In the final rule for the 2015 home health prospective payment rate update, CMS revised the face-to-face (F2F) encounter requirements for physician certification for home health services. CMS has eliminated the narrative requirement but will still require that the F2F encounter occurred no more than 90 days prior to the start of home health care or within 30 days of the start of the home health care, and be performed by a physician or allowed non-physician practitioner (NPP).
CMS has also altered its medical review process for determining patient eligibility for home health services. CMS will now request the agency’s medical record when additional documentation is requested, and will also look for evidence that supports eligibility for home health services from the physician’s medical record.
CMS says it has eliminated the narrative requirement to simplify the F2F encounter regulations and reduce burdens for agencies and physicians. However, NAHC believes CMS’ revisions have only made the F2F requirements even more burdensome. NAHC is still in communication with CMS regarding F2F and how agencies are expected to operationalize the new aspects of the requirement. Based on information NAHC has gathered so far, NAHC offers a number of recommendations.
Click here to see the recommendations from NAHC.