Georgia Medicaid red lights face-to-face requirement

Monday, July 25, 2011

ATLANTA - Medicare hasn't implemented its face-to-face requirement for home medical equipment yet, but that hasn't stopped Georgia Medicaid.

It plans to start enforcing the requirement July 1.

"Yes, Georgia has it all figured out," said Ed Cockman, owner of Family Healthcare in Valdosta, Ga. "Our federal government should call them."

The Affordable Care Act, passed last year, includes a provision requiring a face-to-face encounter with a physician within the last six months for a home medical equipment order.

HME stakeholders first learned of Georgia Medicaid's plan to implement the requirement on Dec. 28. That's when the state announced it planned to start enforcing the requirement on Jan. 1.

After backlash from stakeholders, however, Georgia Medicaid backpedaled. Between then and now, stakeholders have been trying to get more details on how the state plans to implement the requirement, with minimal success.

"We know the intent of the requirement and we support it," said Weesie Walker, who manages the National Seating & Mobility branch in Atlanta. "But we want them to look at what it's going to mean in the real world."

An example of how the requirement won't work in the "real world," stakeholders say: For a lot of complex rehab, a physical or occupational therapist is the patient's primary contact, not the physician.

"If a PT calls us and says 'We need a controller for a power wheelchair' and faxes in the order, if the patient hasn't seen the doctor, we can't touch that order," Cockman said. "The PT is not on the list of approved practitioners."

HME stakeholders have been able to get some clarification on the requirement. For example, wheelchair repairs don't require a face-to-face encounter if they're reasonable and customary, Georgia Medicaid has indicated.

"But we have an ongoing list of questions," said Teresa Tatum, the executive director of the Georgia Association of Medical Equipment Services.

To help them meet the requirement, stakeholders have added a line on the letter of medical necessity signed by the physician for the date when the patient was last seen.