In what it described as part of “ongoing efforts to increase access to care and to reduce unnecessary administrative burdens for stakeholders,” The Centers for Medicare & Medicaid Services (CMS) has discontinued the use of Certificates of Medical Necessity (CMN) and Durable Medical Equipment (DME) Information forms (DIFs) for claims with dates of service on or after January 1, 2023.
The decision extends flexibilities implemented during the pandemic. CMS cites “improvements in claims processing and medical records management” as having made CMNs and DIFs redundant to information already available within the claim or medical record.
Suppliers will no longer need to complete these forms for claims for:
- CMS-484 – Oxygen
- CMS-846 – Pneumatic Compression Devices
- CMS-847 – Osteogenesis Stimulators
- CMS-848 – Transcutaneous Electrical Nerve Stimulators
- CMS-849 – Seat Lift Mechanisms
- CMS-854 – Section C Continuation Form
- CMS-10125 – External Infusion Pumps
- CMS-10126 – Enteral and Parenteral Nutrition
The change stemmed from CMS’s relaxation of coverage requirements for home oxygen therapy in 2021, including dropping the CMN for these claims.
Home oxygen therapy has been in high demand for Medicare beneficiaries since the onset of COVID-19. During the pandemic, CMS provided flexibilities that allowed medical necessity documentation to be based on a prescription and Standard Written Order (SWO). However, CMS did not go so far to remove the medical record review in its changes to the home oxygen therapy National Coverage Determination (NCD) beyond the public health emergency.
Following the NCD changes, CMS announced that it will be discontinuing CMNs and DIFs for other product categories. Perhaps seeing that the Medicare Administrative Contractors (MACs) were successfully processing claims without CMNs during the PHE, CMS eliminated CMNs and DIFs for additional product categories.
The Council for Quality Respiratory Care (CQRC), a coalition of home oxygen therapy provider and manufacturing companies, argues that the change does not go far enough towards ensuring that patient access to supplemental oxygen supplies is not restricted. And the group has garnered some degree of support on Capitol Hill.
On August 10, 2022, U.S. Reps. Terri A. Sewell (D-Alabama) and Larry Bucshon (R-Indiana) and 20 other members of Congress submitted a letter to Health and Human Services Secretary Xavier Becerra and CMS Administrator Chiquita Brooks-LaSure requesting that they instruct Medicare contractors to rely upon a Standard Written Order for processing home oxygen claims. They expressed concern that “Medicare contractor documentation requirements do not create barriers to beneficiaries receiving these therapies.”
Interestingly, CMS said any claims submitted after January 1, 2023, with CMNs and DIFs that are no longer required will be rejected. Suppliers will have to resubmit those claims without the CMN or DIF.
Given that CMNs and DIFs can be time consuming, it is not surprising that the reaction to their elimination has been largely positive. However, there is some concern that the change in documentation requirements may result in improper processing of claims. It will take some time before the impact of the elimination of CMNs and DIFs can be assessed.