Face-to-face rule: Be the solution, not the problem

A. With face-to-face (F2F) encounter documentation now required for 166 items of DME and a proposed significant expansion of the prior authorization demonstration project looming, referring physicians who have historically said “my way or the highway” in regard to face-to-face documentation are now being held accountable.  

Today, DME providers are more insistent that physicians complete and appropriately document F2F encounters. DME providers know all too well that it no longer makes sense to accept sub-par documentation just to have the payments recouped in audits or denied altogether in a pre-payment audit. It makes more financial sense to not do business at all than to vend equipment and be denied payment.

The reality is that F2F documentation requirements are here to stay and are only going to expand. For DME companies, this represents an opportunity to distance themselves from their competition by providing their referring physicians with a solution not a problem.

CMS continues to embrace technologies that move toward online standardization and automation of documentation, and has updated the Program Integrity Manual regarding template use. Next time you have to address incomplete F2F documentation from a referral source, one alternative is to introduce them to a new way of completing evaluations: online electronic clinical templates.

To a layperson, requiring a patient-physician encounter and the documentation from that visit before delivery of DME may seem inconsequential. To the DME industry, it is another step in a paradigm shift from the old CMS pay-and-chase model. CMS wants accountability from DME providers and physicians. Find solutions that meet that expectation.

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