Face to Face Encounter for Six HCPCS Codes

An announcement in the Federal Register regarding indicates any product billed with six identified HCPCS will require a Face-to-Face Encounter and a Written Order Prior to Delivery. The six HCPCS are:

CMS-6081-N also announced that the following six O&P HCPCS codes will require a Face-to-Face Encounter and Written Order Prior to Delivery as a condition of payment for claims with a date of service on or after April 13, 2022:

• L0648 Lumbar-Sacral Orthosis, Sagittal Control, With Rigid Anterior And Posterior Panels, Posterior Extends From Sacrococcygeal Junction To T-9 Vertebra, Produces Intracavitary Pressure To Reduce Load On The Intervertebral Discs, Includes Straps, Closures, May Include Padding, Shoulder Straps, Pendulous Abdomen Design, Prefabricated, Off-The-Shelf
• L0650 Lumbar-Sacral Orthosis, Sagittal-Coronal Control, With Rigid Anterior And Posterior Frame/Panel(S), Posterior Extends From Sacrococcygeal Junction To T-9 Vertebra, Lateral Strength Provided By Rigid Lateral Frame/Panel(S), Produces Intracavitary Pressure To Reduce Load On Intervertebral Discs, Includes Straps, Closures, May Include Padding, Shoulder Straps, Pendulous Abdomen Design, Prefabricated, Off-The-Shelf
• L1832 Knee Orthosis, Adjustable Knee Joints (Unicentric Or Polycentric), Positional Orthosis, Rigid Support, Prefabricated Item That Has Been Trimmed, Bent, Molded, Assembled Or Otherwise Customized To Fit A Specific Patient By An Individual With Expertise
• L1833 Knee Orthosis, Adjustable Knee Joints (Unicentric Or Polycentric), Positional Orthosis, Rigid Support, Prefabricated, Off-The-Shelf
• L1851 Knee Orthosis (KO), Single Upright, Thigh And Calf, With Adjustable Flexion And Extension Joint (Unicentric Or Polycentric), Medial-Lateral And Rotation Control, With Or Without Varus/Valgus Adjustment, Prefabricated, Off-The-Shelf
• L3960 Shoulder Elbow Wrist Hand Orthosis, Abduction Positioning, Airplane Design, Prefabricated, Includes Fitting And Adjustment

The first five HCPCS will also require prior authorization from Medicare.

The effective dates for the process are:

April 13, 2022, NY, IL, FL, CA

July 17,2022 MD, PA, NJ, MI, OH, KY, TX, NC GA, MO, AZ, WA

October 10, 2022, Nationwide

What Does This Mean for You?

Prior to delivering an item billed with one of these codes, the patient is required to see a physician and have the encounter documented. Additionally, the physician must complete a Written Order Prior to Delivery (WOPD.) Since these items also require prior authorization, you must submit copies of the medical record indicating there was a Face-to-Face Encounter and the final WOPD at the time of prior authorization. You cannot dispense the brace until prior authorization approval is received.

Stay tuned for more details about prior authorization implementation and Face to Face Encounters. The DME MACs will be offering training and resources for suppliers. As information becomes available, we will share it with you all here.