Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Order and Face-to-Face Encounter Requirements

Effective January 1, 2020, CMS streamlined and simplified the order requirements for DMEPOS items (PDF), and outlined the process for identifying items that need a face-to-face encounter, written order prior to delivery, and/or prior authorization.

On January 13, 2022, the first iteration of the Required Face-to-Face Encounter and Written Order Prior to Delivery List (87 FR 2051) was published that announced 46 PMD codes per statute, and seven other DMEPOS items (one- osteogenesis stimulator and six- orthoses

On January 17, 2023, a second Federal Register Notice (88 FR 2546) was published that announced 10 additional orthoses that will require a face-to-face encounter and written order prior to delivery as a condition of payment.

On, May 13, 2024, a third Federal Register Notice was published that announced 13 additional codes (three- hospital beds, two- osteogenesis stimulators, six- lumbar sacral orthoses, and two- knee orthoses). One orthosis code was removed from the list due to its removal from the Master List.

Therefore, as of August 12, 2024, there is a total of 75 items on the Face-to-Face Encounter and Written Order Prior to Delivery List.

Standardized DMEPOS Written Order/Prescription

Any Medicare provider or supplier that writes DMEPOS orders or prescriptions will now use a standard set of elements that will be applicable to all DMEPOS items.

• Beneficiary name or Medicare Beneficiary Identifier (MBI) Number
• Description of the item
• Quantity, if applicable
• Treating practitioner name or National Provider Identifier (NPI)
• Date of the order
• Treating practitioner signature

The treating practitioner must submit the complete written order to the supplier prior to submitting a claim for Medicare payment.

Consolidated DMEPOS Lists

The Master List (PDF) is a library of all DMEPOS items posing vulnerabilities to the Trust Fund that may require providers/suppliers to comply with additional conditions related to payment requirements. From this list, items may be selected for one or both of the Required Lists:

• The Required Face-to-Face Encounter and Written Order Prior to Delivery List (PDF)
• The Required Prior Authorization List (PDF)

Required Face-to-Face Encounter and Written Order Prior to Delivery List

Review contractors assess compliance with the face-to-face encounter and written order prior to delivery requirements. Some items (such as PMDs) have statutorily imposed requirements. For items that do not have statutory requirements, a face-to-face encounter and written order is required only if the item is selected from the Master List and placed on the Required Face-to-Face Encounter and Written Order Prior to Delivery List. Items selected for the list will be published in the Federal Register with no less than a 60-day Notice Period.

CMS may suspend the face-to-face encounter and written order prior to delivery requirements generally, or for a particular item or items, at any time and without creating a new rule, except for those items included on the Master List due to statutory mandate.

Written Order Prior to Delivery (WOPD) Requirements

For items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List, a complete order is required prior to the item’s delivery. (For all other DMEPOS items, the order is required prior to claim submission.)

Face-to-Face Encounter requirements applicable to certain DMEPOS items:

• For all items requiring a face-to-face encounter, a practitioner visit is required within six months preceding the order. Note: face-to-face encounters for PMDs were previously required within 45 days preceding the written order.
• The encounter must be used to gather subjective and objective information associated with diagnosing, treating, or managing a clinical condition for which the DMEPOS is ordered.
• The face-to-face encounter must be documented in the pertinent portion of the medical record (for example, history, physical examination, diagnostic tests, summary of findings, progress notes, treatment plans or other sources of information that may be appropriate). The supporting documentation must include subjective and objective, beneficiary specific information used for diagnosing, treating, or managing a clinical condition for which the DMEPOS is ordered.
• If the encounter is performed via telehealth, the requirements for telehealth services and payment for telehealth services must be met.
• A supplier must maintain the written order/prescription and the supporting documentation provided by the treating practitioner and make them available to CMS and its agents upon request.

CMS may suspend the face-to-face encounter and written order prior to delivery requirements generally, or for a particular item or items, at any time and without creating a new rule--except for items included on the Master List (PDF).

Learn More

Medicare Learning Network—DMEPOS Written Order, Face-to-Face Encounter, and/or Prior Authorization Requirements (PDF): Learn more about the standard elements for a DMEPOS order and items potentially subject to face-to-face encounter and written order prior to delivery and/or prior authorization requirements.

Final Rule CMS-1713: The rule, finalized in 2019, streamlines the requirements for ordering DMEPOS items, and develops a new list of DMEPOS items potentially subject to a face-to-face encounter, written orders prior to delivery, and/or prior authorization requirements.

Federal Register Notice: This notice announces the items included on the Required Face-to-Face Encounter and Written Order Prior to Delivery List.