Newest FTF Development – Audits Begin for WOPD

On December 3, 2013 CMS posted a clarification on the Face-to-Face rule that rattled the DME community.  The F2F rule, has effectively been divided into two major directives: 1) the requirement for a documented F2F within the six months prior to the written order, and 2) the requirement to secure a Written Order Prior to Delivery. CMS intends to enforce the Written Order Prior to Delivery for claims processed in January 2014.

Prior to the December announcement, enforcement of the Rule was delayed on two separate occasions.  The first was a three month delay in the enforcement from the original July 1, 2013 start date, and the second offered an unspecified delay of enforcement through an unspecified date in 2014.  However, on December 3rd, CMS came forward to indicate that only the F2F provisions were intended for delay and they never intended a delay for the WOPD requirement.  Amid several remaining unanswered questions, CMS and the MACs continue to move this portion of the directive forward.

As of February 18, 2014, we are beginning to see the first of what we except to be many audits as a result of this announcement.  The Jurisdiction C DME MAC posted a notice of a service-specific prepayment review of a number of HCPCS affected by the F2F rule:

• E0607 – Home Blood Glucose Monitor
• K0001 – Standard Manual Wheelchair
• K0002 – Standard Hemi Manual Wheelchair
• K0003 – Lightweight Manual Wheelchair
• E0748 – Osteogenesis Stimulator
• E2510 – Speech Generating Device
• E2402 – Negative Pressure Wound Therapy Electrical Pump

This pre-payment review is an effort to verify compliance with the Face-to-Face provisions concerning the detailed written order prior to delivery (DWOPD) requirements.  Claims subjected to this audit will be developed for additional documentation including:

• Written Order Prior to Delivery
• Delivery Documentation
• Pertinent patient records
• Copy of the ABN if used

While this audit was announced by the Jurisdiction C DME MAC, we expect that the other MACs will be following suit in the days ahead.