Physicians and Durable Medical Equipment (DME) suppliers need to be aware that, effective July 1, 2013, and to be enforced as of October 1, 2013, Medicare requires a physician/patient face-to-face encounter within 6 months prior to the physicians order for an item on an extensive DME list. This type of face-to-face encounter has been required since 2006 for power wheel chairs. This change for DME was first mandated by Section 6407 of the Affordable Care Act. The DME includes hospital beds and accessories, oxygen, nebulizer compressors, CPAP/BiPAP, seat lift mechanisms, manual wheelchairs and others, as noted on the revised DME list issued by the Department of Health and Human Services Centers for Medicare & Medicaid Services (CMS). CMS, through its contractors, will no doubt be conducting future audits and issuing overpayment determinations for failure to comply with these new requirements.
The face-to-face encounter may be conducted by a physician, nurse practitioner (“NP”), physician assistant (“PA”) or clinical nurse specialist (“CNS”), who must document that the patient was evaluated and/or treated for a condition that supports the item of DME ordered. If the DME is ordered by an NP, PA or CNS, a physician must document the face-to-face encounter by signing/co-signing the pertinent part of the medical record. Physicians will be provided an additional payment, using code G0454, for signing/co-signing the face-to-face encounter by a NP, PA or CNS.