By Lindsay D. Andronaco RN, BSN, CWCN, WOC, DAPWCA, FAACWS
Public policy is an aspect that affects every day practice for most wound, ostomy and continence nurses, but is something that we do not generally think about. One health policy topic that is in the forefront of my mind is how the Centers for Medicare and Medicaid Services (CMS) is looking to change the process for how patients access durable medical equipment, or DME products. This change in public policy would affect the access of these necessary products to our patients.
CMS has been evaluating one subset of the Affordable Care Act that would require a physician to document that a physician, PA, NP or CNS, had a face-to-face encounter with the patient and preformed an examination within the six months prior to the written order for the durable medical equipment items. That documentation must warrant, based on the diagnoses codes and supporting clinical information, that the beneficiary is in need of the DME items ordered. The order must be co-signed by the MD.
This could pose more issues for those practice settings where there is limited access to MDs. Some states, such as New Hampshire, NPs are allowed to have their own practice. The policy does not allow room for these types of systems issues and show a comprehension of issues with access to MDs. If this process is not followed, this can result in denials and patients not having access to their required DME item. It could also mean that the patient, who may immediately require the DME item, tries to pay for this product out of pocket while the denial is appealed.
I feel that this proposal requiring that an encounter must occur within six months before the order is written for the DME is extreme and should be revised. This change will cause a roadblock for our patients' access to DME products. It also seems unnecessary for a MD to authorize this, as APRNS have been ordering DME items since 1997 under their scope of practice.
An example of a DME item is ostomy products. It has been requested under H. Res 152 and S. Res 95, that ostomy appliances be re-designated so it does not fall under the DME. Not only does having ostomy products under the DME leave them susceptible to DME-bidding, which is coming soon, but it also places roadblocks for the over 700,000 individuals with ostomies in the US. If these legislators ever sat with an individual with an ostomy and understood where they are coming from when they have emergency surgery, mucocutaneous separations, hernias, revisions, and stoma shrinkage after surgery, they would think twice about having it be so difficult for these patients to obtain access to these necessary medical products.
United Ostomy Associations of America. Available at: http://www.ostomy.org/ostomy_info/pubs/ColostomyNPG2011. Accessed April 17, 2014.
Wound, Ostomy and Continence Nurses Society. CMS to delay enforcement of some DME requirements - but not bidding. July 12, 2013. Available at: http://www.wocn.org/news/131999/CMS-to-Delay-Enforcement-of-Some-DME-Re…. Accessed on April 17, 2014.
Wound, Ostomy and Continence Nurses Society. A Public Policy Update. January 21, 2014. Available at: http://www.wocn.org/news/153490/A-Public-Policy-Update-from-the-WOCN-So…. Accessed April 17, 2014.
About the Author
Lindsay (Prussman) Andronaco is board certified in wound care by the Wound Ostomy Continence Nursing Certification Board. She also is a Diplomate for the American Professional Wound Care Association. Her clinical focus is working with Diabetic Limb Salvage/Surgical/Plastic Reconstruction patients, though her interests and experience are varied and include surgical, urological and burn care, biotherapeutics and Kennedy Terminal Ulcer research. Lindsay is the 2011 recipient of the Dorland Health People's Award in the category of 'Wound Ostomy Continence nurse' and has been recognized in Case In Point Magazine as being one of the "Top People in Healthcare" for her "passionate leadership and an overall holistic approach to medicine."
Lindsay is board certified in wound care by the Wound Ostomy Continence Nursing Certification Board. She also is a Diplomate for the American Professional Wound Care Association. In 2011, Lindsay was honored with the Dorland Health People's Award in the category of 'Wound Ostomy Continence nurse.'
The views and opinions expressed in this blog are solely those of the author, and do not represent the views of WoundSource, Kestrel Health Information, Inc., its affiliates, or subsidiary companies.
The views and opinions expressed in this blog are solely those of the author, and do not represent the views of WoundSource, HMP Global, its affiliates, or subsidiary companies.