“Face to Face Requirements” “Written Order Prior to Delivery” “PECOS” post 1/6/14

1. ”Tuesday at 10 “ February 11, 2014 “Face to Face Requirements” “Written Order Prior to Delivery” “PECOS” post 1/6/14 Presented by Argosy Group, Inc Tel: 888-691-2746 info@argosygroup.org

2. Disclaimer • It is the intent of the Argosy Group to provide up to date, accurate information . The information contained in this presentation is for educational purposes only and is not presented as legal advice or with any expressed or implied warranty of accuracy. • Argosy Group encourages you to visit and communicate with your Medicare Regional DMEMAC and your Accreditation Agency often

3. Face-to-Face Requirements • Mandated by the Affordable Care Act (2003) • Initial Implementation: July 1, 2013 Postponed • Next date: October 1, 2013 Postponed • Next date: Early 2014? Continue to check in with your DMEMAC for updates • Section 6407 of the ACA established a face-to-face encounter requirement for certain items of DME. The law requires that a physician must document that a physician, nurse practitioner, physician assistant or clinical nurse specialist has had a face-to-face encounter with the patient. The encounter must occur within the 6 months before the order is written for the DME.

4. Patient must have a face-to-face before order is written • Supplier must receive a detailed written order before delivery of item • May have negative impact on patient hospital discharge • Providers in a Competitive Bid Area are not exempt • Face-to-face must document all of the coverage guidelines for product being prescribed/provided. List of affected HCPCs will be sent with copy of today’s presentation

5. Get Ready… • Identify items provided that are affected • Determine what policies and procedures need to be updated so that company is in compliance with the face-to-face regulations. • Train employees whose job functions are affected by the change in policy and procedure. • Train, train, train employees….failing to comply with the regulations could result in claim denials and overpayment requests post-payment. • EDUCATE physicians on requirements.

6. Written Order Prior to Delivery • While active enforcement of the face-to-face requirements has been postponed until a future date to be announced in Calendar Year 2014, the delay does not impact provisions related to written orders prior to delivery. CMS will begin enforcement of the written order prior to delivery requirement for dates of service (DOS) on or after January 1, 2014. • A list of products subject to WOPD will be sent with copy of presentation

7. Written Order Prior to Delivery The beneficiary’s name; The DME item ordered; The prescribing practitioner’s National Provider Identification (NPI); The signature of the prescribing practitioner; and, The date of the order • Failure to obtain a valid detailed written order prior to delivery will result in the item being denied as excluded by statute

8. DETAILED WRITTEN ORDER: • CMS requirements for detailed written orders. Per the standard documentation guidelines, detailed written orders must also include the following: • Physician’s Name; • Start date of the order (if different from the date of the order); • Signature date personally entered by the ordering practitioner; • Dosage or concentration, if applicable; • Route of administration, if applicable; • Frequency of use; • Duration of infusion, if applicable; • Quantity to be dispensed; and • Number of refills, if applicable.

9. PECOSProvider, Enrollment, Chain & Ownership System • CMS will instruct contractors to turn on Phase 2 denial edits on January 6, 2014. These edits will check the following claims for a valid individual National Provider Identifier (NPI) and deny the claim when this information is invalid Pre 1/6/2014: • N544 Alert: Although this was paid, you have billed with a referring/ordering provider that does not match our system record. Unless corrected, this will not be paid in the future.

10. Post Implementation – Dates of Service on/after January 6, 2014 • If the ordering/referring provider: - Is on the claim, Medicare will verify that the ordering/referring provider is in PECOS and eligible to order and refer. - If ordering/referring provider is not in PECOS or is in PECOS but is not of the specialty to order or refer, the claim will not be paid. It will be denied. - If the name submitted on the claim does not match the provider’s name in PECOS, the claim will be denied.

11. If you are receiving the N544 messages, take the following steps in the order listed to correct the claim and avoid claim rejections: • Check to see whether the provider is a specialty that can order DMEPOS. • DME ordered by physical and occupational therapists, who are enrolled in PECOS, but are not allowed by statute to order DME for Medicare purposes.

12. Verify that the ordering physician NPI is on the list of physicians and other non-physician practitioners enrolled in PECOS. This can be done by: • Calling the Noridian IVR, 1-877-320-0390 and selecting Option 6 to enter the NPI and name of the referring provider. The IVR will then respond if the individual is or is not enrolled in PECOS. • Checking the CMS ordering/referring provider downloadable report containing the NPI, first name, and last name of providers enrolled in PECOS located at http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/MedicareProviderSupEnroll/MedicareOrderingandReferring.html

13. Ensure you are correctly entering the Ordering/Referring Provider’s name on the claim. • Do not use “nicknames” on the claim, as their use could cause the claim to fail the edits. • Do not enter a credential (e.g., “Dr.”) in a name field. • Ensure that the name and the NPI you enter for the ordering provider belong to a physician or non-physician practitioner and not to an organization, such as a group practice that employs the physician or non-physician practitioner who generated the order or referral. • Make sure on electronic claims that you are not submitting the last name in the first name field and vice versa.

14. Q & A “Voice” Refill Reminders DME Audit Shield Operations Consulting Argosy Group, Inc Accreditation Preparation DME Billing Service & AR Collector Join us at 10:00 a.m. CST on Tuesday, March 11, 2014 for another “Tuesday at Ten Presentation”

15. Let Argosy Group help younavigate your DME business • Medicare Compliance driven Billing Service/Application – RT RX DME Billing Service • Accounts Receivable Recovery and Management • Real-Time On-Line Insurance verification • Independent Chart Audit Programs • On-site or On-line Consulting (Intake to Billing) • Policy & Procedure Manuals Development • Accreditation Readiness & Mock Reviews • On-line Continuing Education (CEUs) • Reimbursement Training The Argosy Group, Inc and Raintree RX has given us the confidence to spend more time growing our business and less time on paper-work. It is user friendly and cost-effective. Filing of claims is timely and questions are answered right away. I highly recommend Raintree RX as the new age “Pharmacy & Specialty DME” billing solution. Rose Johnson, DME Manager Able Care Pharmacy & Medical Supplies, Enfield CT

16. Reference Sites • www.cms.hhs.gov CMS • www.cms.hhs.gov/manuals/downloads • www.medicarenhic.com (Region A) • www.ngsmedicare.com (Region B) • www.cignagovernmentservices.com (Region C) • www.noridianmedicare.com (Region D) • www.dmepdac.com (Medicare Pricing, Data Analysis and Coding)