New Face to Face Meeting Requirements for patients receiving Medicare, Home Care or Hospice
New Face to Face Meeting Requirements for patients receiving Medicare, Home Care or Hospice
By Babette B. Bach Esquire, Sarasota, FL
A requirement that health care providers have a face-to-face meeting with patients was added as a Medicare payment requirement for home health and hospice care by the Affordable Care Act (ACA). Implementation of the requirement was effective April 1st 2011.The Face-to-Face requirement is intended to be a tool for reducing fraud and abuse by assuring that physicians or other healthcare providers have actually met with potential home health patients to determine their specific care needs.
The specifics of the Face-to-Face requirement for home health care are included in CMS regulations that were issued on November 17, 2010. The regulations establish that a face-to-face encounter must have “occurred no more than 90 days prior to the home health start of care date or within 30 days of the start of the home health care by including the date of the encounter.” The certification of the need for home health care must include an explanation as to why the physician’s clinical findings support the need for home health care, including that the patient is homebound and the need for either intermittent skilled nursing services or therapy. Regulations provide that a face-to-face encounter can be by tele-health as provided in the Social Security Act.
If the face-to-face encounter occurred within 90 days of the start of care, but was not related to the primary reason that the patient requires home health services, or if the patient has not seen the certifying practitioner within the 90 days, the practitioner must have a face-to-face encounter with the patient within 30 days of the start of the home health care.
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Babette B. Bach, Esquire, Board Certified Elder Law
Bach & Jacobs, P.A.
240 S. Pineapple Avenue, Suite 700
Sarasota, FL 34236
941-906-1231
941-954-1185 facsimile
