Medicare Fee-for-Service Compliance Programs: Simplifying Documentation Requirements

As part of our Patients over Paperwork Initiative, Medicare is simplifying documentation requirements so that you spend less time on paperwork, allowing you to focus more on your patients and less on confusing and time-consuming claims documentation. We've made some important changes already. We need your suggestions on where to focus next. Please send your feedback and suggestions to MedicareMedicalReview@cms.hhs.gov.

To make it easier for providers and reduce improper payments and appeals, CMS is implementing the Documentation Requirements Simplification (DRS) Initiative. The key objectives of this initiative are:

Recent Updates

1. Shipping immunosuppressive drugs

   BEFORE: Suppliers could only ship immunosuppressive drugs to the patient’s home following an inpatient stay.

   AFTER: Suppliers may deliver the initial prescriptions of a beneficiary’s immunosuppressive drugs to an alternate address, such as the transplant facility or other location where the beneficiary is temporarily staying.

   For more information: CR 11072 (PDF) and CR 11172 (PDF) (Implementation dates April 3, 2019 and April 18, 2019)

2. Home health recertification documentation

   BEFORE: Physicians needed to include a separate statement about how much longer home health services would be needed as part of the home health recertification.

   AFTER: A separate statement is not needed.

   For more information: CR 11104 (PDF) (Implementation date April 22, 2019)

3. DMEPOS order requirements

   BEFORE: There were different order elements required for different types of DMEPOS.

   AFTER: There’s a single, clear set of requirements for ordering DMEPOS items. There’s also now a single list of DMEPOS items potentially subject to certain payment requirements.

   For more information: Fact sheet on the CY 2020 final rule (CMS-1713-F) Final Rule, (Implementation Date: January 1, 2020) See 84 FR 60648

4. Ambulance certification statements

   BEFORE: There was confusion about whether a specific, separate and distinct form was needed when a physician certifies the need for non-emergency ambulance transport.

   AFTER: A specific, separate form is not needed. Other existing documentation may serve as the certification if the appropriate information is included. In addition, we added to the list of non-physician practitioners that may sign a certification statement when one cannot be obtained from the physician. Licensed Practical Nurses, social workers and case managers were added to the list which already included physician assistants, nurse practitioners, clinical nurse specialists, registered nurses and discharge planners.

   For more information: CMS-1715-F (Implementation Date: January 1, 2020) See 84 FR 62568

Learn about past changes