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when does face to face encounter for medicare patients have to be

by Prof. Afton Huel Published 2 years ago Updated 1 year ago
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The face-to-face encounter must occur within the 90 days prior to the start of home health care, or within the 30 days after the start of care

The encounter must occur within the 90 days prior to the start of care, or within the 30 days after the start of care. Documentation of such an encounter must be present on certifications for patients with starts of care on or after January 1, 2011.

Full Answer

What is a face-to-face encounter for Medicare home health services?

The Affordable Care Act (ACA) established a face-to-face encounter requirement for certification of eligibility for Medicare home health services, by requiring the certifying physician to document that he or she, or a non-physician practitioner working with the physician, has seen the patient.

When does the first face-to-face encounter with the patient take place?

The face-to-face encounter must occur within the 90 days prior to the start of home health care, or within the 30 days after the start of care

When did the face to face encounter become required for home health?

[2] Implementation of the face-to-face (F2F) encounter requirement is effective for all home health claims with a start of care date on or after April 1, 2011. Who Can Perform a Face-to-Face Encounter? A F2F encounter may be performed by the certifying physician.

How long do you have to bill for face to face?

A: The encounter must occur no more than 90 days prior to the home health start of care date or within 30 days after the start of care. If a patient does not receive face to face encounter by day 30, coverage requirements are not met and episode cannot be billed.

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When should face to face encounter occur?

Q: What are the timeframe requirements? A: The encounter must occur no more than 90 days prior to the home health start of care date or within 30 days after the start of care. If a patient does not receive face to face encounter by day 30, coverage requirements are not met and episode cannot be billed.

What should CMS do to ensure that all patients that need a face to face encounter receive one?

We recommend that CMS (1) consider requiring a standardized form to ensure that physicians include all elements required for the face-to-face documentation, (2) develop a specific strategy to communicate directly with physicians about the face-to- face requirement, and (3) develop other oversight mechanisms for the ...

Can a nurse practitioner do a face to face encounter?

If you work in collaboration with a nurse practitioner or a clinical nurse specialist, or supervise a physician's assistant, the face-to-face encounter may be carried out by that non-physician practitioner who must have documented their clinical findings and communicated those findings to you.

What is a F2F encounter?

A F2F encounter must be performed by the certifying physician, a physician (with privileges) who cared for the patient in an acute or post-acute care facility from which the patient was directly admitted to home health, or allowed Non-Physician Practitioner (NPP)1 who does not have a financial relationship with the ...

How long is a f2f good for?

After an initial home health episode, recertification of the need for continued home care must be provided at least every 60 days, and must be signed and dated by the physician who reviews the plan of care.

What is Encounter date?

What is Encounter date in healthcare? Definition: The documented month, day, and year the patient arrived in the outpatient setting. Consider the outpatient encounter date as the earliest documented date the patient arrived in the applicable hospital outpatient setting.

Which of the following situations would require an oasis assessment?

Currently, OASIS requirements apply to all patients receiving skilled care reimbursed by Medicare, Medicaid, and Medicare or Medicaid managed care patients with the following exceptions: patients under the age of 18, patients receiving maternity services, patients receiving only chore or housekeeping services, and ...

Can nurse practitioners order home health in Florida?

Section 3708 of the CARES Act permanently authorizes nurse practitioners (NPs) to certify for Medicare and Medicaid home health care services in accordance with state law.

What should be included in a clinical summary?

Clinical Summary – An after-visit summary that provides a patient with relevant and actionable information and instructions containing in no particular order: • Patient name. Provider's name and office contact information. Date and location of the visit. Reason for the office visit.

What happens if a home health patient dies before the face-to-face encounter occurs?

If a home health patient dies shortly after admission before the face-to-face encounter occurs, if the contractor determines a good faith effort existed on the part of the HHA to facilitate/coordinate the encounter and if all other certification requirements are met, the certification is deemed to be complete.

What documentation must include the date when the physician or allowed NPP saw the patient?

The documentation must include the date when the physician or allowed NPP saw the patient, and a brief narrative composed by the certifying physician who describes how the patient’s clinical condition as seen during that encounter supports the patient’s homebound status and need for skilled services .

What is the FTF encounter?

The FTF encounter must be related to the primary reason for the home care admission. This requirement is a condition of payment. Without a complete initial certification, there cannot be subsequent episodes. Claims may be denied if the FTF documentation is not complete.

How long does it take for a FTF to occur?

