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Face-to-Face Requirement for Lymphedema Pneumatic Compression Devices–Enforcement Delayed Until October

Face-to-face fanfare

Rule means 'heavy lifting' for providers
by: Liz Beaulieu
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Friday, August 2, 2013

WASHINGTON – Industry stakeholders recommend that HME providers learn the ins and outs of the face-to-face rule well before CMS starts enforcement on Oct. 1.

Stakeholders remind providers that the rule has not one, but two major requirements: a face-to-face exam and a detailed written order.

"Providers are still surprised at how much detailed information they need to have—all before they can deliver any equipment," said Asela Cuervo, a private practice attorney in Washington, D.C. "They're going to have to do a great deal of heavy lifting."

CMS announced on June 27, one business day before implementation, that it would not enforce the rule until Oct. 1. The reason: "concerns that some providers needed additional time to establish operational protocols necessary to comply" with the rule.

Meeting the two major requirements shouldn't be too much of a stretch for most providers, stakeholders say.

"Most providers are going ahead and getting the clinical documentation, they just need to start getting those written orders before delivery," said Kim Brummett, senior director for regulatory affairs at AAHomecare.

Other important-to-know details of the rule, stakeholders say: A physician assistant, nurse practitioner or clinical nurse specialist may conduct the face-to-face exam, but the physician still needs to sign off on it; and the physician must include his or her signature and NPI number on the detailed written order. Also, the rule applies only to equipment, not to supplies, they say.

"People have gotten caught up on this applying to every piece of DME," Brummett said.

While that much stakeholders are sure of, there are still many gray areas surrounding the rule. AAHomecare has prepared and shared with CMS a draft FAQ that it would like to see the agency distribute, but the document has been hung up in a clearance process, stakeholders say.

"They need to put some guidance out there," Brummett said. "They said we needed more time to get prepared, but it's more about us needing more from them."

The rule, once it's enforced, will be more than something just providers have to get used to, stakeholders say.

"Beneficiaries have to understand, too, that they may not get equipment when they want it," Cuervo said.