Warning RE: [OANDP-L] Establish Protocols for Newly Required Face-to-Face
Jake Wood, CP
Description
Collection
Title:
Warning RE: [OANDP-L] Establish Protocols for Newly Required Face-to-Face
Creator:
Jake Wood, CP
Date:
7/3/2013
Text:
Fellow Practitioners, Warning & Clarification
My original post:
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.
_______________________________________
Results of my posting: Please read and let us all be very careful!
1. I received the same email from CMS for region C. The appendix shows
only E-codes for region C, so it is truly just for DME. anonymous CPO
2. Ossur response to me (THANK YOU SO MUCH, OSSUR)
Our Error
Posted by _David McGill_ ( <URL Redacted>) | April 18,
2013
On January 22, 2013, we authored a post stating that effective July 1,
doctors would have to sign Detailed Written Orders before delivery of a
prosthetic or orthotic device. We were wrong.
Buried on page 262 (of 483) of the comments to the Final Rule is the
following statement by Medicare:
As noted previously, section 1834(h)(3) of the Act incorporates by cross
reference prosthetic devices, orthotics, and prosthetics to the items
encompassed by section 1834(a)(11)(B) of the Act. At this time, we are not
implementing the proposed changes to § 410.36(b) to require documentation of a
face-to-face encounter for prosthetic devices, orthotics, and prosthetics
that, according to § 410.36(b), require a written order before delivery in
this final rule. We intend to use future rulemaking to determine which
prosthetic devices, orthotics, and prosthetics, require, as a condition of
payment, a written order before delivery supported by documentation of a face-
to-face encounter with the beneficiary consistent with section 1834(a)(11)(B)
(ii) of the Act. [Emphasis added]
What does this mean for me?
If you're an O&P supplier, the Detailed Written Order requirements that
you've always followed remain unchanged. If you have the doctor sign the DWO
before billing the prosthetic or orthotic device, you are Medicare
compliant.
However, the new DWO-before-delivery rule does apply to items other than
prosthetics and orthotics, effective July 1, 2013.
Our Apology
We know you trust us to get it right the first time. We also know that
trust is hard to earn and easy to lose. We've implemented new safeguards to
prevent this kind of error in the future.
We apologize for the confusion we caused. And we thank you for subscribing
to and reading Össur R&R.
3.
I just read the same Noridian update but was wondering what they mean by
certain items of DME. I would be pleasantly surprised if this included
O and P.
Please let me know if you get a hold of the list.
Thank you,
Tyra cpo
4.
Jake,
From what I understand this is for specific DME items and does not
include O&P...yet
See here for list <URL Redacted>
The list of 167 applicable DME items can be found in Table 89 of the
final rule or in the Medicare Program Integrity Manual. It is important
to note that this rule does not apply to prosthetics, orthotics, or
supplies (POS) and does not include power mobility devices (PMDs), which
are already subject to existing face-to-face requirements.
Sol Heifetz
Director of Operations
Presque Isle Medical Jake,
From what I understand this is for specific DME items and does not
include O&P...yet
See here for list <URL Redacted>
The list of 167 applicable DME items can be found in Table 89 of the
final rule or in the Medicare Program Integrity Manual. It is important
to note that this rule does not apply to prosthetics, orthotics, or
supplies (POS) and does not include power mobility devices (PMDs), which
are already subject to existing face-to-face requirements.
Sol Heifetz
Director of Operations
Presque Isle Medical Technologies
Thank you all for helping. Jake R. Wood C.P., F.A.A.O.P.
My original post:
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.
_______________________________________
Results of my posting: Please read and let us all be very careful!
1. I received the same email from CMS for region C. The appendix shows
only E-codes for region C, so it is truly just for DME. anonymous CPO
2. Ossur response to me (THANK YOU SO MUCH, OSSUR)
Our Error
Posted by _David McGill_ ( <URL Redacted>) | April 18,
2013
On January 22, 2013, we authored a post stating that effective July 1,
doctors would have to sign Detailed Written Orders before delivery of a
prosthetic or orthotic device. We were wrong.
Buried on page 262 (of 483) of the comments to the Final Rule is the
following statement by Medicare:
As noted previously, section 1834(h)(3) of the Act incorporates by cross
reference prosthetic devices, orthotics, and prosthetics to the items
encompassed by section 1834(a)(11)(B) of the Act. At this time, we are not
implementing the proposed changes to § 410.36(b) to require documentation of a
face-to-face encounter for prosthetic devices, orthotics, and prosthetics
that, according to § 410.36(b), require a written order before delivery in
this final rule. We intend to use future rulemaking to determine which
prosthetic devices, orthotics, and prosthetics, require, as a condition of
payment, a written order before delivery supported by documentation of a face-
to-face encounter with the beneficiary consistent with section 1834(a)(11)(B)
(ii) of the Act. [Emphasis added]
What does this mean for me?
If you're an O&P supplier, the Detailed Written Order requirements that
you've always followed remain unchanged. If you have the doctor sign the DWO
before billing the prosthetic or orthotic device, you are Medicare
compliant.
However, the new DWO-before-delivery rule does apply to items other than
prosthetics and orthotics, effective July 1, 2013.
Our Apology
We know you trust us to get it right the first time. We also know that
trust is hard to earn and easy to lose. We've implemented new safeguards to
prevent this kind of error in the future.
We apologize for the confusion we caused. And we thank you for subscribing
to and reading Össur R&R.
3.
I just read the same Noridian update but was wondering what they mean by
certain items of DME. I would be pleasantly surprised if this included
O and P.
Please let me know if you get a hold of the list.
Thank you,
Tyra cpo
4.
Jake,
From what I understand this is for specific DME items and does not
include O&P...yet
See here for list <URL Redacted>
The list of 167 applicable DME items can be found in Table 89 of the
final rule or in the Medicare Program Integrity Manual. It is important
to note that this rule does not apply to prosthetics, orthotics, or
supplies (POS) and does not include power mobility devices (PMDs), which
are already subject to existing face-to-face requirements.
Sol Heifetz
Director of Operations
Presque Isle Medical Jake,
From what I understand this is for specific DME items and does not
include O&P...yet
See here for list <URL Redacted>
The list of 167 applicable DME items can be found in Table 89 of the
final rule or in the Medicare Program Integrity Manual. It is important
to note that this rule does not apply to prosthetics, orthotics, or
supplies (POS) and does not include power mobility devices (PMDs), which
are already subject to existing face-to-face requirements.
Sol Heifetz
Director of Operations
Presque Isle Medical Technologies
Thank you all for helping. Jake R. Wood C.P., F.A.A.O.P.
Citation
Jake Wood, CP, “Warning RE: [OANDP-L] Establish Protocols for Newly Required Face-to-Face,” Digital Resource Foundation for Orthotics and Prosthetics, accessed November 27, 2024, https://library.drfop.org/items/show/235447.
