F2F Exams: CMS Clarifies Policy & Issues "Dear Physician" Letter

A new bulletin from the Centers for Medicare & Medicaid Services (CMS) has clarified who can conduct the face-to-face (F2F) examination and the responsibilities of the ordering physician.

CMS has also released a new Dear Physician letter about those topics.

The bulletin says a physician (M.D., D.O. or D.P.M.), a physician assistant, a nurse practitioner or a clinical nurse specialist must conduct the F2F exam with the Medicare beneficiary within six months before a written order for certain types of durable medical equipment.

The equipment involved includes categories such as manual wheelchairs (including standard, standard hemi, lightweight, high-strength lightweight, ultralightweight and heavy-duty/extra heavy-duty); hospital beds; patient lifts; pressure-reducing support surfaces; seat-lift mechanisms; speech-generating devices; and wheelchair options and accessories.

The Dear Physician letter, signed by the four DME MAC medical directors, reminds the prescribing physician that the F2F exam "must document that the beneficiary was evaluated and/or treated for a condition that supports the need for the item(s) of DME ordered," and that "all Medicare coverage and documentation requirements for DMEPOS also apply."

The beneficiary's medical records must include sufficient information "to demonstrate that the applicable coverage criteria are met," the bulletin adds.

While the clinical professional who prescribes the equipment does not have to be the person who conducted the F2F exam, the bulletin says the prescribing professional must verify that the F2F exam did take place within six months prior to the date of the prescription, must have documentation of that exam, and must provide a copy of the F2F exam documentation and the prescription to the DME supplier.

The Dear Physician Letter also describes the elements that must be included in the written order prior to delivery, including the beneficiary's and physician's names, the date of the order and the start date, and a detailed description of the equipment being ordered.

Click HERE for a pdf copy of the Dear Physician letter to pass on to referral sources.

About the Author

Laurie Watanabe is the editor of Mobility Management. She can be reached at lwatanabe@1105media.com.

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