CMS Finalizes F2F for Medicaid

Home Health Agencies Should Prepare for Compliance

CMS recently finalized the face-to-face encounter rule for Medicaid. While the effective date of the ruling is July 1, 2016, states will have until July 1, 2017 or July 1, 2018 to be in compliance. To ensure that states and providers are implementing the rule appropriately, CMS is delaying compliance for up to one year if a state’s legislature has met in that year, otherwise the delay will be two years.

The main components of the final rule are as follows:

  • For the initial ordering of home health services, the physician must document that a face-to-face encounter that is related to the primary reason the beneficiary requires home health services occurred no more than 90 days before or 30 days after the start of services.
  • For the initial ordering of certain medical equipment, the physician or authorized NPP must document that a face-to-face encounter that is related to the primary reason the beneficiary requires medical equipment occurred no more than six months prior to the start of services.
  • The face-to-face encounter for home health and medical equipment may be performed by the physician or certain authorized NPPs.
  • The role of the physician in ordering Medicaid home health services and medical equipment is maintained.
  • Clarifies the definition of medical supplies, equipment and appliances.

HEALTHCAREfirst customers currently have access to forms that can be used to document face-to-face physician encounters in their software. If any state Medicaid program announces additional requirements tied to this rule, HEALTHCAREfirst will update the system.

The full ruling can be viewed here: https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-01585.pdf

February 3, 2016

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