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HME News Interviews Andrea Stark on Face-to-Face

Friday, March 6th, 2015

Angela Hayden

Andrea Stark talks with HME News correspondent Anna McDevitt about the Face-to-Face rule in this exclusive interview. The Face-to-Face (FTF) rule affects a total of 166 HCPCS and requires that a physician document the face-to-face encounter with the beneficiary and sign off on evaluations performed by nurse practitioners, physician assistants or clinical nurse specialists. The evaluation of the beneficiary must have taken place within the six months prior to the detailed written order. Additional requirements handed down for those 166 codes disqualify the use of verbal orders to dispense equipment and instead subject these HCPCS to the detailed written order prior to delivery (WOPD) requirements as outlined in the Program Integrity Manual.  These provisions are broken into two phases of implementation: Phase 1 – the requirement for the detailed written order prior to delivery and Phase II- the requirement for the face-to-face notes to be the supplier’s possession prior to delivery.  Phase I began enforcement January 1, 2014, and we currently have an undetermined delay in enforcement of Phase II.


Andrea will be partnering with Healthcare Attorney Jeff Baird and Liz Beaulieu of HME News to discuss the newest developments in the Face-to-Face in the March 11th webcast “A Look Ahead: Legal and Reimbursement Headliners and Guidance for 2015”, click here for additional details on this event. Despite the delay in enforcement of Phase II, Andrea Stark recommends an early adoption approach to this rule as discussed in her interview.  Click on the image below to view:




Why is National Bid Pricing Relevant to Your Business?

Thursday, February 5th, 2015

Angela Hayden


Competitive Bid pricing will expand to all suppliers on January 1, 2016. This mandate is a directive of the 2015 End Stage Renal Disease and Prospective Payment System final rule posted on November 6, 2014.


If you supply respiratory equipment, enteral nutrition, mobility equipment (from walkers to power chairs), infusion equipment, TENS units, support surfaces, commodes, patient lifts, seat lifts, NPWT, or hospital beds you are affected by this rule, and now is the time to prepare for how these changes will impact your business.


Per the ruling, fee schedule amounts for items and services that are subject to competitive bidding will be adjusted on a regional level. The US will be broken down into a total of eight regions where this logic will be applied, including rural areas. Pricing will be adjusted based on how your area is classified within your respective region (rural or non-rural), but one thing is for certain, reimbursement is slated to decrease across the board.


In our recently aired webcast on January 13th, we partnered with HME News to deliver a better understanding of this complex ruling. We provided our attendees with an example of what pricing might look like after the expansion from this rule. Using the pricing adjustment logic explained in the final rule and current Single Payment Amount (SPA) data, we were able to determine what the new Regional SPA might look like for suppliers in a hypothetical location (Bartlesville, OK) post roll out. The results showed a 47% reduction in the reimbursement rate for oxygen concentrators in that area.


A realistic calculation is an essential tool to prepare your business for these future changes.  Now is the time to examine your processes, re-negotiate contracts with your vendors, and/or reallocate staff resources to eliminate inefficiencies in your system. MiraVista can equip you with tools you need to progress through this process.


If you missed the event and would like to get the full details for how this ruling is to be implemented, the event is still available on-demand in digital format.


Additionally, we will be hosting the second part of this series on February 11th to discuss the bundled payment demonstration. The bundled payment provision will directly affect the way that CPAPs and Standard Power Wheelchairs are reimbursed in up to 12 demonstration areas and will set a precedent that will likely impact other products in the future.  Register for the bundle that includes coverage of Part 1 and Part 2 of this series here.


See the HME News write up of the January 13th webinar here.

Update on FTF Directives for Multiple Physicians

Tuesday, May 13th, 2014

Andrea Stark


MiraVista has it on good authority that a clarification from CMS is imminent regarding scenarios where multiple physicians participate in the order process and whether this will be allowed under the FTF directives.  While we can only speculate on what the directive will actually contain, we are optimistic that the change will be a welcomed one by providers.


Currently, CMS has directed the DME MACs that only the physician that documents the FTF can be the one that orders the equipment.  However, the industry has presented CMS with numerous examples of instances where multiple practitioners can be involved.  One such example is a patient visiting a primary care physician with signs of obstructive sleep apnea.  After evaluation, the patient is referred to a sleep lab where the interpreting physician orders the CPAP and suggests an appropriate pressure setting.  Other scenarios are complicated in a hospital setting where multiple physicians evaluate the patient during rounds and the physician coordinating the discharge may or may not be the one that documented the prior evaluation(s).  Each of these two scenarios present suppliers with a predicament in the context of existing guidance.


MiraVista will continue to monitor for this development and will provide an update to our subscribers when the final direction is made available.


Still confused about Face-to-Face requirements? 

You are not alone.


The rules and requirements have continued to unravel since the publication of the Face-to-Face rule and many providers are still scratching their heads about implementation in the real world. Join our webcast “Face-to-Face in the Real World: How to Comply in Its Current Form” on June 3, 2014 at 3pm ET as Andrea Stark partners with HME News to discuss the Face-to-Face rule as it currently exists for DME providers and what to anticipate as we move forward.  Register on our webinars/seminars page.


An Innovative Approach to Obtaining Physician Documentation

Friday, February 17th, 2012

Andrea Stark HME News 2012Have you ever found it difficult to obtain required documentation from a physician? In this interview with HME News, DME consultant Andrea Stark discuses several ways you can obtain the documentation you need without alienating your referral sources.

“It’s important to time it correctly so that you’re [requesting documentation] while the doctor still needs something from you” – Stark.


To see the full interview, visit: http://www.hmenews.com/video.php?cat_id=2&v_id=260.

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