Glossary / Face-to-face encounter

Face-to-face encounter Medicare DME term

Face-to-face encounter

The in-person or qualifying telehealth visit where the treating practitioner evaluates the patient for the item, within the 6 months before the order.

A face-to-face encounter is a visit in which the treating practitioner examines the patient and documents the clinical condition the DMEPOS item addresses. Under 42 CFR 410.38(d)(2), for power mobility devices and any item on CMS's Required Face-to-Face Encounter and Written Order Prior to Delivery List, that encounter must occur within the 6 months before the order date. A telehealth visit counts if it meets Medicare's telehealth rules.

The encounter lives in the practitioner's chart notes, not on a supplier form. Reviewers want to see that the visit gathered subjective and objective findings for diagnosing, treating, or managing the condition that makes the item medically necessary. Supplier-prepared statements and attestations signed by the physician do not substitute for the contemporaneous record.

Items not on the Required List have no regulatory face-to-face requirement, but the clinical record still has to establish medical necessity, and the coverage policy for the item (the LCD and its policy article) may set its own evaluation and timing rules, as the PAP and oxygen policies do.

Common questions

Which items require a face-to-face encounter?

Power mobility devices and the items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List, which CMS publishes alongside the Master List. Check the current list rather than assuming from the category.

Does a telehealth visit count?

Yes, when the visit satisfies Medicare's telehealth requirements in 42 CFR 410.78 and 414.65. The documentation standard is the same as an in-person visit.

What if the encounter is more than 6 months before the order?

The order does not qualify. The patient needs a new encounter and then a new order dated after it; AffirmDME's checklist compares the encounter date to the order date and flags the gap.

Related

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Sources: 42 CFR 410.38(d)(2) — face-to-face encounter · DME MAC Article A55426 — Standard Documentation Requirements · CMS: Master List and Required Lists . Definitions summarize public Medicare policy and are not legal or billing advice.

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