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:
- 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?
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