CMS Issues Final Rule on Medicaid F2F for Home Health

The Centers for Medicare and Medicaid Services (CMS) has issued a final rule regarding a new physician face-to-face (F2F) documentation requirement for Medicaid home health services. This rule is slated to be effective July 1, 2016.

CMS has posted a Fact Sheet which states the intention of the new rule is to "promote program integrity and provide clear guidance on the parameters of the home health benefit in Medicaid which will enable beneficiaries to receive high quality care in the community, rather than rely on care in more expensive institutional settings.” It further clarifies the new rule aligns with Medicare to the greatest extent possible which will help to streamline beneficiaries’ access to needed items and maximize consistency in service delivery, as well as reduce administrative burden on the provider community. LeadingAge New York has advocated for a streamlined process to document the F2F Medicare requirement so as to reduce the “administrative burden.” This new Medicaid rule may complicate an already burdensome process.  

The new rule requires physicians to document the F2F encounters with Medicaid beneficiaries for the authorization of home health services within certain timeframes. In addition, for medical supplies, equipment, and appliances, physicians or certain authorized non-physician practitioners (NPPs) must document the occurrence of the F2F encounter within reasonable timeframes. This process can include the use of telehealth. The rule may negatively impact doctors ordering home care for Medicaid patients.

In the final rule it does not provide any detail on how the documentation should be captured. It does clarify under Medicaid, the patient does not have to meet the “homebound” standard to receive home health services.  

LeadingAge NY will continue to analyze the final rule and keep members posted on any new developments or clarifications.

Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871