1 Why were changes made to the Wheeled Mobility Device policy? In response to the logistical concerns observed during the transition period for this policy implementation, verbiage changes were made for clarification purposes in the sections 2, 32, and 34 of the Wheeled Mobility Device LMN form. The updated Wheeled Mobility Device (WMD) policy, letter of medical necessity (LMN) forms, and instructions www.huskyhealthct.org/providers/providers_wheeled_mobility.html, will be implemented on July 1, 2014. Other modifications and clarifications aim to address the questions posed to the Department of Social Services (DSS) and Community Health Network of Connecticut (CHNCT) within this Frequently Asked Questions posting. What other policy changes were made? Verbiage changes and an increase in time deadlines [see Section I, #3a] were made in the Wheeled Mobility Device Guidelines Instructions: Section I, #3a Completing the relevant sections of the attached Wheeled Mobility Letter of Medical Necessity form, the referring health care professional(s) submit(s) typed clinical documentation, which confirms medical necessity and effectiveness for the specific member, including a clinical assessment and associated rationale for the requested DME within the member’s customary and anticipated environments. This documentation must validate:  the member received an objective, onsite evaluation by a licensed occupational and/or physical therapist, which included the onsite collaboration of the DME provider; and  the evaluation occurred within the past 6 months for persons living in the community, or 3 months for persons living in a nursing facility, from the documented evaluation date; and  included the provision of actual DME trials and simulations and a comparison of various DME options; and  the requested DME will restore or facilitate participation in the individual's usual mobility related activities of daily living (MRADL) tasks within their customary and anticipated environments. Frequently asked question: To ensure the member is receiving a quality assessment, comparisons of the essential components, such as WMD frame choice, seating components, are required under #39 on the LMN form. If all available options are equally effective to address the member’s needs, this needs to be documented. Section I, #3c The request is substantiated by a medical evaluation by the member’s primary care provider, which may be either a specific evaluation for a customized wheelchair, or other evaluation of the member, such as the most recent history and physical examination and subsequent progress notes; completed or updated within the past 6 months for persons living in the community or 90 days for persons living in a nursing facility. For members with Medicare coverage, provide the Face-to-Face examination for the specified DME required by the Centers for Medicare & Medicaid (CMS), which will also meet Connecticut Medicaid’s medical evaluation requirement. 2 Section II, #3 The Wheeled Mobility Device Guidelines must be utilized after January 1, 2014 for an authorization request for a Wheeled Mobility Device. Currently, the typewritten or handwritten Letter of Medical Necessity forms will be accepted. After January 1, 2015, the requirement for only typewritten forms will be re-evaluated. Section II, #5  If sections 38n – 38w are not necessary, these pages can be discarded.  When the DME Provider uses the Clear Coverage prior authorization process, photographs are accepted. Adherence to appropriate HIPAA and other permissions is necessary. Photographs should not be faxed. Section II, #8 If special consideration is needed regarding a specific prior authorization request that does not meet the Wheeled Mobility Device Policy guidelines, the evaluating clinician should contact Nancy Shuster, EdS, MS, OTR, ATP; DME Clinical Analyst 203-949-6164. Can you please explain the prescription requirements for WMD? For skilling nursing facility and intermediate care facility residents:    If a CMAP-enrolled attending MD/DO, APRN, or PA sign the W-628 prescription, their signature is not required on p. 13 of the Wheeled Mobility Device Letter of Medical Necessity form, and must match the information in sections #9 - 11 of the LMN form. If the Interdisciplinary Team (IDT) requests that the physician sign the form on p. 13, the physician’s contact information must match the contact information on #9 - 11. A physiatrist or orthopedist can prescribe a customized wheelchair, given his/her collaboration with the member’s Primary Care Physician and incorporation into the member’s overall Plan of Care. For the home based client:  A CMAP-enrolled attending MD/DO, APRN, or PA must sign p. 13 of the Wheeled Mobility Device Letter of Medical Necessity form, following the electronic signatures. This is the prescription for the customized wheelchair. A separate prescription is not needed. The prescribing physician’s contact information must be provided in #9 - 11 of the LMN form. Why is the health care clinician’s contact information required? The evaluating occupational and physical therapist’s contact information is required, including ALL sections on p. 13; i.e., name, credentials, CT license, agency, full address, phone number, fax number, and email address. The Department understands that some therapists do not have agency-specific email and/or are difficult to reach; however, contact information is needed to enable the CHNCT DME Team to contact the therapists to expedite the medical necessity determination process. The WMD LMN form has been altered to include the “Preferred” phone, fax, and email information. Note that all email correspondences regarding confidential information utilize the CHNCT secure email system. 