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November 17, 2022

CMN and DIF Elimination – Correct Coding and Billing

Joint DME MAC Publication

Effective for claims with dates of service on or after January 1, 2023, claims that are received with CMNs or DIFs attached will be rejected and returned to the supplier.

Background

As a trusted partner, the Centers for Medicare & Medicaid Services (CMS) engages with stakeholders across the health system to understand their experiences with CMS regulations, particularly how existing and proposed CMS regulations impact the experience of healthcare. CMS has received feedback from providers and suppliers that CMNs and DIFs are burdensome and duplicate information already available on the claim or in the medical record, so in response to this feedback, CMS is ending the need for CMNs and DIFs for all claims with dates of service on or after January 1, 2023.

Affected LCDs

Requirement of a CMN or DIF (CMS forms 484, 846, 847, 848, 849, 10125, and 10126) is eliminated for claims with dates of service on or after January 1, 2023 in the following DME MAC Local Coverage Determinations (LCDs) and LCD-related Policy Articles:

CMNs:

Osteogenesis Stimulators LCD (L33796) and related Policy Article (A52513)
Oxygen and Oxygen Equipment LCD (L33797) and related Policy Article (A52514)
Pneumatic Compression Devices LCD (L33829) and related Policy Article (A52488)
Seat Lift Mechanisms LCD (L33801) and related Policy Article (A52518)
Transcutaneous Electrical Nerve Stimulators (TENS) LCD (L33802) and related Policy Article (A52520)

DIFs:

Enteral Nutrition LCD (L38955) and related Policy Article (A58833)
External Infusion Pumps LCD (L33794) and related Policy Article (A52507)
Parenteral Nutrition LCD (L38953) and related Policy Article (A58836)

Claim Instructions

For claims with dates of service on or after January 1, 2023, suppliers must not submit a CMN or DIF with the claim. If a CMN or DIF is included with the claim, the claim will be rejected and returned to the supplier.

For claims with dates of service on or before December 31, 2022, if the CMN or DIF is required, it must be submitted with the claim, or be on file with a previous claim.

As a reminder, for dates of service affected by the COVID-19 Public Health Emergency (PHE) – i.e., claims with dates of service on or after March 1, 2020 and for the duration of the COVID-19 PHE – certain items or services do not require submission of a CMN or DIF for processing of the claim. CMS' interim final rule with comment (CMS-1744-IFC), which published on April 6, 2020, identified that clinical indications for coverage associated with certain LCDs and NCDs would not be enforced during the COVID-19 PHE. Based on claims processing issues that would result from missing information (for instance) on CMNs or DIFs, in relation to the non-enforcement of clinical indications, CMS also determined that CMNs and DIFs would not be required for oxygen claims and external infusion pump claims (respectively) during the COVID-19 PHE. Refer to the DME MAC joint publication titled CMS Issues Interim Final Rules with Comment (CMS-1744-IFC & CMS-5531-IFC) – COVID-19 Public Health Emergency for additional information concerning the COVID-19 PHE and effects on coding of claims for certain items or services.

DME MAC Educational Materials

The DME MACs are working diligently to update all educational material (including LCDs, LCD-related Policy Articles, and other collateral educational material), to reflect the new guidance.

Refer to each DME MAC website for additional information, including the DME MAC LCD webpages (linked below) for access to the LCDs and related Policy Articles.

Publication History

November 17, 2022 Originally Published

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