Yes, this exception is open to any EP who meets both of these criteria (lack of face-to-face interactions and lack of follow-up with patients). Medicare considers the lack of face-to-face and needs for follow-up care to be situations where the EP has no or nearly no face-to-face patient interactions or need for follow-up care. The EP would need to demonstrate either a complete lack of face-to-face interaction and follow-up or those cases of face-to-face interaction and follow-up are extremely rare and not part of the normal scope of practice for that EP. EPs need to apply no later than July 1, 2014, to avoid the payment adjustment in 2015 although Medicare encourages EPs to apply well before the deadline.
