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Face-to-Face Requirements Set to Take Effect July 1

Update from American Association for Homecare

On June 7, NHIC, Corp. released a notice titled “Detailed Written Orders and Face-to-Face Encounters” informing DME providers of changes to documentation requirements for face-to-face encounters.

Beginning July 1, physicians must document a face-to-face encounter exam with a beneficiary in the six months prior to the written orders of certain items of DME. According to the release, this section will not apply to power mobility devices, as they are covered under a separate requirement. For more information on these changes, click here and here.

AAHomecare’s Regulatory Council has been working for weeks with CMS representatives to clarify the requirements, and to delay implementation because of the tremendous burden this requirement will place on DME providers in Round 2 bid areas. CMS responded initially, but not completely. AAHomecare is waiting for a response from CMS to yesterday’s inquiry as to when additional clarification would be forthcoming, as well as when a delay will be announced.

AAHomecare will keep members informed of any additional feedback we receive. In the meantime, providers should sign up for the NHIC, Corp. listserve and prepare for the July 1 start date.

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