The Centers for Medicare & Medicaid Services held a special Open Door Forum to discuss suggested clinical elements that should be included in the electronic clinical template for lower limb prosthesis.
At the beginning of the forum, CMS clarified that the template is intended as an educational effort to help physicians understand what CMS needs to document to satisfy coverage requirements for lower limb prosthesis. These forums are meant to help CMS identify a list of data elements that physicians need to document during a face-to-face visit with a Medicare beneficiary about to receive a lower limb prosthetic.
Several O&P practitioners voiced concern during the forum that the more details physicians had to include in their reports, the easier it would be for Recovery Audit Contractors to find something missing and deny their claim. However, CMS felt that this was a generalized statement for only specific claims, and did not apply to every claim.
“[The Electronic Clinical Template for Lower Limb Prosthesis] is not intended to create a list of things that a physician needs to fill out in its entirety. It’s intended to highlight the important areas that can support medical necessity for the device that’s ordered, and that will certainly depend on the specific device that the physician orders,” Michael Handrigan, MD, medical officer for the Provider Compliance Group at CMS, stated. “For example, if the cardiovascular system is an important aspect of the overall health status then these are the elements within that section that we feel are important for the physician to fill out. It’s really intended to create an electronic backdrop for an electronic system that ultimately in the future will be able to walk the physician through the right elements to enter, not necessarily all of them on one particular patient.”
Providers are encouraged to direct questions to eclinicaltemplate@cms.hhs.gov. The next Open Door Forum for the electronic clinical template for lower limb prosthesis is scheduled for Sept. 11 at 4 p.m. EST.
