Enforcement of the face-to-face encounter requirement from a recent CMS Final Rule will be delayed for three months thanks to a coordinated and effective advocacy effort.
Home Care Alliance has been informed that the Centers for Medicare and Medicaid Services (CMS) has sent instructions to its contractors advising them that home health agencies and hospices are to be allowed to use the first quarter of 2011 to implement procedures to meet face-to-face encounters requirements.
It is vitally important to note that providers should continue to implement face-to-face encounters as soon as possible. Doing so will enable the collection of information about provider and beneficiary problems and pitfalls related to this regulation that need to be addressed with CMS. According to NAHC, CMS has plans to begin meetings with home health and hospice representatives, and other stakeholders, early in January to answer remaining questions and resolve problems as they come to light.
According to VNAA, the 3-month transition period will not be extended and CMS called on national organizations to take action and to work with CMS during the transition period.
This delay represents a victory for home health and hospice and is a prime example of how advocacy is effective in making a difference. The member agencies of HCA joined others nationwide in a great effort and, together with other associations, were able to convince CMS that a delay was necessary. Massachusetts was also fortunate to have great support from the federal legislative delegation.
For the purpose of continuing with implementation, NAHC has outlined the requirements for physician signature and the regulatory basis as to why after January 1, 2011, date stamps will no longer be accepted if the physician does not sign AND date.
Details are available in the Medicare General Information, Eligibility and Entitlement Manual under section 30.1. That requirement is also addressed in this summary.
HCA will provide more information as it becomes available.
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