Skip to Main Content

Required Face-to-Face (F2F) Encounter and Written Order Prior to Delivery (WOPD) List Questions & Answers (Q&As)

Click on a question to expand or Show All / Close All

  1. What items currently require a Face-to-Face encounter and WOPD?

    • 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 listExternal PDF from CMS.

      Originally published: 10.13.2022
      Reviewed: 12.08.2025

  2. What are the requirements for a valid WOPD?

    • 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: 12.08.2025

  3. Is there a limit to the time span between the Face-to-Face encounter and the date of the WOPD?

    • Yes. The WOPD must be completed within 6 months after the Face-to-Face encounter.

      Originally published: 10.13.2022
      Reviewed: 12.08.2025

  4. What are the elements required for a valid Face-to-Face encounter?

    • 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: 12.08.2025

  5. Can telehealth be used as a Face-to-Face encounter?

    • 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 ServicesExternal PDF for more information.

      Originally published: 10.13.2022
      Reviewed: 12.08.2025

  6. Who must conduct the Face-to-Face encounter?

    • 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: 12.08.2025

  7. Is a qualifying Face-to-Face encounter required each time there's a new order for an item on the Required List?

    • A qualifying face-to-face encounter is required within 6 months of writing the order for any item on the Required Face-to-Face Encounter and Written Order Prior to Delivery List.

      Exceptions – When a Face-to-Face Encounter is not required:

      1. Replacing the same item after its reasonable useful lifetime (if policy specific rules are met)
      2. Replacing a Power Mobility Device (PMD) in the same performance group that was previously covered by Medicare during the 5-year useful lifetime.
        • Note: Replacement during an item’s useful lifetime is limited to situations involving loss or irreparable damage from a specific accident or natural disaster (e.g., fire, flood, etc.).

      Originally published: 10.13.2022
      Revised: 12.08.2025

  8. If a beneficiary switches from a Medicare Advantage (MA) plan to traditional Medicare and is already using a DMEPOS item, do they need a new WOPD and a new F2F visit?

    • When a person transitions from another payer (like an MA plan) to traditional Medicare, they can continue to receive their DMEPOS item only if all Medicare requirements for that item are met.

      If issuing a new item:

      • The supplier may pick up the item that was originally provided under the MA plan.
      • The supplier may then issue a new item.
      • To issue the new item, the supplier must get a new F2F visit and a new WOPD. See the applicable LCD and Policy Article  for additional documentation requirements.

      If the beneficiary is continuing to use the same item:

      • The original WOPD and F2F must meet all Medicare coverage rules for that item (based on the applicable LCD/NCD). See the applicable LCD and Policy Article  for any additional documentation requirements.
      • A new F2F and WOPD is not required if those original documents already meet Medicare’s requirements.
      • The F2F must have been completed within 6 months of the WOPD.
      • For proof of delivery requirements for equipment retained from a prior payer, see the Standard Documentation Requirements for All Claims Submitted to DME MACs (A55426)External Website.

      Originally published: 06.26.2026

Back to the Top of the Page Top

spacer

26 Century Blvd, Suite NT600, Nashville, TN 37214 © CGS Administrators, LLC. All Rights Reserved