Face-to-Face Encounter Requirement for Hospice and Home Health Providers Effective NOW

Effective April 1, 2011, hospice and home health providers will be required to comply with the face-to-face rule for purposes of verification of a patient’s eligibility for Medicare home health services and of recertification for Medicare hospice services. Enforcement of this requirement was delayed from January 1, 2011, in order to allow home health and hospice providers time to work out any systemic issues associated with implementation of the face-to-face visit requirement. According to CMS, “the face-to-face requirement ensures that the orders and certification for home health services are based on a physician’s current knowledge of the patient’s clinical condition.” These encounters must then be documented on patients’ certifications. Moreover, where the home health encounter must occur within the 90 days prior to the stat of care or within the 30 days after the start of care, the hospice encounter must occur prior to the patient’s 180th day recertification, and each subsequent recertification. The hospice encounter must occur no more than 30 calendar days prior to the start of the hospice patient’s third benefit period.

For more information, please contact Abby Pendleton, Esq. or Jessica L. Gustafson, Esq. at (248) 996-8510 or (212) 734-0128 or visit the Hospice specialty page on the HLP website.