CMS Posts New Q&A guidance on Face-to-Face Encounters

As of this past week, the Centers for Medicare and Medicaid Services posted new Questions and Answers regarding the physician face-to-face encounter requirement.

The CMS site with all Q&A’s on the rule, which will be enforced beginning April 1, 2011, is available here, and some of the newest questions are listed below:

• What happens if the certification isn’t documented before a patient is discharged?

• Can an HHA obtain and record verbal orders regarding the required encounter information, which are then sent to the physician for signature?

• Since the HHABN Option Box 1 does not apply, do Option Box 2 (discontinue services for agency business reasons) or Option Box 3 (no physician orders) apply?

• Will subsequent episodes be covered if face-to-face requirements are not met timely during the first episode?

• Can a physician certify a patient’s eligibility and document the face-to-face encounter based on information received from another physician who recently saw the patient, such as the patient’s attending physician during an acute stay?

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