Nearly 4.5 Million Medicare Beneficiaries Require Face-to-face Meetings

By Author: Ruskin Booth
Total Articles: 14
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Beginning January 1, 2011, home health and hospice patients will need to follow a new federal regulation issued by the Centers for Medicare and Medicaid Services (CMS) which says they must have a face-to-face meeting with a physician or nurse practitioner to receive services under Medicare.

“There are valid reasons for the implementation of this new rule,” notes Alan Weinstock, an insurance broker at MedicareSupplementPlans.com. “Physician involvement in care planning and authorization maintains benefit integrity.”

However, the National Association for Home Care & Hospice (NAHC) has encouraged CMS to review the implementation process to limit the possibility of disruptions in access to home health and hospice care. This is especially important because many of the people affected and some of the doctors aren’t even familiar with the new rule.

New CMS Face-to-Face Rule for Home Health

In July of this year, the CMS published the 2011 Proposed Rule for home health and hospice in the Federal Register. This included new requirements for face-to-face encounters with physicians or non-physician ...
... practitioners with regard to certification for home health patients and recertification for hospice patients.

The mandate for face-to-face encounters for home health patients goes into effect January 1, 2011 and is for initial certification of home health patients. It may take place in person or via tele-health. It can be performed by a physician, nurse practitioner, clinical nurse specialist working in collaboration with a physician, certified nurse-midwife or physician assistant under the supervision of a physician. Non-physician practitioners cannot be owners of the home health agency.

Non-physician practitioners must notify a physician of their findings so that the doctor can document the encounter and certify the patient’s eligibility for Medicare. The face-to-face must take place no more than 30 days prior to the start of home health care. If the Medicare beneficiaries condition changes and the reason for the face-to-face is not the reason for home health care, another face-to-face would be required.

New CMS Face-to-Face Rule for Hospice

Hospice patients being certified for a stay in excess of 180 days require a face-to-face encounter as well. A hospice physician or nurse practitioner must complete the face-to-face encounter prior to certification of the first 60-day hospice period, which occurs after two 90-day benefit periods.

The visit is to verify the patient’s continued eligibility for the hospice benefit. It must take place no more than 15 days prior to the 180-day recertification period and for each subsequent recertification.

The Patient Protection and Affordable Care Act mandated that a physician face-to-face encounter occur as a condition for payment for fee-for-service Medicare home health. CMS’ final rule updating the home health prospective payment system for 2011 included language to implement this section of the law.

The concern of the National Association for Home Care & Hospice (NAHC) is that affected patients need to continue to remain “independent and happy in the comfort of their homes.” Medicare shouldn’t jeopardize this without ensuring sufficient time to understand and test the new rule.

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