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Face to face: No need to worry With Seth Johnson Q. How will the Medicare face-to-face requirement impact suppliers? A. In August CMS issued a proposed rule to implement the long anticipated requirement for all Medicare beneficiaries to have a face-to-face examination by a physician before receiving DMEPOS. The final regulation, which should be published in early November, came out of the Medicare Prescription Drug and Modernization Act last year. While many industry stakeholders, including Pride, submitted comments on the proposal focusing on the need to expand the date of order timeframe from 30 to at least 120 days, provide clarity of medical documentation requirements, allow other clinicians to conduct the examinations, and eliminate the requirement that the examination not be for the sole purpose of obtaining an item of DME, the outcome should be favorable. As long as these issues are reflected in the final rule, this should be a positive rule, and help reiterate that the burden of medical necessity is with the physician and not the DME supplier. This rule is a positive for suppliers as it provides further guidance as to the specific requirements that are necessary in order to ensure payment for Medicare items furnished to beneficiaries. The final rule should also assist in efforts to raise the image of the industry with Congress and the Administration and further reduce fraud. The face-to-face examination final rule should not create an undue burden for suppliers, rather it should provide further evidence that the industry is meeting a higher standard and that the products and services provided are medically necessary. Contact Seth Johnson, director of government affairs at Pride Mobility Products, at 800-800-8586.

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