CMS audits and documentation

CMS audits and documentation

Brittany Stresing

5/12/2021

I wanted to add on to someone else's post from the other day because they
beat me to the [unch on writing an email.
Regarding CMS requirements in particular, we listened to the recent CMS
webinar which seems to continue to add more detail they want from us yet
this is not listed anywhere so it seems like literally anything could be
selected as not enough detail. For example, we cannot simply describe that
they garden daily which requires kneeling and walking on uneven ground etc
but they saying we have to document the acreage and type of things gardened
specifically. I am going to be basing this off what a patient tells me and
hoping it is correct. But nowhere is there a list of what
information in this type of detail is required so where does it end? And
this is for our documentation which is just in addition to doctors but
doesn't hold weight when CMS doesnt want it to. Also, there is nowhere
specifying what measurement is needed for validating a socket replacement.
So we can spend money buying softwares to scan and document size changes
but does this matter if we don't know what differences are needed to be
safe in an audit. Are hand measurements accepted? It has never said they
are not? Do we need patients filling out forms about their
recreational activities and go in detail about each possible activity (like
i said the acreage that they garden)? Does this even hold any weight? I
sometimes struggle to get details out let alone acreage or measurements
from patients, and what if CMS checks and this info is not correct? I
didn't drive to the patients home to measure their garden nor should I have
to. Again, doctors documentation means more yet they aren't being
audited for this info or sent a Dear Physicians letter saying all MDs are
required to document this.

I was recently having a conversation about this with another practitioner
and it just seems like we can keep spending money that we are not
reimbursed for but we are willing to in technology to allow us to validate
our measurements and shape changes but how do we even know this is enough?
We have no real guidelines so it seems like we could get picked on at any
moment to say well you didn't specify that it was 0.07 acres of gardenias
and chilli peppers that he gardens and also we see your measurements but
0.85cm we don't feel is enough of a change in volume now. It used to be
sock ply, but then that didn't seem to be enough. So what is it that we all
can go off of to know what it is specifically they want. Is it a certain
amount of change in one area of the limb (ex: a bulbous leg that is no
longer bulbous by ___mm) or what? I know most of us want to just do the
right thing and follow the rules, but the rules are clear as mud. We can
invest 50k in the best software to measure and validate, but if we don't
even know the rules what did that expense do. It could be worth it if it
allows us to get paid and stay paid, but we have to assurance of this.

I think we all just want to know the rules so we can get all the proper
documentation, treat the patient properly, get paid for our services, and
actually keep that money in a few years and not have the goal post changed
on what is required in documentation. I know I am not alone since I have
been having this discussion often with many practitioners lately and we all
seem annoyed at the clarity or rules/ documentaion at this time.

Thank you in advance.

Brittany Stresing, CPO FAAOP