Face to Face Requirements—Enforcement effective January 1, 2014

Face to Face Requirements—Enforcement effective January 1, 2014

The CMS announced that the DME MACS are now able to enforce, under the Affordable Care Act (ACA) 6407, the detailed written order from Face to Face (F2F) ruling for dates of service on or after January 1, 2014.

What does this mean for you the DME supplier? 

If you receive a referral for a piece of equipment that falls into the one of the 166 HCPCS codes (attached) listed under the F2F ruling, you must have a detailed written order prior to delivery.  Under this ruling, you can no longer deliver on a dispensing or preliminary order.   The detailed written order (DWO)must have been written within 6 months of the F2F evaluation; be sure to watch those dates as the guidelines are strict.  The information required on the detailed written order remain the same as indicated in the medical policy pertaining to the equipment, except for the NPI of the ordering practitioner needs to be included on the detailed written order.   This ordering practitioner must be certified in PECOS and can be a Nurse Practitioner (NP), Physician Assistant (PA), Certified Nurse Specialist (CNS), or a physician.   The practitioner that performs the F2F evaluation must be the one signing the detailed written order.  The DME supplier may complete the detailed written order, and then have the ordering practitioner review, sign, and date.    There has been a lot questions regarding setup of the equipment; if you receive the order today and for whatever reason the equipment cannot be set up today, that is perfectly fine.   Even though DME suppliers try very diligently to setup equipment promptly, you are not required, under the F2F rule, to set up the equipment the same day.  Make sure to date stamped the DWO and medical record upon receipt to prove that both were received prior to delivery. 

As for the F2F evaluation, the medical need for the item being ordered must meet coverage criteria and must be documented in the medical record.  If the NP, PA, or CNS performs the F2F evaluation, the physician must sign off the medical record, but does not have to sign off the DWO.  Even though the F2F evaluation is not being enforced by the DME MACS until “a date” in 2014; we strongly encourage you to receive the medical record prior to delivery.  The DME MACS are not the only auditors in the DME industry.  

For any further questions, please contact the Reimbursement Team. 

Ronda Buhrmester                                                          Peggy Walker

Office:  888-665-6518                                                      Office: 800-401-3643

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