CMS Updates Face-to-Face Q&As

The Centers for Medicare & Medicaid Services (CMS) updated home health face to face encounter Q&As on Feb. 4th. The following Q&As were added to the CMS web site at the following link for a total of 25 home health-related face-to-face Q&As: Home Health Face-to-Face Encounter FAQs.

  1. Answer ID 10414: Will Medicare requirements be met if hospital discharge planners (physician’s nurse or social worker) completes the face-to-face encounter document based on information from the patient’s medical record and physician’s review and signature?
    Answer: If the physician’s support personnel extract information concerning the physician/patient encounter from the physician’s own medical record entries, and those medical record entries include how the patient’s clinical condition (as seen during the encounter) supports homebound status and the need for skilled services, the above scenario is acceptable.
  2. Answer ID 10412: When will medical reviewers and other CMS oversight begin to deny claims if the face-to-face requirement has not been met?
    Answer: CMS wants to ensure there is no interruption in access to care for Medicare beneficiaries. Although many home health agencies and physicians are aware of and are able to comply with this policy, CMS is concerned that some home health agencies and physicians may need additional time to establish operational protocols necessary to comply with this new law. As such, CMS expects that during the first quarter of CY 2011, home health agencies and physicians who order home health services will collaborate and establish internal processes to ensure compliance. Beginning with the second quarter of CY2011, home health agencies will have fully established such internal processes and CMS will expect appropriate documentation of the encounter.
  3. Answer ID 10410: Can a physician performing the face-to-face encounter bill Medicare for the visit?
    Answer: The physician who documents the face-to-face encounter must be the certifying physician. Per section 424.22(d), the certifying physician may not have a financial relationship as defined in 411.351 with the HHA to which he or she is referring patients. Similarly, a non-physician practitioner (NPP) performing the face-to-face encounter is subject to the same financial restrictions as the certifying physician.
  4. Answer ID 10413: What are the specific financial restrictions for physicians or NPPs performing the face-to-face?
    Answer: The financial restrictions and exemptions are consistent with the Stark Law.

One Response to “CMS Updates Face-to-Face Q&As”

  1. Kim Crawford Says:

    Can an Agency submit a RAP without a F2F document on file
    How will the F2F requirement be comminucated on the final claim?
    Will this be monitored through State Survey or ADR request?

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