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DME Face-to-Face Rule Compliance Date Approaching

Wednesday, September 18th, 2013

CMS Deadline for DME Face-to-Face Certification Rules – October 1, 2013

DME Face to Face RuleThe CMS extended deadline for DME Face-to-Face encounter requirements is fast approaching. Providers need to be certain that they are in compliance before October 1, 2013.

Concerns that some providers and suppliers needed additional time to establish protocols led CMS to suspend the time when it expects full compliance with DME face-to-face encounter requirements until October 1, 2013. The compliance deadline is approaching fast and providers who are involved in DME should adopt appropriate standards and procedures before CMS commences active enforcement of the requirement.

Section 6407 of the Affordable Care Act requires a face-to-face encounter with a physician, nurse practitioner, physician assistant, or clinical nurse specialist for certain items of DME.

Most DME suppliers and physicians have implemented appropriate policies and are aware of the change in certification requirement. CMS is concerned that some may need additional time to establish operational protocols necessary to comply with this new law. Suppliers and physicians who order certain DME items should have been collaborating to establish processes to ensure compliance with the new requirement. CMS will begin reviewing for appropriate documentation of internal processes and compliance with the face-to-face requirement for DME for all patient encounters beginning on October 1, 2013.

John H. Fisher

Health Care Counsel
Ruder Ware, L.L.S.C.
500 First Street, Suite 8000
P.O. Box 8050
Wausau, WI 54402-8050

Tel 715.845.4336
Fax 715.845.2718

Ruder Ware is a member of Meritas Law Firms Worldwide

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