Required Face-to-Face (F2F) Encounter and Written Order Prior to Delivery (WOPD) List Questions & Answers (Q&As)
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- What items currently require a Face-to-Face encounter and WOPD?
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Use the WOPD Lookup Tool to check if a specific HCPCS is included in the Required List for Face-to-Face and WOPD.
See the complete list
from CMS.
Originally published: 10.13.2022
Revised: 01.08.2025
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- What are the requirements for a valid WOPD?
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The information for the WOPD is the same as a Standard Written Order (SWO). The only difference is that suppliers must have the SWO before delivering the item to the beneficiary. The order date must be on or before the date of delivery.
Originally published: 10.13.2022
Reviewed: 01.08.2025
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- Is there a limit to the time span between the Face-to-Face encounter and the date of the WOPD?
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Yes. The WOPD must be completed within 6 months after the Face-to-Face encounter.
Originally published: 10.13.2022
Reviewed: 01.08.2025
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- What are the elements required for a valid Face-to-Face encounter?
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The Face-to-Face encounter is used to support payment for the items ordered and should be documented in the medical record.
Examples of documentation for the encounter includes the patient's:
- History
- Physical examination
- Diagnostic tests
- Summary of findings
- Progress note
- Treatment plans
- Other appropriate sources of information that may be appropriate
The supporting documentation must include subjective and objective patient-specific information used for diagnosing, treating, or managing a clinical condition for which the DMEPOS is ordered.
See the Local Coverage Determination and Policy Article of the item you are providing to make sure all coverage criteria are met.Originally published: 10.13.2022
Reviewed: 01.08.2025
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- Can telehealth be used as a Face-to-Face encounter?
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This Face-to-Face requirement also includes examinations conducted by CMS-approved use of telehealth examinations, which must meet the requirements of DMEPOS coverage. See MLN901705 – Telehealth Services
for more information.
Originally published: 10.13.2022
Reviewed: 01.08.2025
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- Who must conduct the Face-to-Face encounter?
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For items on the Required List other than power mobility devices (PMDs), the treating practitioner who conducted the Face-to-Face encounter doesn't need to be the prescriber for the DMEPOS item. The prescriber must verify that a qualifying Face-to-Face encounter occurred within 6 months of the date of their order and have documentation of that encounter. For PMDs, the treating practitioner must conduct the Face-to-Face encounter.
Originally published: 10.13.2022
Reviewed: 01.08.2025
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- Is a qualifying Face-to-Face encounter required each time there's a new order for an item on the Required List?
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Yes. Anytime a new order is submitted for an item on the Required List
, there must be a new Face-to-Face encounter.
Originally published: 10.13.2022
Reviewed: 01.08.2025
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