Medicaid Patients Likely to Come Under Face-to-Face Rules
Posted On: September 27th, 2011
Former Vice President, Product Marketing and Strategy, McKesson (Retired)
While home health and hospice agencies are coming up to speed on face-to-face requirements for their Medicare populations, CMS has proposed similar rules for Medicaid patients and medical equipment.
The comment period for the proposal under the Affordable Care Act (ACA) has ended, and it’s unknown when CMS will rule. It wouldn’t surprise me if the agency determines the rule is needed, but it places yet another documentation burden on home health and hospice agencies.
Under current rules, the face-to-face visit for home health must occur no more than 90 days before services start or within 30 days after. The encounter must be related to the need for home health and can be performed by a physician or non-physician practitioner. However, a physician must certify the need.
For hospice, ACA requires that a hospice physician or nurse practitioner NP have a face-to-face encounter with every hospice patient to determine the continued eligibility of that patient prior to the 180th day recertification and prior to each subsequent recertification.
What’s still unclear is whether CMS also will mandate specific timing of patient evaluations during therapy, although that wouldn’t surprise me, either.
Under current guidelines on the Medicare side, CMS requires patient evaluations on the 13th and 19th visits, in addition to the regular evaluation every 30 days. Evaluation visits must be made by a qualified therapist, not an assistant. And if a patient is receiving multiple therapies (physical, occupational or speech/language), the patient must be evaluated on the 13th and 19th visits for each type of therapy — in addition to an overall evaluation every 30 days.
Agencies operating in rural areas as determined by the Core Based Statistical Area (CBSA) Code get more latitude on the visits. Evaluation by a qualified therapist must take place between the 11th and 13th visits and then again between the 17th and 19th visits. In documented cases, agencies not considered rural also can utilize this rule.
As the delivery and payment of home health and hospice services continues to change—often quite dramatically—I can’t emphasize enough the importance of using technology, such as home health software to help home health documentation processes, maintain compliance and speed payment.