As you are aware the Affordable Care Act (ACA) altered how nurses can order DME products for their patients. A provision of the ACA required a physician to document that the physician, PA, NP or CNS has had a face-to-face encounter examination with a beneficiary in the six months prior to the written order for certain items of DME. In the case of a DME ordered by a PA, NP, or CNS, a physician (M.D. or D.O.) must document the occurrence of a face-to-face encounter by signing/co-signing and dating the pertinent portion of the medical record. Failure to meet any of the requirements would have resulted in denial of the claim. The nursing community, including the WOCN Society, has been strongly opposed to the implementation of this provision over concerns that the M.D. oversight requirement is unnecessary and will reduce patient access to DME products. Since 1997, both NPs and CNS' have been authorized by CMS to order DME. Ordering DME for patients is clearly an activity that is within the scope of practice of APRNs.
H.R. 2, The Medicare Access and CHIP Reauthorization Act of 2015, was signed into law by President Obama on April 16thand included a provision to remove the requirement that an M.D. must document the occurrence of a face-to-face encounter. This will greatly reduce the burden that many members have had with ordering DME in the past several years, and removing this barrier has been an advocacy priority for WOCN as a result of hearing from many members on this issue. We expect CMS to offer additional guidance and clarification on DME orders later this year as a result of this legislation, stay tuned for further updates. In the interim, this provision is not being enforced by CMS and suppliers are not required to abide by the M.D. sign off requirement.
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