With misinformation and uncertainty swirling around the new Physician Face-to-Face Requirements (F2F), the Home Care Alliance has released notices for hospitals and physicians as a guide for both home health agencies and their partners to utilize in understanding the impending changes.
As reported in HCA newsletters and alerts, CMS hosted its first (and only) educational forum on the new changes to the Face-to-Face physician encounter requirement for Medicare home health coverage on December 16. Given the lateness of the guidance, the effective date of January 1, 2015, and the many still unanswered questions, the Home Care Alliance of MA, the National Association for Home Care and Hospice, and others have asked CMS to phase-in enforcement of the requirements to allow time for home health agencies, physicians and hospitals to be educated about the new rules. CMS has not yet responded to that request.
In an effort to counter some misinformation circulating that the F2F requirement has been repealed, the Alliance has released the notices for agencies to use with their individual partners in the provider community. The Alliance is also working with the MA Medical Society and the MA Hospital Association on efforts to educate physicians and hospitals about the changes. We have encouraged MMS and MHA to inform hospitals and doctors that:
• the F2F encounter requirement is still in place for Medicare patients in need of home health services.
• the F2F encounter still MUST be documented, signed and dated by an MD, along with the documentation of the patient’s need for skilled care, homebound status and plan of care.
• home health agencies will work with our hospital and physician partners to understand the requirements once CMS clarifies the rule and begins educational sessions for all providers.
Clearly, there are still issues that need to be clarified around the hospitalist as the certifying physician.
HCA will continue to push for more guidance from CMS on this, as well as more physician and hospital education from CMS.
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