New Home Health Requirements Effective Jan. 1, 2015

The 2015 Home Care Prospective Payment Final Rule (effective January 1, 2015), relaxes the face-to-face encounter regulations as set forth by the Patient Protection and Affordable Care Act (“PPACA”).

During an open door forum held on December 16, 2014, CMS announced that it modified documentation requirements “in an effort to simplify the face-to-face encounter regulations, reduce burden for home health agencies (“HHAs”) and physicians, and to mitigate instances where physicians and HHAs unintentionally fail to comply with certification requirements.”

Specifically, the Final rule reformed the current face-to-face encounter regulations with 3 key changes:

• First, CMS eliminated the current narrative requirement with the exception of when a physician orders home care solely for skilled nursing visits for management and evaluation of the patient’s care plan. It is important to note, however, the certifying physician is still required to certify that a face-to-face physician encounter occurred, that the encounter was related to the primary reason for home health services, and the date of encounter must be documented.

• Second, CMS finalized that if an HHA claim is denied, the corresponding physician claim for certifying or re-certifying the beneficiary’s eligibility for Medicare-covered home health services is considered non-covered as well because a respective claim for Medicare-covered home health services no longer exists.

• Third, CMS clarified that face-to-face encounters are required for certifications, rather than initial episodes, and that certification will be considered to be anytime a new assessment is completed to initiate care.

Additionally, CMS eliminated the requirement that home health therapy reassessments be performed at the 13th and 19th visits. Effective January 1, 2015, a qualified therapist must performed a reassessment every 30 calendar days. Notably, the Final Rule provides therapists with flexibility with respect to the timing of the assessment.

The full text version of the Final Rule is available here.

For more information, or for questions related to home health services, please contact Abby Pendleton, Esq. or Jessica Gustafson, Esq. at (248) 996-8510 or via e-mail at or

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