Home Health & Hospice

CMS Issues Guidance Regarding Face-to-Face Physician Encounters

Homecare Insider, December 14, 2011

The Centers for Medicare and Medicaid Services (CMS) contractors have been denying payment for homecare patients, following an acute or post-acute stay, in the following circumstances:

  • The home health agency uses a single form (i.e., 485) for the plan of care and the certification with a single signature by the community physician who assumes oversight of the patient’s home healthcare
  • The physician who cared for the patient in the acute or post-acute setting is the certifying physician and has provided and signed attached documentation of the face-to-face encounter
  • Failure of the acute or post-acute physician to identify the community physician who will assume care for the patient
 On December 8, 2011, CMS issued the following guidance in regard to the face-to-face physician encounter:
  • CMS does not require that a specific form be used for home health certification or plan of care and agencies who use the 485 (which contains only one physician signature line) may attach the face-to-face encounter documentation as an addendum.
  • For patients admitted to homecare following an acute or post-acute stay, one physician may sign the certification and face-to-face documentation while a different physician can sign the plan of care.
  • If the face-to-face encounter documentation and the CMS-485 form collectively satisfy all of the certification and plan of care content requirements as defined in Chapter 7 Section 30 of the Medicare Benefit Policy Manual, Medicare contractors shall accept a CMS-485 form signed by the community physician who assumes oversight of the patient’s home healthcare with an addendum containing the face-to-face encounter documentation requirements signed by a physician who cared for the patient in an acute or post-acute setting, to satisfy the certification, face-to-face encounter, and plan of care requirements. In this scenario, the certifying physician is the acute or post-acute physician, has initiated content on the CMS-485, and has completed and signed the face-to-face encounter documentation. The physician who signs the CMS-485 assumes care for the patient’s home healthcare.
  • CMS has not mandated the acute or post-acute physician to follow a specific documentation protocol to hand-off a patient to the community physician.
CMS has instructed contractors to reopen claims denied for the reasons above and perform a complete and full review. CMS has instructed contractors that if all content requirements of the certification and the face-to-face encounter are met, they are to accept a 485, signed by the community physician, with an addendum containing the face-to-face physician encounter documentation that meets the requirements, including that it is signed by the acute physician who cared for the patient in an acute or post-acute setting.