September 29, 2020
Effective September 30, 2020, DMAS is eliminating the special “sign off” requirements that have applied to Certificates of Medical Necessity (CMN) for continuous glucose monitors (CGMs). Prior to the change, Chapter IV of the Durable Medical Equipment and Supplies (DME) Manual, Covered Services and Limitations, in the section for Glucose Monitors, (p. 27) required that the supervising endocrinologist sign off on the CMN. The language was as follows:
“A resident physician, endocrinology fellow, nurse practitioner acting within the scope of their practice under state law, or a physician’s assistant supervised by an endocrinologist can write the order as long as the supervising endocrinologist signs the CMN.”
In its draft provider manual, DMAS has eliminated this language in its entirety, making the requirement for a CMN for a CGM the same as for a CMN for all other DME. The general rule for a CMN for DME (and the new rule for CGM) is as follows:
“[sic] the practitioner must sign and date the completed CMN.” (See, DME, Ch IV. Pp. 5-9 (emphasis added.))
The term, “practitioner” encompasses more than just medical doctors, and may include Nurse Practitioners, Physician Assistants, and Doctors of Osteopathic Medicine. This relaxation of the CMN process will reduce provider burden and will increase the efficiency of patient access to this technology, which has revolutionized diabetes care by affording significant medical and lifestyle benefits.
On September 16, 2020, DMAS released its draft provider manual for DME and opened it for comment. Although the comment period will end on October 16, 2020, DMAS has indicated that this change is effective at the end of September.
If you have any questions about these pharmacy measures, please contact a member of Hancock Daniel’s Life Sciences team.
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The information contained in this advisory is for general educational purposes only. It is presented with the understanding that neither the author nor Hancock, Daniel & Johnson, P.C., is offering any legal or other professional services. Since the law in many areas is complex and can change rapidly, this information may not apply to a given factual situation and can become outdated. Individuals desiring legal advice should consult legal counsel for up-to-date and fact-specific advice. Under no circumstances will the author or Hancock, Daniel & Johnson, P.C. be liable for any direct, indirect, or consequential damages resulting from the use of this material.