Once in a while the CMS announces a change that providers and suppliers like but find hard to believe. That is the case with the announcement of the elimination of the Certificate of Medical Necessity (CMN) and Durable Medical Equipment Information Forms (DIF). If you are a professional who has been ordering, or a durable medical equipment (DME) supplier who has been providing, equipment that required a CMN or DIF, this is a radical change to a process that you have been following for many years.
The CMN and DIF forms were originally required to help document medical necessity and to prove that the patient met the coverage criteria for selected DME, prosthetics, orthotics, and supplies. Treating physicians signed the CMNs and provided them to the DME suppliers, who submitted the CMNs with the claims for the equipment. The DME suppliers created/signed the DIF forms and submitted them with the claims for the equipment. Following are the frequently asked questions that this author has received about this major change.
Q: Is it true that CMS is eliminating the CMN and DIF forms?
A: Yes, CMS is eliminating the CMN and DIF forms effective January 1, 2023.
Q: Why is CMS eliminating the CMN and DIF Forms?
A: Because of improvements in claims processing and electronic health records (EHRs), the information on the CMN and DIF forms is redundant. Overall, CMS is on a mission to reduce provider and supplier burden, modernize processes, and increase customer satisfaction. Not only will eliminating the forms mean less work for physicians, other qualified healthcare professionals, and DME suppliers, but it will also reduce the number of documents that must be processed and saved.
Q: How will CMS obtain the medical necessity and coverage information once the CMN and DIF forms are no longer submitted with claims?
A: According to CMS, all the required information is either already on the claim form or in the patient's medical record. Keep in mind that the CMN and DIF forms never took the place of documentation in the medical record. If your DME Medicare Administrative Contractor (MAC) needs some information that is not on the claim, they will request the medical record documentation. Therefore, now is an opportune time to verify that your medical record documentation includes all the medical necessity and coverage information that is currently provided via the CMN and DIF forms.
Q: Is CMS eliminating all the CMN and DIF forms?
A: Yes, all the CMN and DIF forms will be eliminated, including:
CMS-484 Oxygen (NOTE: This CMN is not required during the COVID-19 public health emergency.)
CMS-846 Pneumatic Compression Devices (NOTE: Wound/ulcer management physicians and qualified healthcare professionals should be particularly interested in the elimination of the CMN for pneumatic compression devices. See Supplemental Figure, http://links.lww.com/NSW/A122.)
CMS-847 Osteogenesis Stimulators
CMS-848 Transcutaneous Electrical Nerve Stimulators (purchase only)
CMS-849 Seat Lift Mechanisms
CMS-854 Section C Continuation Form
CMS-10125 External Infusion Pumps (NOTE: This DIF is not required during the COVID-19 public health emergency.)
CMS-10126 Enteral and Parenteral Nutrition
Q: Is the standard written order (SWO) still required after December 31, 2022?
A: The elimination of the CMN and DIF forms is separate from the SWO. Therefore, the SWO is still required in 2023.
Q: The elimination of the CMN and DIF forms is great news. Can we begin eliminating the form submission before January 1, 2023?
A: No. CMNs and DIFs are still required to be submitted with claims for dates of service on or before 12/31/2022.
Q: Believe it or not, my company likes using the CMN and DIF forms. Can we still submit the forms for dates of service on or after January 1, 2023?
A: No. CMS is totally eliminating the CMN and DIF forms effective for dates of service on or after January 1, 2023. Therefore, continued use of the forms is not an option. In fact, any claims submitted with the CMN or DIF forms will be rejected by the Common Electronic Data Interchange. Once the rejection is received, the claim should be resubmitted without the attached CMN or DIF form. NOTE: A rejected claim is different than a denied claim, which requires an appeal.
Q: Will the Medicare Advantage programs still require the submission of CMN and DIF forms?
A: This author could not find anything in the Medicare Claims Processing Manual that clearly requires the Medicare Advantage programs to eliminate the forms. Therefore, the only way to know that answer is to contact each contracted Medicare Advantage program.
Q: Our coders and billers are not going to believe me when I tell them the CMN and DIF forms will be eliminated for dates of service on or after January 1, 2023. Could you provide the link(s) to the official document(s) that announced this huge change?
A: Yes, here are two references that you should share with your revenue cycle team:
1. MLN Matters Article SE22002 entitled Elimination of Certificates of Medical Necessity & Durable Medical Equipment Information Forms:https://www.cms.gov/files/document/se22002-elimination-certificates-medical-nece
2. Change Request 12734 Claims Processing Manual Update-Pub. 100-04 for Elimination of Certificates of Medical Necessity (CMNs) and Durable Medical Equipment Forms (DIFs):https://www.cms.gov/files/document/r11427CP.pdf
If you did not receive these notices in your email, take the time to sign up for the electronic mailing list of the MAC that processes your claims. The MACs are very conscientious about releasing important updates via their electronic mailing lists (new term for Listservs).
Author's Comments
Like all major Medicare changes, some implementation details have yet to be released by CMS and/or the DME MACs. Keep watching your email for further details. However, you should prepare now to stop submitting CMN and DIF forms with claims that contain dates of service on or after January 1, 2023, because that implementation detail is certain. Your preparations should include the following:
* Inform your compliance department about the eliminated forms so they have time to update ordering processes, EHR templates, and forms.
* Inform your EHR vendor that you will not be submitting CMN and DIF forms for dates of service on or after January 1, 2023.
* Contact your contracted Medicare Advantage, private payers, and so on to learn if they will still require CMN and DIF forms; adjust your workflow processes accordingly.