On Friday, February 9, 2018, it was announced that legislation was passed that CMS will now consider othotists and prosthetists notes as part of the patient's medical record. Specifically, 13 Section 1834(h) of the Social Security Act (42 U.S.C. 1395m (h)) has been amended by adding at the end the following new paragraph:
‘‘(5) DOCUMENTATION CREATED BY ORTHOTISTS AND PROSTHETISTS - For purposes of determining the reasonableness and medical necessity of orthotics and prosthetics, documentation created by an orthotist or prosthetist shall be considered part of the individual's medical record to support documentation created by eligible professionals described in section 1848(k)(3)(B).''.
Note that this change does not eliminate the requirement that the physician order the equipment and appropriately document the medical need for it in his notes. It is imperative that practitioners continue to remain consistent in their notes with those of the physician's.
There is still the need for LCDs, IOMs and other CMS publications to be appropriately updated, however, the bottom line is that the Orthotist and Prosthetist notes are now officially part of the medical record for purposes of Medicare medical necessity and claims audits!
The van Halem Group is working to obtain more information on the implementation and effective dates of updated policies. Continue to follow our blog and check back for more information on this change, as it becomes available.