Face to Face Encounter Requirements –Delayed until 2014

With another delay in the Affordable Care Act for the face to face rule, suppliers will have more time to implement the process.  However, if the supplier already has the new face to face rule in place, then the supplier needs to continue on and do not stop.  If it has not yet been implemented into the daily processes, we, at VGM & US Rehab, continue to encourage members to implement the face to face rule process immediately.   Do not wait until the effective date is announced.

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 (see attachment list by product category), will require the following items PRIOR to delivery:

1.     Written Order Prior to Delivery (WOPD)

2.     F2F encounter signed and dated ordering practitioner /IF NP or PA completes must be reviewed and signed off by physician.

The WOPD must contain at minimum the following:  Patient Name -Item ordered -Date of order-Ordering Practitioner signature and date/Ordering Practitioner NPI

Certain policies would also need method of usage and length of need such as Oxygen/Hospital beds.

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.  Basically, the treating practitioner needs to document the medical necessity for the item being ordered.  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 face to face encounter.

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 F2F encounter, 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.   The supplier is allowed to complete the WOPD, then ordering practitioner needs to review, sign, and date the order.  If the WOPD is missing a required element, the supplier can issue a new WOPD for the ordering practitioner to sign, or make the corrections and have the ordering practitioner initial and date the correction; remember this will all have to take place prior to delivery of the item.

For capped rental equipment and oxygen content, starting July 1, 2013, the beneficiary does not need to have an evaluation every 6 months.  The F2F ruling applies to new, initial orders.   Beneficiaries who live in a competitive bid area and who transition to a contract supplier will be required to have a new face to face.  This is considered a change in suppliers which requires a new order which also then requires a new face to face evaluation.

When educating referral sources the person interviewing the patient can document that the patient states  “I need a hospital bed because I can’t sleep in my standard bed due to COPD/CHF, etc., and need to sleep with my  head elevated” – same with discharge planners/social workers/ etc.

Remember only enforcement is delayed, not the implementation.    For more on the recent announcement, use the attached link.  

HCPCS codes by product category.pdf

Face to Face Delay Until 2014.doc

Ronda Buhrmester, RT                                                  Peggy Walker, RN

888-665-6518                                                               800-401-3643

ronda.buhrmester@vgm.com                                   peggy.walker @vgm.com