CMS announced yet another delay of new face to face rule stemming from the Affordable Care Act 6407 (ACA). The delay is continued until sometime in 2014; no exact date is given which means it could be January 1, 2014 or soon after. CMS will start actively enforcing and will expect full compliance with the face to face requirements when the new date is announced.
What does this mean for you as a provider? If you already started the process of the face to face rules, then you need to continue to follow it; do not stop. If you have not started the face to face requirements, then you need to implement this process into your daily protocols beginning now. Do not wait until the effective date.
Remember only enforcement is delayed until 2014; the implementation started July 1, 2013. This does not stop audits from occurring on a either a prepay or post pay level. We have already received notification of a complex medical review from one Jurisdiction relating to the face to face rule!
The documentation of a face to face occurring within 6 months prior to the order being written and the detailed written order has to be in the providers hands prior to delivery of the item. If the documentation requires a physician signing off, then this has to be completed prior to delivery as well.
DME Providers, you need to contact your Congress liaisons letting them know the havoc the Affordable Care Act 6407 regarding the Face to Face rules are having on your patients getting access to the medical equipment needed and the adversity on your company.
VGM and US Rehab have scheduled a webinar for members on September 20, 2013 at 10am CST regarding the Face to Face Requirements.
For more information contact the reimbursement team, Ronda Buhrmester at 888-665-6518 or Peggy Walker at 800-401-3643.