Certificates Gone but Not Forgotten

CMS is discontinuing certificates for medical necessity and durable medical equipment.

CMS is discontinuing Certificates of Medical Necessity and Durable Medical Equipment (DME) information forms effective Jan. 1, 2023.

You don’t need to complete these forms for claims with dates of service on or after Jan. 1, 2023:

  • CMS-484 – Oxygen
  • CMS-846 – Pneumatic Compression Devices
  • CMS-847 – Osteogenesis Stimulators
  • CMS-848 – Transcutaneous Electrical Nerve Stimulators
  • CMS-849 – Seat Lift Mechanisms
  • CMS-854 – Section C Continuation Form
  • CMS-10125 – External Infusion Pumps
  • CMS-10126 – Enteral and Parenteral Nutrition

In breaking this down, my favorite is the CMS-854-Section C Continuation form. The instructions on the form require:

  • Narrative description of all items, accessories and options ordered
  • Supplier’s charge
  • Medicare Fee Schedule Allowance for each item, accessory and option.

I would have to say requiring the physician to have all  this information for the DME that they prescribe is a daunting task indeed. I imagine many physicians have software that has the “Medicare Fee Schedule Allowances,” but this means that physicians, or really the folks doing their billing would have to make sure that the codes in the form agree with the DME the patient requires. 

Right up with the continuation form is the “Seat Lift Mechanism” form. The physician must answer the following questions:

  1. Does the patient have severe arthritis of the hip or knee?
  2. Does the patient have a severe neuromuscular disease?
  3.  Is the patient completely incapable of standing up from a regular armchair or any chair in his/her home?
  4. Once standing, does the patient have the ability to ambulate?
  5. Have all appropriate therapeutic modalities to enable the patient to transfer from a chair to a standing position (e.g., medication, physical therapy) been tried and failed? If YES, this is documented in the patient’s medical records.

It makes folks just want to scream, “They just need help getting out of a chair.” 

Let’s hope CMS keeps making our life easier.


Timothy Powell, CPA

Timothy Powell is a nationally recognized expert on regulatory matters, including the False Claims Act, Zone Program Integrity Contractor (ZPIC) audits, and U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) compliance. He is a member of the RACmonitor editorial board and a national correspondent for Monitor Mondays.

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