CMS Delays DME Documentation Requirements—Call to Action


by Michael Powe, AAPA Senior Vice President of Reimbursement and Professional Advocacy

Responding to concerns expressed by AAPA and other healthcare organizations and individuals, the Centers for Medicare & Medicaid Services (CMS) announced on June 28, 2013, a delay in the implementation of a regulation that would have required a physician signature when PAs (and NPs) ordered certain durable medical equipment (DME). Currently, PAs are able to order all covered DME with no requirement for a physician signature.

We encourage PAs and PA constituent organizations to provide examples of how the delayed regulation, if implemented, will disrupt care in your practice and we look forward to obtaining input and guidance from PAs and our constituent organizations as AAPA works with federal agencies and Congress. For additional information or to submit examples, please contact Michael Powe, AAPA’s vice president of reimbursement and professional advocacy, at

Mandated by the Affordable Care Act (ACA) and previously scheduled to go into effect on July 1, the new rule targets specific DME items that cost more than $1,000, or were deemed by CMS to be particularly at risk for fraud, waste and abuse. In addition to requiring a face-to-face visit with the patient within six months of ordering DME – which AAPA did not oppose – the regulation required that a physician document, by signature to the DME supplier, the fact that a face-to-face encounter with the Medicare beneficiary had occurred. The rule authorizes PAs to perform that face-to-face visit.

During interactions with senior officials at the U.S. Department of Health and Human Services (HHS) and CMS regarding this issue, AAPA stressed that federal healthcare policies should encourage improved practice efficiencies and decreased administrative burdens. AAPA believes requirements such as this move in the opposite direction.

AAPA understands the intent of the regulation and fully supports reasonable efforts and activities that seek to reduce fraud and abuse in the Medicare program. However, it is essential that those efforts not harm beneficiary access to timely medical care or become overly burdensome for healthcare professionals.

AAPA will continue to work with CMS, HHS and other stakeholders to assure the most appropriate outcome regarding this issue. Thanks to the many PAs who have described the clinical implications of this rule and to the Association of Family Practice PAs for assuring that this issue was front and center for AAPA.

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