Additional Time to Establish Protocols for Newly Required Face-to-Face Encounter

Jake Wood, CP

Fellow Practitioners,

I received this e-mail 6/28/2013 from NGS Jurisdiction “B”. I believe this
pertains to O&P. Please assess your own situation.

____________________________________

Additional Time to Establish Protocols for Newly Required Face-to-Face
Encounters for DME (201306-06)
Due to concerns that some providers and suppliers may need additional time
to establish operational protocols necessary to comply with face-to-face
encounter requirements mandated by the Affordable Care Act (ACA) for certain
items of Durable Medical Equipment (DME), CMS will start actively
enforcing and will expect full compliance with the DME face-to-face requirements
beginning on October 1, 2013.
Section 6407 of the ACA established a face-to-face encounter requirement
for certain items of DME. The law requires that a physician must document
that a physician, nurse practitioner, physician assistant, or clinical nurse
specialist has had a face-to-face encounter with the patient. The encounter
must occur within the 6 months before the order is written for the DME.
Although many DME suppliers and physicians are aware of and are able to
comply with this policy, CMS is concerned that some may need additional time
to establish operational protocols necessary to comply with this new law.
As such, CMS expects that during the next several months, suppliers and
physicians who order certain DME items will continue to collaborate and
establish internal processes to ensure compliance with the face-to-face
requirement. CMS expects durable medical equipment suppliers to have fully
established such internal processes and have appropriate documentation of required
encounters by October 1, 2013.
CMS will continue to address industry questions concerning the new
requirements and will update information on our _Medical Review and Education_
(http://click.email.ngsmedicare.com/?qs¸e869f339e3f636f4332266fac4ee322771a51
85d2a04552f22ddbf6deb8667) website. CMS and its contractors will also use
other communication channels to ensure that the provider community is
properly informed of this announcement.

Jake R. Wood C.P., FAAOP
O&P Associates, Inc.
10506 W. Bluemound Rd.
Milwaukee, Wi 53226
414-257-2727
414-257-9898 (Fax)
414-315-9749 (Cell)

 

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