The Master List for Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) comes from a November 2019 final rule that created the list to serve as a library of items that have been identified as potential vulnerabilities to the Medicare Trust Fund based on criteria outlined in 42 CFR 414.234(b). In other words, items are added to the Master List, in part, because CMS has identified a high rate of errors in billing associated with these items.
On May 13, 2024, the Centers for Medicare & Medicaid Services (CMS) and the Department of Health and Human Services (HHS) published 89 FR 41324 (the Rule), which added Healthcare Common Procedure Coding System (HCPCS) codes to the Master List of Items Potentially Subject to Face-To-Face Encounters and Written Orders Prior to Delivery (F2F/WOPD) and/or Required Prior Authorization Requirements. The updates are effective on August 12, 2024.
The Master List contains items that appear on the DMEPOS Fee Schedule and meet one of the additional criteria as stated in 42 CFR 414.234(b)(1), including “any items statutorily requiring a face-to-face encounter, a written order prior to delivery or prior authorization.” Thus, items included on the Master List can then be added to the F2F/WOPD List or Required Prior Authorization List. The F2F/WOPD contains DMEPOS items that require a face-to-face encounter and written order and are added by HHS and CMS based on analysis of various factors, including operating limitations, item utilization, cost-benefit analysis, emerging trends, and vulnerabilities identified in official agency reports. Items that are added to the Prior Authorization List are selected from the Master List and require prior authorization.
CMS added a total of 76 HCPCS codes that meet the criteria for inclusion in the Master List. Each code added is listed in Table 1 of the Rule. The published Rule also adds 13 HCPCS codes to the F2F/WOPD List, including codes for three hospital beds, two osteogenesis stimulators, six lumbar sacral orthoses, and two knee orthoses. Lastly, the published Rule updates the Required Prior Authorization List to include the addition of nine HCPCS codes and the removal of one HCPCS code. HHS and CMS noted the additions to the Prior Authorization List were due to a recent history of continually high improper payment rates. Implementation of updates to the Master List and the F2F/WOPD List are effective on August 12, 2024. Prior authorization of newly added osteogenesis stimulators will be implemented in two phases, with phase one beginning on August 12, 2024, applying to only CA, FL, OH and PA. Phase two begins on November 12, 2024, and applies to the remaining states and territories.
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