08/22/2022    Paul Kesselman, DPM

Discontinuation Certificates of Medical Necessity

Recently there has been a flurry of messages from
DME MAC and CMS contractors regarding the
discontinuation of Certificates of Medical
Necessity (CMN) for dates of service effective
January 1, 2023. While I will provide a lengthy
description of this issue in an upcoming article in
Podiatry Management, I felt it necessary to
disseminate this clarification statement.

Certificates of Medical Necessity (CMN) are formal
specialized documents which are provided by
Medicare for specific categories of
DMEPOS. These include devices typically prescribed
and ordered but not dispensed by podiatrists
including but not limited to wheelchairs, TENS,
Bone Stimulators, PCD and NPWT. Other categories of
CMN not prescribed by podiatrists are power
operated wheelchairs, oxygen, CPAP, hospital beds
and more.

Self-generated "Certificates of Medical Necessity"
are really not the formal CMN endorsed by CMS nor
are they addressed by this announcement nor are
they currently acceptable as medical documentation.
In most cases these other "pseudo CMN" forms are
those typically developed by surgical dressing,
orthotic and prosthetic or shoe manufacturers or
distributors who think they can create an all in
one shortcut form to ease the paperwork burden for
their customers. In some cases, the physician
(DPM/MD/DO) has created their own "CMN" and there
is often little to no supportive documentation in
the patient's medical record.

It should be made clear that the CMN forms which
Medicare recently announced to be eliminated will
have absolutely no effect on the burden of
supplying all the same required documents for
shoes, AFO, surgical dressings and/or any other
DMEPOS covered device.

Any non-CMS endorsed CMN which you generate
yourself, or is provided by a colleague,
manufacturer or distributor should be met with
skepticism. These are considered supplier generated
forms and not considered part of the medical
documentation the patient's chart needs to support.

The process by which Medicare will replace the
formal CMN or DIF process has not yet been
announced. But again, do not be fooled by the
announcement that "CMN" will be eliminated on Jan 1
2023 and that this will somehow ease your
documentation and administrative burden. This
announcement will virtually have no effect on
podiatrists who supply their own patients with DME.
The final word: Continue to document according to
the requirements of the LCD.

Paul Kesselman, DPM, Oceanside, NY

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