by Jared Staheli
June 18th, 2015
The Paperwork Reduction Act (PRA) of 1995 §44 USC 3500, et seq. requires that the Director of the Office of Management and Budget approve any collections of information performed by or for the Federal Government unless the collection fits within exceptions for audits and investigations. Absent such approval, the collection violates the PRA and agencies may not hold the public to the requirement. Therefore, DMERCs must adhere to the following:
1. Power operated vehicles additional documentation requirements
A Certificate of Medical Necessity (CMN) must accompany initial claims for power operated vehicles (POV). Except during the course of audits and investigations, DMERCs must not require that additional documentation accompany all POV claims. DMERCs may continue requesting information during the course of audits and investigations and when developing individual claims on either a pre- or a post-payment basis. If DMERCs choose to conduct such investigations, they must follow the guidelines in the Program Integrity Manual, Chapter 3.
2. Power wheelchair additional documentation requirements re: make and model name/number
There must be no requirement that all claims for power wheelchairs include the make and model name/number of the wheelchair separate from the claim or the CMN.
The CMN, an OMB approved information collection form, can be used to collect this information. Specifically, DMERCs can require that the make and model name/ number of the power wheelchair be included in Section C of the CMN. Section C requires the supplier to include a narrative description of the items, options and accessories ordered.
3. Power wheelchair additional documentation requirements re: functional abilities
There must be no requirement for suppliers to submit additional documentation to describe a beneficiary's medical condition and functional abilities when the supplier bills for a higher level of equipment than previously supplied.
While it is appropriate to avoid paying for duplicate equipment, it is inappropriate to require this documentation for all claims for "higher level equipment." DMERCs may choose to perform pre- or post- payment probe samples to review these types of claims individually in order to determine medical necessity. If DMERCs choose to conduct such investigations, they must follow the guidelines in the Program Integrity Manual, Chapter 3.