CMS Reverses Its Position on the F2F Medicare Advantage (MA) plans

Face to Face Encounter Update.

The National Association for Home Care and Hospice (NAHC) recently published an article updating its members on CMS’ decision to reverse it’s position on the face-to-face (F2F) encounter requirements. Below is the article from NAHC in its entirety.

NAHC Gains Reversal of Medicare Advantage (MA) Face-to-Face Encounter Policy

The Centers for Medicare & Medicaid Services (CMS) informed the National Association for Home Care & Hospice (NAHC) today that they are reversing their position on the face-to-face encounter requirement for members who receive home health services.

CMS, in its final call letter for the 2015 rates for Medicare Advantage (MA) plans, “clarified” that the MA plans would apply the same certification requirements as fee-for-service (FFS) Medicare to plan members who receive home health services. This directive would also require that the plans apply the face-to-face requirement. NAHC had serious concerns with this directive and took them to officials at CMS. NAHC questioned the rationale behind the requirement, given that MA plans have a preauthorization process that would negate the need to follow Medicare FFS certification requirements. NAHC also expressed its interpretation of the regulations to require that the MA plans offer the same scope of benefits to their members as Medicare but need not apply the same certification criteria as Medicare. To view a recent NAHC Report article on MA plans, click here.

CMS shared the following memorandum that was issued to the Medicare Advantage plans on June 11, 2014.

This memorandum is to correct the Final Call Letter of April 7, 2014 regarding Medicare Advantage organization’s (MAO’s) certification of enrollees for home health services. We are clarifying that an MAO’s authorization for home health services may substitute for the Original Medicare face-to-face certification requirement for the authorization of home health care services.

In certain circumstances, MAOs are not required to follow Original Medicare documentation requirements for the provision of Medicare covered services, but may substitute methods they deem appropriate for ensuring that the services provided are medically necessary, so long as they are not more restrictive than the coverage standards that apply in Original Medicare.