Face to Face Encounter ~ As Of Right Now

Let’s start with a timeline of events that will lead into what the expectations are for DME suppliers. The face to face encounter requirements were released by the Federal Register in a proposed on July 30, 2012 with the final rule completed on November 16, 2012. CMS gave direction to the to the DME MACS May 31, 2013 which was then released to the supplier community in the MLN Matters MM8304 with the rule going into effect July 1,2013 ~ same date as Round 2 Competitive Bid.

Now, what happened during those 6 months from November 2012 to the release date of May 2013; no one really knows what was on CMS’ mind. However, on June 27, 2013, Capitol Hill released an article delaying the enforcement date to October 1, 2013.

Please note: The implementation is not delayed, only the enforcement is delayed! Suppliers are putting themselves as risk if they do not begin working on implementation immediately.

This is what we know as of this minute. Medicare requires that specific items of DME, if it’s one of the 166 HCPCs codes, will require the following items PRIOR to delivery:

  1. Written Order Prior to Delivery (WOPD)
  2. Face to Face encounter signed and dated by ordering practitioner

The WOPD must contain, at minimum, the following:

  • Patient Name
  • Item Ordered
  • Diagnosis related to condition requiring item – if item is diagnosis driven
  • Length of Need – if required by policy
  • Method of Usage – required on some items such as oxygen
  • Date of Order
  • Ordering Practitioner Signature and Date
  • Ordering Practitioner NPI

According to the Federal Register, the F2F encounter by the Physician, NP, PA, or CNS, must have evaluated the beneficiary, conducted a needs assessment for the beneficiary, or treated the beneficiary for the medical condition that supports the need for each item of DME. The information would be part of the medical record, which identifies the practitioner who provided the F2F assessment. Multiple items can be documented during the encounter which must occur within 6 months of the detailed written order.

The face to face encounter has to have occurred within the 6 months prior to the date of the detailed order. If the NP, PA, or CNS performed the F2Fencounter, the physician must sign and date those progress notes; and that physician will receive an additional payment for signing off those notes using the code G0454. The physician does not have to sign the actual detailed order ~ this can be done by the NP, PA, or CNS. 

Remember this is a CMS requirement that comes from direction of the Affordable Care Act.Unfortunately, the untimeliness along with the lack of clear and accurate information is the real error. The DMEMACs are working with CMS to clarify issues and to decrease the confusion. Also, the 4 DME Medical Directors will assist the supplier community on the education efforts as they have in the past. 

We as an industry need to work together with the DMEMACs. If you have any questions or issues, please be sure to contact Peggy Walker or Ronda Buhrmester so we can be sure to communicate with the appropriate people. We are waiting for more information and direction on the F2F encounter requirements which will be share with our members once we are aware.

In the meantime, you need to start working on this process now with educating your team, your referrals, and your patients. Hopefully, we will receive more information soon so we can get this out to our members.

Here is updated information as of July 15, 2013 from AA Homecare:


Ronda Buhrmester – 888-665-6518 – ronda.buhrmester@vgm.com

Peggy Walker – 800-401-3643 – peggy.walker@vgm.com