DME MAC Joint Publications Update F2F Ruling

Posted on in Billing/Reimbursement, HME Government Issues

By: The VGM Reimbursement Team

Since its implementation on July 1, 2013, the Affordable Care Act’s face-to-face (F2F) ruling has put a damper on the entire HME industry, as many suppliers are aware.

Recently the DME MACs released joint publications on the F2F ruling that included some updates. These updates are good news for the industry, BUT please take into consideration our suggestions below.  Remember audits are still occurring, and suppliers need to make sure they get paid for the services they provider to their patients.

Below are the updates to the F2F ruling under the ACA 6407 from the articles released in April 2016, with specific suggestions from us for each one. These updates do not apply to the power mobility devices policy; the updates apply only to those HCPCS codes under the F2F ruling.

  1. Face-to-face examination: The examination no longer needs to be obtained prior to delivery and no longer needs to include a date-stamped received.

    Reimbursement team suggestion: The medical policy coverage criteria still needs to be met. We encourage you to obtain the examination, even if it’s the unsigned version, to make sure the medical policy coverage criteria has been met. At some time, make sure to get the signed notes for your patient’s file for audit purposes. Do not rely on the referral telling you that it’s in the documentation.

  2. The five-element order (5EO): Only the five elements below are required on the order prior to delivery:
    1. Beneficiary’s name
    2. Item being ordered - this may be general or specific (e.g., hospital bed or semi-electric hospital bed)
    3. Signature of the prescriber
    4. Prescriber’s NPI
    5. Date of the order

A date-stamped order is still required prior to delivery to show that it was received by the supplier prior to delivery. This requirement has not changed.

A Detailed Written Order (DWO) is still required prior to submitting the claim for payment. The DWO must include a detailed description of the item (e.g., semi-electric hospital bed) and all other elements required on the order per the medical policy, including any other billable codes.

Reimbursement team suggestion: If your company has a process in place to get a DWO prior to delivery and it’s working well, then do not change the process. Make sure the orders being used are labeled appropriately, such as “Detailed Written Order.” Having the forms/orders labeled appropriately makes the review process easier and better for the supplier.

To review the articles that were updated, please click on the links below:

If you have already instructed your referral sources to follow this ruling, don’t change your processes. And, you still want to gather as much information as you can prior to delivery. Remember the audits are still happening.

There will be more discussion on this at VGM’s Heartland Conference 2016 during our Mission Possible II pre-conference show. Hope to see you there.

Ronda Buhrmester, CRT                                   Dan Fedor
888.665.6518                                                      844-794-8459
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