New CMS Home Health Care Requirement for Physicians: Face to Face Encounter

4/5/11  New CMS Home Health Care Requirement for Physicians:  Face to Face Encounter

We are contacting you to inform you of a new requirement that will affect physicians that

order, and the patients that they refer, for Medicare home health services.

In accord with the Patient Protection Affordable Care Act, CMS issued a Final

Regulation that goes into effect April 1, 2011 (first published January 1, 2011) whereby

Medicare will pay for home health services only when a patient has had a face-to-face

encounter with the physician that certifies the home health plan of care in the 90 days

prior to, or 30 days of, the start of services. The primary reason for home health services

must be addressed during this encounter.

Physicians that work in collaboration with a nurse practitioner or a clinical nurse

specialist, or supervise a physician’s assistant, the face-to-face encounter may be carried

out by that non-physician practitioner who must have documented their clinical findings

and communicated those finding to you. However, only a physician may order home

health services, certify that a face-to-face encounter occurred, and certify that other

eligibility criteria are met (medical necessity and homebound status).

**ALL NP's:  Now is the time to write those letters to your legislators, and help us fix this rule.