THE
SURVEYOR
I SPRING 2014
CMS QUALITY
STANDARDS
AND THE CLIENT
RECORD
Greg Stowell, ACHC Clinical Compliance Educator for DMEPOS, Pharmacy & Sleep
The influx of Recovery Audit Contractor (RAC) and Comprehensive Error Rate (CERT) audits has forced Home/Durable Medical
Equipment (HME) providers to look at what documentation should be included in the client/patient record. It is not uncommon to hear
providers say “I don’t have to have the information in the client’s record; I just need to know I can get it in an audit.” Obtaining all the
pertinent support documentation can be challenging for providers, but the consequences of not getting this information in advance
are significant. Did you know that the CMS Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Quality
Standards actually address this issue? By not having this information, CMS may view you, the provider, as being in violation of its
Quality Standards.
The DMEPOS Quality Standards (dated October 2008, Section II: Supplier ProductSpecific Service Requirements, A. Intake & Assessment) states:
1. THE SUPPLIER SHALL:
Consult with the prescribing physician as needed to confirm the order and to
recommend any necessary changes, refinements, or additional evaluations to the
prescribed equipment, item(s), and/or service(s);
Review the beneficiary’s record as appropriate and incorporate any pertinent
information, related to the beneficiary’s condition(s) that affect the provision of the
DMEPOS and related services, or to the actual equipment, item(s), and service(s)
provided, in collaboration with the prescribing physician; and
The DMEPOS prescription, any CMNs, and pertinent documentation from the
beneficiary’s prescribing physician shall be kept unaltered in the beneficiary’s
record.
For more information, please contact Greg Stowell at
[email protected].
Does this mean that all
relevant information
must be in the client/
patient record?
CMS thinks so. As providers you
have many regulatory entities
imposing complex, and sometimes
conflicting, rules. National Coverage
Determinations (NCDs) and Local
Coverage Determinations (LCDs)
govern many authorizations and, later,
audit defense. Don’t get caught off
guard by having CMS state that you
are out of compliance with Quality
Standards by neglecting to have all
required information in the client/
patient record.
A C C R E D I T AT I O N C O M M I S S I O N f o r H E A LT H C A R E
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