However, as the forum progressed, other participants recounted the burdensome tasks associated with obtaining physician signatures and maintaining these documents. And additional callers reported that the documents were of no value or caused problems because they have been known to contradict the medical records. Therefore, many felt that eliminating the extra forms and often redundant data collection would eventually prove helpful in avoiding errors due to inconsistencies between the forms and the medical records.
Even if these forms are eliminated, providers will still need to obtain physicians’ orders for these items, and your internal clinical documentation will have to justify the use of this equipment. Therefore, it would be prudent to review your current documentation requirements and start planning to incorporate any changes you may need if and when these forms are no longer required.
Current CMN/DIF forms can be found by going to: http://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/CMS-Forms-List.html and then entering the form number in the “filter on” box at the top of the page.