CMS Publishes Home Health Physician Targeted Face-to-Face Guidance

A Physician’s Guide to Medicare’s Home Health Certification.

For those of you who attended my regulatory update at the HEALTHCAREfirst Users Conference in San Antonio, one of the topics discussed were recent face to face guidance clarifications and CMS’ intention to issue additional clarifications in a MedLearn Matters article targeted to physicians.

CMS has now published this as, “A Physician’s Guide to Medicare’s Home Health Certification, including the Face-to-Face Encounter.”  We recommend making sure the physicians you work with have this guidance.

Some of the items discussed in the Medlearn Matters guide include:

  • Physician Home Health Certification Requirements remain the same.
  • Reminders regarding time frame for completion of the certification and certification content reminders.
  • Descriptions of physicians and NPPs who may perform a face-to-face encounter are now more detailed and are as follows:

Medicare-enrolled physicians who are also the certifying physician;
The following physicians are allowed to perform the face-to-face encounter and inform the certifying physician:

  • Physicians (Medicare-enrolled or otherwise) who cared for the patient in an acute or post-acute facility during a recent acute or post-acute stay and have privileges at the facility;
  • Because residents (Medicare-enrolled or otherwise) do not have privileges at acute or post-acute facilities, if they are performing the encounter and informing the certifying physician, they must inform the certifying physician under the supervision of their teaching physician who must have such privileges.

NPPs that may perform the face-to-face encounter include:

  • A nurse practitioner or clinical nurse specialist working in collaboration with the certifying physician in accordance with State law;
  • A certified nurse-midwife under the supervision of the certifying physician, as authorized by State law; and
  • A physician assistant under the supervision of the certifying physician.

NPPs are subject to the same financial restrictions with the home health agency as the certifying physician.

  • Details on documentation requirements including Face-to-face encounter documentation. It must be clearly titled, dated, include the date of the encounter and be signed by the certifying physician, whether as part of the certification form itself, or as an addendum. If the face-to-face documentation is co-located with the certification of eligibility, only one physician signature, from the certifying physician is required. However, if the face-to-face documentation is attached as an addendum to the certification (a separate document), the face-to-face documentation and certification each require a signature from the certifying physician.
  • Electronic signatures are still acceptable.

Full Medlearn Matters article can be located here.