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2/17/2014 at 2:46:27 PM GMT

I wanted to ask the membership several questions regarding the WOPD provision and get an idea of how everyone is handling this nightmare two months in...

1: What kind of form/s are you using, are you using your own generated forms at all? We are using a combination of our own forms and the existing discharge documentation from certain hospital systems (with slight alterations, mostly having someone at the hospital add the Doc's NPI)

     -any tips on streamlining this process? What seems to be the consensus from the discharge planners?

2: Is everyone filling out their own WOPDs? we are taking the instruction from CGS to mean that WE can fill out the entire WOPD with the exception of the signature of the Doc and the date... We've found that this greatly increases accuracy as well as return time?

 3: How much has this affected your ability to get equipment delivered in a timely manner? We are seeing slight delays across the board...

4: Has anyone seen any denials or audits focusing on WOPD yet? Based on what i'm hearing from CGS they are still giving us some time to implement all these processes, I can imagine they are on the horizon though.

 5: Any other thoughts or problems? Would anyone be interested in seeing the forms MRS Homecare is using. I will be happy to post them here in a format that anyone can edit themselves.

3/6/2014 at 9:33:15 PM GMT
Posts: 9
Tyler -
AAHomecare is developing an ongoing bullet point of issues with Face-to-Face and WOPD. Some other state associations have added a few comments/ questions also. AAH has been writing letters to CMS asking for clarification and explaining problems with parts of the policy. We can add to this list too if GAMES members have comments / issues.


·         Same physician must conduct the face to face and sign the written order prior to delivery

·         Original delay was for both WOPD and face to face from 7/1/13.  Education from MACS that they had to be implemented together and then changed in December 2013.

·         Delay enforcement of face to face and not WOPD, DME MACs educating not delayed due to the fact that CR8304 only speaks  to DME MAC contractors, it does not speak to CERT, RAC or ZPIC.

·         Requirements for documentation on WOPD in statute versus DME MACs stating WOPD and DWO are the same.  WOPD was intended to be a written dispensing order with 5 elements, not the DWO.

·         DME MACs indicating a missing element is not curable by a provider.  If a provider realizes an element is missing (NPI), obtains a corrected WOPD, they should be able to bill from the point that the written order was ‘cured’.  DME MACs indicate another provider can obtain a WOPD that is valid and bill going forward, but not the original provider.   DMDs cite there is no language that the WOPD can be cured, there is also no language that it cannot be cured, why assume it can’t?

·         Requiring a date/time stamp on WOPD and face to face documentation to prove receipt of items prior to delivery.    One DME MAC now indicates a fax date stamp would be ok.  If the face to face occurred on a date prior to or on the delivery and the physician signed and dates the WOPD on or prior to the date of delivery, this should be sufficient. 

·         The dear physician letter put out by DME MAC DMDs indicate that when the state requires a new written order (which some do annually) then the Medicare face to face rule applies and the patient needs to obtain another face to face.  The face to face rule should apply only when Medicare requires a new written order, not the state.

·         The dear physician letter put out by DME MAC DMDs indicates the date of the written order has to be before the date of service (which is the date of delivery).  It can be on the same date and has always been on or before for the few items that required a WOPD previously.

·         The requirement for a new face to face when there is an acquisition.  Historically, in acquisitions a new CMN document (this was back when CMNs were the requirement) did not need to be obtained if the acquiring provider felt the CMN in the purchased providers file met Medicare’s requirements.  The requirement for a new written order with a change in provider has led to the interpretation that a new face to face is required in an acquisition.  This is systematically impossible.  If provider A buys provider B and there are 5,000 patients with rental items that are on the list for face to face requirement, then 5,000 patients need to go to the doctor because provider A sells their business to provider B?  A with the old CMN requirement, an acquisition should be exempt from the face to face requirement, as long as the patient met the criteria for face to face when they were originally setup by provider A.

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