Two Updates for Home Health Care
Proper Certification Required for F2F Encounters
In the MLN Connects for March 2nd, there was a reminder of the requirement for physicians or non-physician practitioners to have face-to-face (F2F) encounters with beneficiaries before they certify eligibility for the home health benefit. One aspect is for the certifying physician to certify (attest) that the face-to-face encounter occurred and document the date of the encounter. For medical review purposes, Medicare requires documentation in the certifying physician’s medical records and/or the acute/post-acute care facility’s medical records to be used as the basis for certification of patient eligibility. This documentation must include the clinical note or discharge summary for the face-to-face encounter.
Many members have had their home health claims payment denied as a result of this requirement not being understood or adhered to by physicians or non-physician practitioners.
A similar regulation is scheduled to take place in July for Medicaid patients; this will require physicians to document F2F encounters for the authorization of home health services within certain timeframes.
Below are helpful resources and previous MLN articles on the Medicare F2F:
- CY 2015 Home Health Prospective Payment System Final Rule
- Medicare Benefit Policy Manual, Chapter 7, Section 30.5.1
- National Provider Call: Certifying Patients for the Medicare Home Health Benefit
- Certifying Patients for the Medicare Home Health Benefit
- Manual Updates to Clarify Requirements for Physician Certification and Recertification of Patient Eligibility for Home Health Services
Home Health Care Planning Improvement Act (S.445) Reintroduced
U.S. Senators Susan Collins (R-ME), the Chair of the Senate Aging Committee, and Ben Cardin (D-MD) have reintroduced the Home Health Care Planning Improvement Act (S.445). The bill will improve the access Medicare beneficiaries have to home health care by allowing physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse midwives to order home health services, all of which are playing increasingly important roles in the delivery of health care, particularly in rural and underserved areas of our nation.
Under current law, only physicians are allowed to certify or initiate home health care for Medicare patients, even though they may not be as familiar with the patient’s case as the non-physician provider.
The Home Health Care Planning Improvement Act removes the needless delays in getting Medicare patients the home health care they need simply because a physician is not available to sign the form required by law.
We have supported this bill, as has LeadingAge National.
Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871