3 If an evaluation for a Wheeled Mobility Device is performed at an agency outside the home, how does the evaluating team perform the Accessibility Survey? As documented in Section I, #3f of the Instructions, the completed Accessibility Survey confirms that the requested wheeled mobility device, including the projected dimensions, was evaluated in the home with the member and/or their designee. An Accessibility Survey is required for persons living at home and not required persons residing in a Skilled Nursing or Intermediate Care Facility.) The therapist’s clinical evaluation including the actual trials of the wheelchair frame and seating components and the onsite collaboration with Assistive Technology Professional (ATP), may occur at a non-home location. However, the Accessibility Survey should validate that the requested Wheeled Mobility Device was actually evaluated in the intended environment; i.e., home, to address mobility-related activities of daily living access. Although ideally the member should trial the exact Wheeled Mobility Device in the home, this is not always possible without adequate sizing, seating components, and hardware customization. Rather, the focus of the survey is on accessibility barriers and environmental demands, given the manufacturer’s projected WMD dimensions; i.e., turning radius, width, length, seat height. The Accessibility Survey must be signed by the member, or assigned designee, who confirms that this survey was performed by the evaluating ATP or a DME Provider designee; i.e., technician. When additional information is requested by the DME Team at CHNCT, what procedure should be used? When additional information is requested by CHNCT, a due date will be provided by the CHNCT DME Team member, which is designed to prevent a “lack of information denial” of the requested Wheeled Mobility Device. Otherwise, a “lack of information denial” might be necessary to ensure compliance with the Connecticut federal court decision that requires DSS and CHNCT to issue decisions on all DME prior authorization requests within a specific time period. See Ladd v. Thomas, 14 F. Supp. 2d 222 (D. Conn. 1998). A “lack of information denial” does not indicate that CHNCT has determined that the Wheeled Mobility Device funding request is not “medically necessary.” Rather, this means that inadequate information was provided to make a medical necessity determination. Why is DSS/CHNCT expecting detailed clinical documentation? The emphasis of the DME Team is to ensure that the member received a comprehensive, objective, quality evaluation and that all variables were considered by the evaluating team. The medical necessity determination can only be made based upon the clinical information received by the CHNCT DME Team. By providing a detailed comprehensive evaluation, the Wheeled Mobility Device outcomes aim to enhance beneficial health and functional outcomes. Regarding additional information requests to the evaluating therapist: The therapist’s response to requested clinical information must be written solely by the evaluating therapist on the affiliated agency’s letterhead, and include the date the document is written, member’s name, Medicaid number, therapist’s name, credentials, and preferred contact information. The original LMN form should not be altered. Documentation pertaining to “Additional information requests” must be sent by the therapist directly to CHNCT and from the DME Provider. A due date for this information will be sent to the therapist by the CHNCT DME Team. 4 Regarding additional information request for the DME Provider, including the Assistive Technology Professional (ATP): The response to requested technical information must include the date the document is written, member’s name, Medicaid number and preferred contact information. The original LMN form should not be altered. If appropriate, the updated DME quotations or prescriptions should be attached. Who completes the Wheeled Mobility Device LMN document? Some evaluating therapists are reporting that some Wheeled Mobility Device LMNs are written “collaboratively” with the evaluating Assistive Technology Professional (ATP). Although the evaluating ATP should indicate which sections he/she wrote via an asterisk, the ATP cannot coach the evaluating therapist regarding the clinical content or write any clinical section. The documentation for the requested components should not be software-generated or generic in nature. The evaluating therapist must personally document all clinical sections of the Wheeled Mobility Device Letter of Medical Necessity without collaboration with the ATP, and explain why the requested components are needed for the specific member. The