Good news for the DMEPOS industry that is involved with the Face-to-Face Ruling! Remember the SRG bill (doc fix), that was signed by President Obama a few months ago? CMS has finally released the update. The article states that the physician no longer needs to co-sign the face-to-face encounter when the Nurse Practitioner, Physician Assistant or Clinical Nurse Specialists perform the visit.
Click here for the full article.
Just as a reminder, both the F2F encounter and detailed written order need to be in the supplier’s hands prior to delivery. And make sure you date stamp when you received these documents.
The DME MACs are auditing effective Jan. 1, 2014, on the detailed written order prior to delivery requirements. As for the F2F encounter, the DME MACs, RAC, ZPIC, and other contractors are not auditing on this requirement. However, CERT can audit on the F2F encounter requirement as they must follow the federal regulations. If CERT does audit a supplier on the F2F encounter requirement, it can be appealed and should be overturned.
We recommend getting the F2F encounter prior to delivery to avoid the appeals process and to make sure the coverage criteria has been meet. If the documentation is not obtained prior to delivery, how would a supplier make sure the coverage criteria is met? Bottom line is to follow the rules to ensure a clean claim.
Contact Dan or Ronda with any questions.