CMS Implements “Face to Face” Rule for Patients’ Receiving Home Health Services
One of the many “anti-fraud” provisions recently implemented by CMS was a requirement that certifying physicians have face-to-face contact with a patient for whom they are certifying homebound status or terminal illness.
A new Medicare home health law goes into effect on January 1st that affirms the role of the physician as the person who orders home health care based on personal examination of the patient. Effective in January 2011, a physician who certifies a patient as eligible for Medicare home health services must see the patient. The law also allows the requirement to be satisfied if a non-physician practitioner (NPP) sees the patient, when the NPP is working for or in collaboration with the physician.
As part of the certification form itself, or as an addendum to it, the physician must document that the physician or NPP saw the patient, and document how the patient’s clinical condition supports a homebound status and need for skilled services. The face-to-face encounter must occur within the 90 days prior to the start of home health care, or within the 30 days after the start of care. While the long-standing requirement for physicians to order and certify the need for home health remains unchanged, this new requirement assures that the physician’s order is based on current knowledge of the patient’s condition.
A more detailed announcement on this subject will be available within the next few days, on the home health agency website at: http://www.cms.gov/center/hha.asp, under the Spotlight section. Questions and answers regarding this requirement will be available the week of December 13th via Medicare’s home health agency website, http://www.cms.gov/center/hha.asp.