OMB applauds
HCFA for its superior professionalism, policy, analysis, and
responsiveness to commenters' concerns in its PRA review and
revision of the Durable Medical Equipment Certificates of Medical
Necessity. HCFA's participation in the PRA process has been
exemplary. However, during the OMB review process, commenters have
raised several outstanding concerns that OMB believes deserve
HCFA's further consideration and resolution. OMB understands that
many of these concerns will require amend- ments to the National
Standard Format (NSF) and perhaps to DMERC operations. The NSF
electronic file structures are covered under this clearance action
along with the hard copy forms. HCFA invested in the National
Standard Format in January 1991 before submitting the requirements
for OMB review. Therefore, revisions of the NSF shall be made
consistent with the objectives of the Paperwork Reduction Act of
1995. OMB approves for use the revised CMNs through 4/97 under the
following conditions: 1) No later than 12/96, HCFA develops a third
one page wheelchair CMN to cover "standard" wheelchairs. "Standard"
wheelchairs are defined as manual wheelchairs in HCPCS codes K0001,
K0002, K0003, and K0004 and with 3 or less accessories; 2) HCFA
allows for private sector automation of the CMNs (in particular
sections B and C on the form) when the CMN information has been
electronically submitted to the DMERC and the hard copy CMN is used
solely for recordkeeping purposes. Without exception, the
computerized versions of the form must contain identical
questions/wording to the OMB-approved form in the same sequence,
with the same pagination, and identical instructions/ definitions
printed on the back of page one. CMN question sets may not be
combined. Within these constraints, flexibility will be allowed in
the computer font as articulated in OMB's later technical remarks;
3) The mandated NSF reflects the revised hardcopy CMNs and in the
future HCFA better coordinates PRA oversight of the hardcopy forms
and related electronic file structures; and 4) The revised CMNs and
DMERC computer screens for electronic transmission display the OMB
clearance number and disclosure statements as required by the
Paperwork Reduction Act of 1995 and 5 CFR 1320. Technical Comments
. To ensure that the programmatic objectives of CMNs are met, CMNs
may be computer generated if: 1) without exception, they meet the
requirements of item 2 above; and 2) are printed within the font
specifications recommended by commenters (see DEZINE HEALTHCARE
SOLUTIONS letter to NAMES dated 4/10/96, forwarded to OMB on
4/11/96) and agreed to by HCFA. In addition, to ensure adequate
industry reproduction, the computer generated CMNs should meet the
enclosed HCFA specifications; and . Computer generated instructions
appropriate for a particular CMN may appear in entirety on the back
side of the first page consistent with the above format
specifications. Finally, as suggested by public commenters, OMB
recommends that HCFA consider the following amendments: . In the
enteral nutrition CMNs, HCFA will consider providing respondents
the choice between specifying the HCPCS code or a narrative
description with the appropriate level of detail (e.g. dosage,
frequency, etc.) HCFA will discuss its decision on this matter and
its basis in the next submission for OMB clearance; . Redesign of
the CMN's Part B to include check-off blocks for "yes" and "no";
and . To allow for additional space in Part C, consolidation of
questions 5-7 in the wheelchair CMNs. Pending implementation of the
third streamlined wheelchair CMN, HCFA will implement all of its
revised CMNs including the two page forms for manual and motorized
wheelchair CMNs. HCFA actively should educate the
physician/supplier community in the use of these forms and inform
them that an additional streamlined wheelchair form (similar in
format but on one page) will be available in the next few
months.
Inventory as of this Action
Requested
Previously Approved
05/31/1997
05/31/1997
04/30/1996
6,800,000
0
6,800,000
1,130,000
0
1,130,000
0
0
0
This information is needed to
correctly process claims and insure that claims are properly paid.
These forms contain medical information necessary to make an
appropriate claims determination. Suppliers and physicians will
complete these forms.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Durable Medical Equipment Regional Carrier, Certificates of Medical Necessity