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Gwinnett Forsyth Chapter United Advanced Practice Registered Nurses

Update on requirement for physician co-signature on DME

Posted almost 5 years ago by Julie Hannah

Do you prescribe home blood glucose monitors, nebulizer machines, CPAP devices, TENS units, portable oxygen or other medical equipment? Section 6407 of the Affordable Care Act established a face-to-face encounter requirement for certain items of DME (durable medical equipment). This law was delayed in implementation, but unless overturned it will soon be in effect for all your patients on Medicare or Medicaid.

The law requires that a physician (MD or DO) must document that a physician, nurse practitioner, physician assistant or clinical nurse specialist document a face-to-face encounter with the patient within the 6 months before the order is written for the DME. The full list of applicable items of DME are listed at the bottom pages of this website:

The order for DME must include all of the following, or the billing claim will be denied:

1. beneficiary's name

2. item of DME ordered

3. prescribing practitioner's National Provider Identifier (NPI)

4. signature of the ordering practitioner (and physician co-signature)

5. date of the order

The requirements listed in the regulation do not supersede other CMS requirements for detailed written orders. Per the standard documentation guidelines, orders must also include:

6. practitioner's and collaborating physician's printed names

7. start date of the order (if after the order date)

8. dosage or concentration, if applicable

9. route of administration, if applicable

10. frequency of use

11. duration of infusion, if applicable

12. quantity to be dispensed

13. number of refills, if applicable

Physicians will be provided an additional payment, using code G0454, for signing/co-signing the face-to-face encounter of the PA/NP/CNS. Note that the G code may only be paid to the physician one time per beneficiary per encounter, regardless of the number of covered items.

This an update regarding CMS (Centers for Medicare and Medicaid Services) rule delay regarding requiring physician co-signature of a face-to-face encounter in the six months prior to the ordering of DME, taken from the AANP website:

AUSTIN, TX (Janaury 10, 2014) -- AANP has been made aware that some NPs are experiencing difficulty when ordering DME items. Certain DME companies are implementing the CMS rule that would require a nurse practitioner to obtain a physician's documentation on the patient's medical record that a face-to-face encounter with that patient has taken place, even though CMS stated in a September 9th announcement that they, "will start actively enforcing and will expect full compliance with the DME face-to-face requirements beginning on a date that will be announced in Calendar Year 2014."  If you encounter a supplier who will not fill your DME order, please advise them that the CMS has not yet provided a date for implementation, and ask that they fill your order.

Additionally, we ask that you email us at so that we can track those suppliers that are not filling DME orders provided by NPs.  AANP has and will continue to work with both CMS and Congress to push for a permanent delay of this burdensome regulation.  To help drive this effort we also ask that you use the links provided to contact CMS Administrator Marilyn Tavenner and your Members of Congress.

I hope this is helpful to my colleagues who prescribe DME.

Julie Hannah, FNP-C