What does the face-to-face rule mean to doctors?

Date Published: June 04 2014

The physician opens the prior authorization notification envelope following a face-to-face evaluation, scans the contents, and rolls his eyes while crumpling up the letter and throwing it in the garbage. “This is the kind of ridiculousness I have been talking about,” he says. “This patient has a primary diagnosis of C-4/C-5 complete quadriplegia and Medicare denied prior authorization because I forgot to rule out a cane and a walker. Who is making these decisions?”

DME companies need the face-to-face paperwork required by Medicare, and physicians, for whatever reason, have trouble providing it. The relationship between DMEs and docs is contentious and sometimes even adversarial. The push and pull over accurate and complete paperwork documenting medical necessity has always created an issue, and continues to be a bone of contention, between the two parties.

In business it is important to understand where another person is coming from to more efficiently work with them. Physicians do not want to have discussions about the importance of complete and accurate paperwork any more than DME representatives do. However it is the DME providers who typically bear the financial burden. The face-to-face rule enforcement and subsequent physician education has made for some unhappy physicians. Let’s walk in their shoes for a little bit.

You go to college for four years to then attend med-school for four more years then add two to six more years of fellowships, residencies and specialty training. After 10+ years of education, you are asked to detail patient information by a DME provider, who has little or no scientific background, so that they can tell you if your prescription is correct or not. Of course it’s correct – you’re the qualified physician!

Letting physicians know that you understand their plight can go a long way. Explain that you are not trying to do their job, you are simply trying to obtain the medical justification for DME in the correct narrative format. Face-to-face documentation collection tools exist to assist physicians in providing complete paperwork faster, not to replace their knowledge.

The face-to-face rule does not have to mean more work for physicians if they will simply acknowledge that the evaluation must be documented in a required format. Until CMS holds physicians directly accountable for incomplete paperwork, DME providers will continue to play the uncomfortable role of messenger. Show physicians a solution that will streamline their knowledge, ensure all information is documented, and produce the narrative outputs CMS is looking for.

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