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: