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The future of face-to-face encounter documentation is now.

Date Published: July 01 2014

My manager used to say "Come to me with a solution not a problem."

With face-to-face encounter documentation now required for 166 items of DME **(see MM8304) and a proposed significant expansion of the Prior Authorization Demonstration project looming, thousands of referring physicians who have historically said “my way or the highway,” in regards to face-to-face (F2F) documentation, are now being held accountable. For many physicians, this creates a problem. 

Today, DME providers are more insistent that physicians complete and appropriately document F2F encounters. DME providers know all too well that it no longer makes sense to accept sub-par F2F documentation just to have the payments recouped in audits or denied altogether in a pre-payment audit. It makes more financial sense to not do business at all than to vend equipment and be denied payment. One national company recently mentioned that they were turning away 70 percent of their referrals because of incomplete F2F documentation. For the patient, physician and DME provider……..this is a HUGE problem.

The reality is that F2F documentation requirements are here to stay and are only going to expand. For DME companies, this represents an opportunity to distance themselves from their competition by providing their referring physicians with a solution not a problem.

The Centers for Medicare & Medicaid Services (CMS) continues to embrace technologies that move towards online standardization and automation of documentation, and has updated the Program Integrity Manual regarding template use. Next time you have to address incomplete F2F documentation from a referral source, one alternative is to introduce them to a new way of completing evaluations: online electronic clinical templates.

To a lay-person, requiring a patient-physician encounter and the documentation from that visit before delivery of DME may seem inconsequential. To the DME industry, it is yet another step in a larger paradigm shift from the old CMS pay-and-chase model of years gone by. The future of face-to-face encounter documentation is now. CMS wants accountability from DME providers and physicians. Our job is to find solutions that meet that expectation.

- Michael Blakey, President.

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