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Face-to-Face Encounter Requirement for Certain Durable Medical Equipment
September 03, 2014
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.
On September 9, 2013, the Centers for Medicare & Medicaid Services (CMS) announced that it would begin actively enforcing and would expect full compliance with new DME face-to-face requirements on a date to be announced in Calendar Year 2014. We are publishing this announcement to make clear that the delay of enforcement only applies to the face-to-face encounter requirements and does not impact provisions related to written orders prior to delivery.
Due to continued 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 DME, CMS will not start actively enforcing or expect full compliance with the DME face-to-face requirements until further notice.