Recently, staff and members of the American Association for Homecare met with Centers for Medicare and Medicaid services to discuss Medicare face-to-face and written order prior to delivery (WOPD) requirements.
Specifically, AAHomecare’s contingent included staff members Kim Brummett and Heather Boyd, accompanied by AAHomecare Regulatory Council members Kimberlie Rogers-Bower, Judy Bunn, Laraine Forry, Asela Cuervo and Cara Bachenheimer, met with CMS staff and the DME MAC Medical Directors on May 28 to discuss several key face-to-face and WOPD issues that the industry would like reviewed and potentially revised by CMS.
AAHomecare delivered a presentation (available online by clicking here) that dicussed topics including:
- The removal of the interpretation that the WOPD be a detailed written order and not the five elements referenced in the rule.
- The interpretation that same physician must conduct the face to face exam and complete the WOPD
- The requirement that a prescriber signature date be on the WOPDs.
- The interpretation that a face to face exam has to occur at every instance where a new order is required.
- The interpretation that a date stamp be placed on all WOPDs received by suppliers.
AAHomecare also discussed the delay of enforcement direction provided by CMS, and whether suppliers are exposed in an audit by the ZPIC and RAC when the face-to-face requirement has not been met. Currently, DME MACs have educated that only the MACs themselves have been notified to delay enforcement.
As of today, two additional updated documents have been released: the DME MACs have released a revised dear physician letter that indicates the same physician does not need to conduct the face to face exam and complete the WOPD, and CMS has issued revised instructions that indicate the delay in enforcement for the face to face is applicable to ZPICs, RACS and Program Safeguard Contractors. ‘
Increased Collaboration
The meeting was in line with an increased emphasis by the association tow ork collaboratively with CMS. AAHomecare’s President and CEO Tom Ryan highlighted the need to adopt a strategy that takes “the long view” in terms of working with the agency.
“AAHomecare and CMS have met 10 times in 2014 and made progress in certain areas,” he noted in a public statement. “Chronic Care Policy Group Director, Laurence Wilson was the keynote speaker at the AAHomecare Washington Legislative Conference. At a meeting in late May, both staffs agreed that face-to-face exams and WOPDs can be completed by different physicians and ZPICs and RACs should be included in the enforcement delay.”
Ryan stated that in addition to expanding the number of people and viewpoints engaged in policy problem-solving, working collaboratively with CMS bolsters AAHomecare’s credibility, and established the association as “a go-to resource and trusted advisor for CMS.”
“I’ve challenged my staff to work collaboratively with CMS and develop stronger relationships because we can all help each other improve our positions, rise above the quagmire and succeed in priority areas,” Ryan stated.