What operational protocols are DME providers implementing to comply with the F2F rule?

Date Published: April 01 2014

In the autumn of 2013 the Centers for Medicare & Medicaid Services (CMS) announced delays to the enforcement of face-to-face requirements from the Code of Federal Regulations at 42 CFR § 410.38, deeming this period the “time to establish operational protocols.” CMS refers to operational protocols as those internal processes established by collaboration of DME suppliers and physicians to ensure compliance with the face-to-face encounter requirement for certain DME items (see MM8304 for complete list).

All durable medical equipment suppliers must have fully established such internal processes and begin receiving appropriate documentation of the required face-to-face encounters by a date that will be announced by CMS in Calendar Year 2014.  

Your organization is unique in size, market, and geographic area and the specific operational protocols established by your organization will be unique also. However, there exists a commonality between all DME suppliers when a new rule such as the F2F is established, and similar implementation issues, internal processes and education will be experienced by all organizations. The most important operational protocol for all stakeholders with the face-to-face rule is Education.

DME suppliers must be able to convey to all stakeholders the importance and basics of the face-to-face rule. This means educating your referral sources, your clients, and especially your employees. Keep in mind that the rule itself is really not that complicated so it is imperative to thoroughly educate and train your staff about the intricacies of the face-to-face requirements for your commonly vended DME items. CMS does a great job compiling the top reasons for non-compliant documentation. Use these compilations of documentation errors to your advantage and ensure that your staff is aware of, and can be on the lookout for, common documentation problems. Empower your staff not just with WHAT they must do, but WHY it is important to your organization and how vital their particular role is to overall compliance within your organization. For example, if the person that retrieves faxes off the fax machine knows that a physician’s signature needs to be legible, a common documentation problem could be addressed as soon as the documentation is received from your referral source.    

Learning the in’s and out’s and keeping on top of changing face-to-face requirements is not a high priority for most referring practitioners. DME suppliers need to keep on top of changes by using informative websites and by providing referral sources with tools that track and educate them about the face-to-face requirements and any changes. One operational protocol that many DME suppliers have instituted is having someone or a department in your organization in the physician liaison role, providing an educational conduit and nurturing the “relationships with referral sources.” Many DME suppliers have tasked their physician liaisons with providing referral sources with easily accessible and readily available information via checklists, websites and online algorithmic programs, such as Often the best educational opportunity for a physician liaison from a DME provider is upon the receipt of a non-affirmative decision from CMS, as doctors want to do a good job and they don’t want the patient or supplier to be held financially liable for prescribed DME because of their deficient paperwork. The chances for a provider to educate referral sources may be infrequent so you need to be ready to take advantage of every opportunity and be preemptive by providing these physicians educational tools that help identify and remedy common documentation deficiencies.

Doctors want the paperwork process simplified and they want to do it right the first time. Doctors like using DMEevalumate because they save on labor; eliminate guesswork; it is easy to use; can be incorporated into any electronic health record and generates paperwork acceptable to Medicare. Any additional data points or changes that CMS makes are incorporated seamlessly into the program without the doctor constantly having to keep up with changes to Medicare criteria.

DME suppliers like using online algorithmic programs because it streamlines operations; it makes them better ready for audits; they can bill Medicare faster and they can bring their referring doctors a tool for the face-to-face rule, not problem paperwork.

Because CMS wants specific data points addressed with each face-to-face encounter, the right electronic template can be extremely useful for gathering F2F encounter information because the same format is used to address each required data point in every F2F encounter. A Medical Algorithm comprises a technology for medical education and decision support, with the potential to decrease time demands on clinicians, to support evidence-based medicine, to reduce errors, and to help increase the quality of care while decreasing the cost of care." With Medical Algorithms built into the template, documentation is formatted correctly, all required data points are addressed in a way Medicare requires. For a quick and easy reference go to



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