Did you know that since October 2013 physicians need to conduct a face-to-face interview with the proposed beneficiaries before ordering durable medical equipment? This is one of the rules specified by Medicare, which further clarifies the need to document the data in the patient’s records. A copy of this medical record needs to be sent to the supplier of the ordered DME.
Documentation- During the course of such a face-to-face meeting there needs to be enough documentation in the relevant parts of the patient’s medical records justifying the beneficiary’s eligibility for the particular piece of durable medical equipment ordered on behalf of the patient. The physician also needs to be familiar with the Medicare policy requirements for the same. The particular policy clearly explains the specific conditions that qualify a patient for that particular DME. The relevant documentation of the medical record needs to be furnished with the suppliers of the DME who will need it before they can submit the claim forms to Medicare.
Role of the Physician- While a practitioner who is not a physician is eligible to conduct the face-to-face meeting; it is still the physician who should do the documentation on behalf of the beneficiary. The physician has to cosign the document signed by the non-physician practitioner (nurse practitioners, clinical nurse specialists, and physician assistants) who conducted the face-to-face. This is to ensure that the evaluation of the beneficiary was documented in regards to the DME on that particular date of service. A signed order in the place of a signed medical order does not hold good, and is not the same as the physician cosigning the particular medical record. Hence DME billing is a crucial part.
Post Documentation- Once the documentation is done after the exam, the physician needs to communicate the same to the supplier of the DME. The DME supplier on his or her part needs to be able to access the records of the face-to-face meeting, and needs to maintain a copy of the written order along with other supporting documents and produce them on demand by CMS. What’s more is that it is mandatory to hold these records for a minimum period of 7 years. The face-to-face interview being a precondition for payment, the DME supplier needs to maintain a copy of the records and produce it whenever required to Medicare.
As mentioned earlier, an order in writing is mandatory for DME items to be covered by Medicare. There is also a requirement that the order contain the following to be valid:
- Name of the Beneficiary
- The DME item ordered
- The NPI (National Provider Identifier)
- Signature of the practitioner who prescribes the DME
The date on which the order was placed
The DME order issued by physician practitioner or non-physician practitioner is valid for a period of six months. Hence, a patient may opt for the DME even after being discharged from the hospital, and does not need a fresh face-to-face meeting to be documented. The face-to-face rules cover most of the DME items like wheelchairs, special hospital beds, oxygen equipment, ventilators, glucose monitors, traction equipment and more, which are specified in the list of HCPCS codes. However, Power Mobility Devices (PMDs) are not included in the regular face-to-face meeting as a separate face-to-face encounter with the physician is required for that, and the order for that needs to be issued within 45 days of the encounter.