Timing of the Face-to-Face Encounter

5.4.1 – Timing of the Face-to-Face Encounter (Rev. 13689; Issued: 03-19-26; Effective: 04-20-26; Implementation: 04-20-26) For DMEPOS items appearing on the Required Face-to-Face and Written Order Prior to Delivery List, the treating practitioner must document and communicate to the DMEPOS supplier that the treating practitioner has had a face-to-face encounter with the beneficiary within the 6 months preceding the date of the written order/prescription. A qualifying face-to-face encounter is required each time there is a new order/prescription for a DMEPOS items on the Required Face-to-Face and Written Order Prior to Delivery List. A single face-to-face encounter may document the clinical conditions necessitating multiple DMEPOS items. In this situation, regardless of whether the DMEPOS items are prescribed on different dates, the single face-to-face encounter may be utilized in support of the multiple items, so long as the encounter date is within 6 months prior to the date of the orders. As always, the supplier is responsible for submitting documentation to support each claim upon request. The exception to this requirement is for items replaced with an identical item (same Healthcare Common Procedure Coding System (HCPCS) code) following the expiration of the five-year reasonable useful lifetime. In this circumstance, a new Face-to-Face evaluation would not be required unless specifically required by a Local Coverage Determination or National Coverage Determination. The face-to-face requirement codified at 42 CFR 410.38 does not supplant other CMS coverage policies.