CMS Clarifies Face‑to‑Face Encounter Requirements for Replacement Claims

What You Need to Know

As discussed in our previous R&R post on WOPD and Face-to-Face Encounter Requirements, any items billed to Medicare with a HCPCS code on the Required List require a Work Order Prior to Delivery and a face-to-face encounter with the treating physician within 6 months before the date on the WOPD. On April 23, 2026, CMS added the following statement to the Face-to-Face Encounter section of the Standard Documentation Requirements for All Claims Submitted to DME Medicare Administrative Contractors (DME MACs):

"The exception to this requirement is for items replaced with an identical item (same HCPCS code) following the expiration of the five-year RUL."

This clarification has a retroactive effective date of January 1, 2024, and confirms that a new face‑to‑face encounter is not required when a beneficiary is simply receiving a routine replacement of the same equipment at the end of its expected useful life. This exception applies only when (1) the original item has reached or exceeded its reasonable useful lifetime, and (2) the replacement item is exactly the same as the original, billed under the same HCPCS code.

What This Means for You

For DMEPOS suppliers, this clarification reduces unnecessary administrative burden for routine replacement claims. When you are replacing equipment solely due to the expiration of the RUL and the replacement item is identical to the original, you no longer need to obtain or submit documentation supporting a new face‑to‑face encounter. This can help speed up order fulfillment and billing while minimizing delays related to provider documentation.

However, it is also important to understand what has not changed. A new written order is still required for replacement equipment, and you must be able to demonstrate that the RUL has been met. All applicable coverage, coding, and payment rules remain in effect, and documentation must still be maintained and made available upon request for audits or reviews.

Operationally, suppliers should ensure they are accurately tracking original delivery dates, confirming that replacement items match the original HCPCS code, and clearly documenting the reason for replacement. Educating your intake, billing, and documentation staff on this clarification can help prevent unnecessary requests for face‑to‑face records and reduce the risk of claim denials.

For more information on CMS's face-to-face requirements, review the Standard Documentation Requirements for All Claims Submitted to DME Medicare Administrative Contractors (DME MACs).