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February/March 2011
News For You

Face-to-Face Encounter: A New Home Care Requirement

In accordance with the Affordable Care Act, the Centers for Medicare and Medicaid Services (CMS) issued a final rule, effective on January 1, 2011, and enforced starting April 1, 2011, that mandates, as a condition of payment, that the certifying physician document that he or she had a face-to-face (F2F) encounter with the patient prior to certifying the patient’s eligibility for home care.

While the longstanding requirement that physicians order and certify the need for home healthcare remains unchanged, this new requirement assures that the physician’s order is based on current knowledge of the patient’s condition.

To help accommodate physician practice, the rule also allows hospitalists to certify patient eligibility, and establish and sign the F2F encounter. In addition, the rule permits non-physician practitioners (NPP) to see the patient and document their findings, when working for or in collaboration with the physician.

The F2F encounter must occur 90 days prior to the start of home care or within 30 days after the start of care. Home care agencies will not be reimbursed for their services if the guidelines for the F2F encounter are not met.

The F2F encounter must be documented on the home health plan of care or an addendum to that plan of care. Documentation of the F2F must be completed by the patient’s physician or hospitalist and must include:

  • Date of the F2F encounter (when physician or allowed NPP saw the patient)
  • Indication that the encounter was related to the primary reason for home care
  • An explanation of how the clinical findings of the F2F support the need for homebound status, and the need for skilled nursing or therapy services
  • Physician’s signature, and documentation of the DATE of the physician’s signature

“We want to assure you that those patients who would benefit from home health services will not be denied the care they need and deserve,” says Judie Truelsen, director, NCH Home Care. “We will do all we can to assist you and your associates with this new process.”

You can learn more about F2F requirement by reviewing the CMS’ FAQs at http://www.cms.gov/center/hha.asp, and education via YouTube.

Questions? Please contact Judie Truelsen at 847.618.7860.

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Last Updated 04/10/2009