Tip From The Trenches

Date Published: March 20 2014

We know the F2F law is in effect 7/1/13, but because of the delay, can NGS come back and audit anything from the 7/1/13 date?

Yes, arguably The Centers for Medicare and Medicaid Services (CMS) can come back and audit anything from the 7/1/13 date forward for the face-to-face rule because that is the date the law became effective. What they CAN do, and what they MAY do, could be two quite disparate alternatives. To reiterate, the current status is as follows:

“As of July 1, 2013, the DME items on the Specified Covered Items list require that the supplier obtain a detailed written order prior to delivery. All written orders shall follow the guidance in the CMS Program Integrity Manual (Internet-only manual, Publication. 100-08), Chapter 5, Section 5.2.3, and shall include, at a minimum, the following elements listed in the regulation:

1.    The beneficiary’s name; 

2.    The DME item ordered; 

3.    The prescribing practitioner’s National Provider Identification (NPI); 

4.    The signature of the prescribing practitioner; and, 

5.    The date of the order.

Active enforcement of the face-to-face requirements has been postponed until a future date to be announced in Calendar Year 2014, the delay does not impact provisions related to written orders prior to delivery. CGS will begin enforcement of the written order prior to delivery requirement for dates of service (DOS) on or after January 1, 2014.”

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