Home Health & Hospice

What are the three changes that CMS recently finalized to face-to-face requirements for episodes beginning on or after January 1, 2015?

Homecare Insider, November 24, 2014

CMS finalized three changes to the face-to-face encounter requirements for episodes beginning on or after January 1, 2015. 

First, CMS will eliminate the narrative requirement currently in regulation. The certifying physician would still be required to certify that a face-to-face patient encounter occurred and document the date of the encounter as part of the certification of eligibility. In place of the narrative, CMS will now require documentation in the certifying physician’s medical records to demonstrate evidence of a patient’s home health eligibility.
 
Second, CMS specifies that if a HHA claim is denied, the corresponding physician claim for certifying/re-certifying patient’s Medicare home health eligibility will also be denied.
 
Lastly, CMS clarifies that a face-to-face encounter will now be required for certifications, rather than initial episodes, and that a certification (not re-certification) is generally considered to occur any time a new start of care assessment is completed to initiate care.