evaluating therapist should utilize the DME Provider quotation to assure consistency between the evaluating team’s recommendation for the medically necessary components and the quotation. To address the above issue, the disclaimer pertaining to the therapist’s signature on p. 13 of the LMN form was changed to, “I certify that I wrote this report and I am the Licensed Occupational and/or Physical Therapist identified below. I have included my credentials, affiliated agency, address, and contact information. My signature affirms that I personally wrote each section of this report, except where an asterisk is designated, based upon my own clinical knowledge, training and evaluation of the person’s medical condition.” References: o RESNA Code of Ethics http://resna.org/certification/RESNA_Code_of_Ethics.pdf o American Physical Therapy Association Code of Ethics for the Physical Therapist www.apta.org/Ethics/Core/ o American Occupational Therapy Association Code of Ethics and Ethics Standards www.aota.org/About-Occupational-Therapy/Ethics.aspx Who should we call if we have questions regarding procedures or regarding a specific Wheeled Mobility Device request? For questions regarding a specific request, contact CHNCT Utilization Management Intake 800440-5071, ask to speak with the “DME Team” and you will be directed to the correct person handling the specific DME funding request. 5 What are the requirements of the electronic signature for the evaluating therapist and physician? Electronic signatures must conform to the Conditions for DSS Acceptance of Electronic Signatures. Acrobat/Adobe or other non-agency based signatures are not permissible. If the health care practitioner’s agency does not comply with the DSS Electronic agreement, a handwritten signature is required. The completed LMN can be scanned, faxed, or submitted electronically through CHNCT Clear Coverage method. Conditions for DSS Acceptance of Electronic Signatures In order for DSS to accept electronic signatures on the Provider’s medical records, the Provider shall, at a minimum, meet the requirements that are listed below. In addition, the Provider shall have written policies governing the assignment and use of electronic signatures on medical records that reflect these requirements. The requirements are as follows: In order to authenticate and safeguard confidentiality of electronic signatures, the Provider shall assign each User of an electronic signature (“User”) at least two (2) distinct identification components, such as an identification code and a password, which, together, shall constitute a “unique code.” For the purposes of this Addendum, the User’s name will not suffice as a password.    Before assigning the unique code, the Provider shall verify the identity of the User.  Each User shall certify, in writing, that, the User will not release his/her User identification code or password to anyone, or allow anyone to access or alter information under his/her identity.  Each Provider and each User shall certify, in writing, that the electronic signature is intended to be the legally binding equivalent of the User’s traditional handwritten signature. The unique code assigned by the Provider to a User shall not be assigned to anyone else. The Provider shall certify, in writing, that the User is the only person authorized by the Provider to use the unique code that was assigned to him or her. The Provider who uses electronic signatures based upon use of identification codes in combination with passwords, as described above, shall use the following additional controls to ensure the security and integrity of each User’s electronic signature: (a) Ensure that no two Users have the same combination of identification components (such as identification code and password); (b) Ensure that passwords are revised periodically, and no less often than every 60 days, except as otherwise agreed to in writing by DSS; (c) Follow loss management procedures to electronically de-authorize lost, stolen, missing or otherwise compromised documents or devices that bear or generate identification code or password information and use suitable, rigorous controls to issue temporary or permanent replacements; (d) Use safeguards to prevent the unauthorized use or attempted use of passwords and/or identification codes; and (e) Test or use only tested devices, such as tokens or cards that bear or generate identification code or password information to ensure that they function properly and have not been altered. If a Provider uses electronic signatures based on two (2) components that are other than identification codes in combination with passwords, the Provider shall use the additional controls as set forth in (a) through (e) of this paragraph as applicable to those identification components. Providers must use a secure, computer-generated, time-stamped audit trail that records independently the date and time of User entries, including actions that create, modify or delete electronic records. Record changes shall not obscure previously recorded information. Audit trail documentation shall be retained for a period at least as long as that required for the medical record and shall be available to DSS for review and copying.