East Carolina University. Tomorrow starts here.®
 
The Brody School of Medicine Office of Compliance
Compliance Wise-Fall 2007


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Durable Medical Equipment Certificates of Medical Necessity: Ensure the DME Supplier has Completed the Description of Equipment Before Providing Your Signature

Have you ever received a request by a durable medical equipment (DME) supplier for your signature on a Certificate of Medical Necessity (CMN) in which the section describing the patient equipment is blank? It is very important to make sure that the DME supplier has specifically described the equipment on the CMN prior to providing your signature. The Office of Inspector General (OIG) has expressly stated that signing a CMN when the equipment description is incomplete could lead to criminal, civil and administrative penalties against both the physician and the DME supplier. By signing the CMN, the physician represents that (i) he or she is the patient’s treating physician and the information regarding the physician’s address and unique physician identification number (UPIN) is correct; (ii) the entire CMN, including sections completed by the DME supplier were completed prior to the physician’s signature; and (iii) the information related to medical necessity is true, accurate, and complete to the best of the physician’s knowledge.

By signing an incomplete CMN, a physician may unknowingly certify medical necessity for medically unnecessary or overly expensive equipment. In doing so, a physician risks being involved in potentially fraudulent conduct by unscrupulous DME suppliers since the physician has no knowledge of what equipment is ultimately purchased for the patient. The business practices of many DME suppliers have been under intense scrutiny by the OIG and the Department of Justice (DOJ) due to the millions of dollars that CMS has spent for DME supplies and equipment over recent years. Therefore, before signing a CMN, always be sure that the CMN has been fully completed by the DME supplier.