Face-to-Face Exam Goes on the List of Medicaid Questions

ATLANTA — When it comes to home medical equipment,
government agencies have never been known for their promptness or
clarity on notification or guidance for new policies.

In Georgia, providers were notified Dec. 28 that the
face-to-face requirement under the Affordable Care Act would be
effective Jan. 1, 2011, when serving the state’s Medicaid
patients.

Under the nation’s new health reform law, Medicare beneficiaries
are required to have an in-person doctor’s visit in order for a
physician to prescribe any items of DME. The face-to-face exam must
be within six months of the physician order. The Department of
Health and Human Services also can apply the requirement to items
paid for under state Medicaid programs.

The Georgia Association for Medical Equipment Suppliers has
asked for a delay in the state’s implementation until major
questions about the new policy can be resolved: “Can you offer
clarification on the new face-to-face requirement? How should the
doctor visit be noted in the provider’s records? Do we need to
submit this to anyone? Does this requirement apply to disposable
supplies? Enteral nutrition? Wheelchair repairs?”

State association members have pointed out their concerns about
the “burdensome” requirement to officials at the state’s Department
of Community Health, according to GAMES Executive Director Teresa
Tatum, but so far, there have been no answers.

“The only response we got back was an email that said ‘the
requirement stands as is,’” Tatum said.

Although CMS has issued no guidance on the new requirement,
state personnel have indicated Georgia’s Medicaid program must be
compliant with the federal law, Tatum said. “But how do you
actually do it?” she wondered. “The doctor and the patient have to
make it happen, but how do we enforce it?”

The association has requested that the issue be addressed at the
next meeting of the state’s Medical Care Advisory Committee. In the
meantime, Tatum said, the new requirement puts providers in the
middle and leaves them holding the bag.

Georgia’s Medicaid providers have also been left hanging with a
reimbursement issue on claims for Medicare-Medicaid dual eligibles,
Tatum said. When the state changed processors to HP Enterprise
Services last year, payments for the crossover claims stopped.

“We’re not getting responses from DCH or HP about the claims,”
she said. “It’s just another frustrating situation where we’re
caught in a circle and getting no answers.”