The FTF encounter must occur within 90 days prior to the Start of Care (SOC) or 30 days after the SOC. The FTF documentation must show the FTF encounter occurred within this timeframe.

Who performs the FTF?

The FTF encounter must be performed by the certifying physician, a physician who cared for the patient in an acute or post-acute facility directly prior to being admitted to home health, and who had privileges at the facility, or a qualified non-physician practitioner (NPP) working in conjunction with the certifying physician. ...

Can a physician attest to a date of encounter?

Only the certifying physician can attest to the date of the encounter on either the certification, or a signed addendum to the certification.

What is face to face encounter?

It is important to understand that the Face-to-Face Encounter is a legislative mandate and condition for payment. With the January 1st deadline quickly approaching planning and implementation of a compliance plan for this new rule is key for preventing any reimbursement issues in the near future. Here are a few tips to assist your agency with complying with the new rule:

How long does a physician have to meet with a patient to qualify for home health benefits?

Physician’s or non-physicians encounters with a patient must be conducted within 90 days prior to or within 30 days of the initial start of care date for home healthcare patients. The goal for the implementation of this rule as noted in the final rule published on November 17, 2010 in the Federal Registry is an effort by the federal government to have greater physician accountability in certifying a patient’s eligibility and establishing a patient’s plan of care.

What is the Affordable Care Act?

The Affordable Care Act also allows the encounter to be satisfied through the use of tele-health services. Tele-health encounters are subject to the requirements in section 1834 (m) of the rule, which limits encounters to one of the specified types of originating sites.

Do you document a face to face encounter?

Documentation of the encounter is the most significant point of this new rule. As many clinicians are familiar with the saying “if you did not document it, you did not do it” this holds especially true in the case of the face-to-face encounter. Although non-physician practitioners are able to certify patients eligibility for the home health benefit the physician must document the encounter. The rule explicitly states that “the certifying physician must document the face-to-face encounter regardless of whether the physician himself or herself or one of the permitted NPPs perform the face-to-face encounter.”

Consolidated DMEPOS Lists

The Master List (PDF) is a library of all DMEPOS items posing vulnerabilities to the Trust Fund that may require providers/suppliers to comply with additional conditions related to payment requirements. From this list, items may be selected for one or both of the Required Lists:

Required Face-to-Face Encounter and Written Order Prior to Delivery List

Review contractors assess compliance with the face-to-face encounter and written order prior to delivery requirements. Some items (such as PMDs) have statutorily imposed requirements.

Written Order Prior to Delivery (WOPD) Requirements

For items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List, a complete order is required prior to the item’s delivery.

Face-to-Face Encounter requirements applicable to certain DMEPOS items

For all items requiring a face-to-face encounter, a practitioner visit is required within six months preceding the order. Note: face-to-face encounters for PMDs were previously required within 45 days preceding the written order.

Learn More

DMEPOS Written Order, Face-to-Face Encounter, and/or Prior Authorization Requirements (PDF): Learn more about the standard elements for a DMEPOS order and items potentially subject to face-to-face encounter and written order prior to delivery and/or prior authorization requirements.

How long does a physician have to see a patient after admission?

In situations when a physician/NPP orders home health care for the patient based on a new condition inevident during a visit within 90 days prior to start of care, the certifying physician/NPP must see the patient again within 30 days after admission.

Who can certify the need for home health care?

A physician, such as a hospitalist who tends to a patient in an acute or post-acute setting who does not follow the patient when discharged may still certify the need for home health care and establish and sign Plan of Care form 485.

Can a certifying physician dictate a home health encounter?

The certifying physician may choose to dictate the encounter. It also is acceptable for the physician/NPP to verbally communicate the encounter to the home health agency (HHA), where the HHA would then document the encounter as part of a certification form for the physician to sign.

How long does it take for a home health encounter to be billed?

A: The encounter must occur no more than 90 days prior to the home health start of care date or within 30 days after the start of care. If a patient does not receive face to face encounter by day 30, coverage requirements are not met and episode cannot be billed.

What is a physician support staff?

A: Physician support staff may assist the physician in drafting the narrative for the documentation of the encounter. Physician support staff are those staff who work with, or for the physician on a regular basis and, as part of their job duties, regularly perform documentation, take dictation from the physician and/or extract from the physician's medical records to support the physician in a variety of ways. CMS notes that HHA staff cannot assist the physician in drafting the narrative as this would violate the statutory requirement.

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