06/15/2018    Paul Kesselman, DPM

CMS Clinical Templates (Bret Ribotsky, DPM

The problem is that these templates are actually
far from good enough and would not pass an audit
conducted by any DME MAC, CERT, etc. That was
actually my point!The authors of these templates
as CMS employees or consultants to CMS didn’t
even have the requisite basic knowledge necessary
to properly answer two of the questions raised to
them.

If CMS really has intentions of educating
suppliers equal to or better than the MACs, I
suggest that CMS employs some of the same
interactive committees and tools used by the DME
MACs, which they clearly do not.

This apparent duplication of effort is at a
minimum is a waste of tax payer dollars. Either
CMS allows the DME MACs to educate the suppliers
and observes those forums and tools or they do it
themselves and has the DME MAC tow the line on
the LCD based on the CMS templates. This however
is not what is transpiring and it goes way beyond
therapeutic shoes. There are many other areas of
DMEPOS involving other policies. Despite the best
efforts of other agencies involved with auditing
DMEPOS claims in asking CMS to work
collaboratively with them on these educational
pieces, this has not happened.

This duplication of effort promotes nothing more
than conflicting opinions on policy, further
frustrates suppliers and is an absurd waste of
financial resources coming from our tax dollars,
further depleting the social security trust fund.

So much for reducing administrative burden and
streamlining ones understanding of an ever
expanding number of confusing policy directives.

In summary, I would urge suppliers and IT
companies to review the CMS templates but NOT use
them until all the kinks have been worked out.

Paul Kesselman, DPM, Woodside, NY

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