7 Element Order
While our previous pre-payment audits for K0823's have been approved for payment, and regardless of the fact that our documents were reviewed by an "expert" and found to meet Medicare's documentation guidelines - my last audit was denied. Here is why:
Our 7 element order is a blank form prepared by our office. We provide this blank Order to the physician only AFTER the face to face examination has been completed, per Medicare guidelines. The heading on our form says "Physician Order for
Power Mobility Device." Another part of our form asks for "Pertinent diagnoses/conditions that relate to the need for the
power mobility device: _________." According to Medicare - because these headings say "Power Mobility Device" - it is considered "prompting" the physician to order a power mobility device.
I explained that we do not tell them what PMD to order - nor do we force them to order anything. I pointed out that Medicare guidelines state that the 7 element order can
only be completed by the physician AFTER the face to face exam has been done. If the physician is asking to move onto the next step of completing the 7 element order, it is a foregone conclusion that the physician feels a PMD is necessary. If the physician
hadn't reached that conclusion during the face to face, there would be no reason to even fill out a Rx. Also note that we used the generic term "Power Mobility Device" and the physician himself hand wrote in "Power Wheelchair" in the "Item Ordered" field.
The following is the article referenced by Medicare in their denial of our claim:
Power Mobility Devices - 7 Element Order
Obviously this rule is open to the individual processor's interpretation. I can see where they felt our Rx was "leading" - I don't have to agree with it. Just wanted to warn anyone else who may have similar documents. I am a firm believer that if it isn't one thing it WILL be another. Hopefully we can all share these experiences with one another to help everyone get their paperwork into compliance.
On a more humorous note - the CSR told me "The physician already knows what information needs to be contained on this 7 element order, you don't have to tell them." I'm glad she cleared that up for me.