Official education on these requirements has been scarce until recently when CMS issued MLN Matters article 8304 which speaks directly to the necessity of documenting the FTF encounter, but did not speak to the requirement of the WOPD in its original release (it was later updated to clarify those requirements). CMS cites the concern that some providers are unprepared for implementation and will need additional time to implement the proper protocols for compliance. However, in our opinion, lack of sufficient education on the entirety of the rule for suppliers and physician referral sources is the most compelling reason for the delay.
CMS has indicated that it will continue to update information concerning the face-to-face rule via their website at www.cms.gov/medical-review MiraVista will keep you informed as updates are released. More detailed coverage of the Face-to-Face ruling can be found in our signature Vista Notes publication or in select digital recordings (specifically “New Face-to-Face Requirements Get Finalized for DME: Are you Ready for Implementation” recorded on 02/07/2013) that can be found on our products page.