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David McGill Blogger

A New Template for O&P

Posted by David McGill | May 21, 2013

The Centers for Medicare and Medicaid Services have posted a draft Lower Limb Prosthesis Electronic Clinical Template on its website. The four-page document "describes the data elements that CMS believes would be useful in supporting the documentation requirements for coverage of Lower Limb Prostheses."

The "Background" section of the template notes that the ordering physician's documentation must support the medical necessity of the device delivered to the beneficiary, and that prosthetists' records aren't sufficient by themselves for establishing medical necessity because the prosthetist has a "financial interest in the claim outcome."

What does the draft template require?

The draft template consists of 8 main sections as follows:
  1. Chief complaint;
  2. History of present illness (with 5 sub-sections);
  3. Past medical and surgical history (with 2 sub-sections);
  4. Social History (with two sub-sections);
  5. Review of Systems (with 8 sub-sections that have 21 sub-sections of their own);
  6. Physical exam (with 8 sub-sections that have 13 subsections of their own);
  7. Beneficiary assessment; and
  8. Plan.
What does this mean to me?

Today it means nothing, as this is just a draft. However, if adopted, this document could have a profound impact on how your business operates. CMS has announced that it will host a series of Open Door Meetings in the future to discuss the draft template. It is critical that you review this thoroughly and actively participate in these meetings. To monitor when those meetings will occur, you should click here at least once a week. 

As you'll see when you review the template in detail, the potential documentation requirements are voluminous. Given the statement in the "Background" section referenced above, we believe that CMS is stating that the physician's records would have to contain all of this clinical data, a task that could prove nearly impossible as a practical matter.

On the other hand, the draft template does have one near-term use: you can utilize it as a way of verifying how complete your records/the prescribing physician's records are against this expansive standard.

Ossur R&R will keep you posted as more information about the draft template becomes available in the future.   

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