Face-to-face rule: Learn ins and outs

Q. What operational protocols should I implement to comply with the F2F rule?
Friday, March 28, 2014

A. Your organization is unique and the specific operational protocols established by your organization should be unique also. Despite uniqueness, a commonality exists between all DME suppliers when something new, such as the face-to-face rule, is established, and the most important operational protocol for all stakeholders with the face-to-face rule is education.

CMS refers to operational protocols as those internal processes established by collaboration of DME suppliers and physicians to ensure compliance with the face-to-face encounter requirement for certain DME items (see MM8304 for complete list). 

Learning the ins and outs of the face-to-face requirement and educating referral sources rests squarely on the shoulders of DME providers. Many have implemented operational protocols with their referral sources that provide them with a tool that tracks, educates, and notifies them about the face-to-face requirements and changes. Implementing an operational protocol that brings face-to-face education to your doctors via online algorithmic programs has been proven successful by many providers because it saves time, eliminates guesswork, and generates accurate paperwork acceptable to Medicare.

DME suppliers must be able to convey to all stakeholders the basics and importance of the face-to-face rule. The rule itself is not overly complicated so it is imperative to thoroughly educate and train your staff about the intricacies of the face-to-face requirements for your common DME items. CMS does a fine job compiling the top reasons for non-compliant documentation. Use these compilations to ensure that your staff is aware of common documentation problems.

Michael Blakey is president of DMEevalumate.com. Reach him at 800-986-9368 or mike@dmeevalumate.com.