Face-To-Face Encounters

DMEevalumate was developed to ensure that face-to-face documentation is in compliance with The Centers for Medicare and Medicaid Services (CMS) and quick and easy for practitioners to produce referral paperwork for DME providers.

The following video produced by CGS explains documentation requirements for power mobility devices from the physican's perspective click here

What is a Face-To-Face Encounter?

Face-to-face encounter is a popular term for the assessment completed by practitioners during a patient visit for durable medical equipment, such as power mobility, oxygen and CPAP therapy. This generates associated paperwork that is often referred to as face-to-face documentation.

Effective May 5, 2005, CMS revised national coverage policy to create a new class of DME identified as Mobility Assistive Equipment (MAE), which included a continuum of technology from canes to power wheelchairs. In addition to the prescription for the PMD, the physician or treating practitioner must provide the supplier with supporting documentation consisting of portions of the medical record essential for supporting the medical necessity and statutory requirements such as an in-person visit and medical evaluation.

Effective July 1, 2013, Medicare requires a physician/patient face-to-face encounter within 6 months prior to the physicians order for more than 100 DME items. For a complete list of items, please view the DME List of Specified Covered Items. This change for additional DME items was mandated by section 6407 of the Affordable Care Act.

Since January 1, 2014, CMS has only been enforcing a portion of the Face-to-Face Rule for DME - that a Face-to-Face encounter take place within the 6 months preceding the date of the Detailed Written Order, and that the supplier secure a compliant Detailed Written Order Prior to Delivery (DWOPD). The DWOPD must be date stamped by the supplier prior to delivery of any item subject to the rule.

"Doc fix" bill, HR 2 "The Medicare Access and CHIP Re-authorization Act of 2015" ("MACRA") was signed into law on April 16, 2015. This "final fix" legislation now permits not only the physician but also a nurse practitioner, physician assistant or clinical nurse specialist to conduct and document a Face-to-Face encounter with a patient during the 6-month period before an Order is written for the DME. MACRA revises the requirement that a physician sign and date those Face-to-Face Notes that a nurse practitioner, physician assistant or clinical nurse specialist generated while conducting the Face-to-Face encounter (as allowed by state law).

In 2015, we expect CMS to promptly begin enforcement of the second portion of the Face-to-Face Rule - the portion that requires suppliers to obtain executed copies of the Face-to-Face Notes from a Face-to-Face encounter performed within 6 months preceding the date on the DWOPD. The Face-to-Face notes must be signed and dated and then date stamped by the supplier prior to delivery of the DMEPOS item subject to the rule.

View a copy of the Dear Physician letter developed by CMS that explains the new regulations for face-to-face and written order requirements for high cost DME.

DMEevalumate.com was written and developed in accordance with the 2005 national coverage policy for PMD and evolved in 2013 to include documentation requirements for respiratory equipment, such as CPAP therapy and oxygen.

In 2014, DMEevalumate.com released its online face-to-face documentation tool and complete outputs for 73 of the 166 DME items, with the addition of nine frequently vended: manual wheelchairs, canes, crutches, walkers, hospital beds, support surfaces, commodes, urological supplies and diabetic supplies.

What is Prior Authorization?

Beginning September 1, 2012, CMS implemented a three-year Medicare demonstration project for power mobility devices (PMD) that subjects all claims included in the project to “prior authorization.” The seven states in the Prior Authorization Demonstration Project (PADP) are California, Florida, Illinois, Michigan, New York, North Carolina and Texas, which comprise more than 43 percent of the Medicare market for PMDs. Providers must submit physician prescriptions and supporting documentation for all PMDs-except those for Group 3 complex rehabilitative power wheelchairs that have power options (K0856 K0864)-for PA review by a Durable Medical Equipment Medicare Administrative Contractor (DME MAC) or incur a 25% reimbursement reduction and increased risk of an audit.

On April 4, 2014, CMS announced that, based on early successes, it has requested approval to expand the demonstration to 12 additional states: Pennsylvania, Ohio, Louisiana, Missouri, Maryland, New Jersey, Indiana, Kentucky, Georgia, Tennessee, Washington and Arizona.

View a copy of the Dear Physician letter developed by CMS that further explains the expansion of the PADP.

On July 15, 2015, CMS announced that the PADP has been extended for another three years. The demonstration is now scheduled to run through August 31, 2018 for all 19 states. The original demonstration requirements remain the same for all states.

As the industry average prior authorization denial rate remains a consistent 51 percent, we believe it’s better to know sooner rather than later if DME qualifies for reimbursement. DME providers who subscribe to DMEevalumate are currently operating at a 99 percent approval rate.

Common face-to-face documentation errors for PMD and respiratory

  1. Invalid or incomplete seven-element order.
  2. Incomplete progress notes – missing clinical information, such as office notes failing to document the need for any mobility aide.
  3. Incomplete progress notes – missing technical requirement, such as a signature or date.
  4. Statutory requirements are not met, such as patient has not had an in-person visit with the physician or the medical evaluation does not clearly document patient’s inability to perform Mobility-Related Activities of Daily Living (MRADLs) within the home.
  5. The date of the written prescription is before the face-to-face evaluation (it must be after).
  6. The PMD provider received the documentation after 45 days of the completion of the face-to-face exam (it must be sent within 45 days).
  7. Other mobility aides were not ruled out, such as canes, walkers and manual wheelchair.
  8. Records did not include face-to-face prior to the sleep study.
  9. There is no documentation of patient receiving instructions on care.
  10. Detailed written order was on a blanket order form (instead of in required narrative format.)

DMEevalumate.com eliminates the above issues because the practitioner cannot move on to the next question unless all required items have been addressed. The algorithmic program analyzes information and accurately determines if all 63 elements (38 for oxygen and 46 for CPAP) have been met. DMEevalumate.com keeps up with changes in the face-to-face rule so the user doesn’t have to.

Resources and checklists

The following links provide more resources for DME providers and physicians to find up-to-date information about face-to-face documentation.

  • For verification regarding the use of electronic templates for face-to-face encounters, review the Medicare Program Integrity Manual
  • For up-to-date information about Prior Authorization of PMDs Demonstration, see www.cms.gov
  • For additional help preparing for audits, go to www.aahomecare.org and download the provided checklists.
  • For current information about the face-to-face encounter requirement, see www.cms.gov
  • As required by The Tax Relief and Health Act of 2006, CMS implemented Medicare recovery auditing in all states and awarded contracts to four regional Recovery Audit Contractors (RACs). View this website for a map of the regions: www.aha.org
  • For specific information pertaining to Jurisdiction A, see www.medicarenhic.com You will need to agree with the terms and click on What’s New.
  • Click on Education and Test Your Knowledge for quick and fun quizzes about specific DMEPOS related topics at www.medicarenhic.com
  • For specific information pertaining to Jurisdiction B, see www.ngsmedicare.com
  • For specific information pertaining to Jurisdiction C, see www.cgsmedicare.com
  • For specific information pertaining to Jurisdiction D, see www.noridianmedicare.com
  • For information on respiratory care, sleep medicine and critical care nursing see www.foocus.com