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who needs face to face requirement for straight medicare only

by Mrs. Ilene Breitenberg DDS Published 2 years ago Updated 1 year ago

• A Physician, Physician’s Assistant (PA), Nurse Practition- er (NP), or Clinical Nurse Specialist (CNS) must have a Face-to-Face (F2F) evaluation with the beneficiary prior to the written DME order and document the Face-to- Face evaluation in the patient’s medical records.

Full Answer

What is the Medicare “face to face” home health requirement?

The Medicare “Face-to-Face” Home Health requirement is a hot topic of conversation within the industry, as it is a regulation that directly affects physicians and those in the medical field, home care and hospice agencies and those requesting home health Medicare benefits and reimbursement. What is the Medicare Face-to-Face Home Health Requirement?

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.

What are the requirements for face-to-face meeting with a physician?

The Affordable Care Act (ACA) added a requirement that prior to such certification the physician must document that the patient had a face-to-face encounter with an allowed physician or non-physician practitioner (NPP) within a reasonable timeframe as established by the Secretary of the U.S. Department of Health and Human Services. [2]

Is Medicare requirement causing unrest in home care industry?

A controversial Medicare requirement continues to cause unrest in the Home Care industry and has recently been the focus of a federal lawsuit.

Does Medicare require face to face?

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.

What is Medicare face to face?

In addition to allowing NPPs to conduct the face-to-face encounter, Medicare allows a physician who attended to the patient in an acute or post-acute setting, but does not follow patient in the community (such as a hospitalist) to certify the need for home health care based on their contact with the patient, and ...

What is required for a face to face?

The initial (Start of Care) certification must include documentation that an allowed physician or non-physician practitioner (NPP) had a face-to-face (FTF) encounter with the patient. The FTF encounter must be related to the primary reason for the home care admission. This requirement is a condition of payment.

What needs to be on a WOPD?

The prescription (order) for the DME must meet all requirements for a WOPD and include all of the items below: Beneficiary's name, Physician's Name. Date of the order and the start date, if start date is different from the date of the order.

Can a nurse practitioner do a face to face encounter?

Q: Who qualifies as a non-physician practitioner (NPP)? A NPP may perform qualifying face to face encounter, must document and communicate findings from their counter to the qualified certifying physician.

How long is 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 are face to face notes?

The face to face notes must include the following: Doctor's Progress Notes; from a visit or exam related to the treatment of a communication disorder. The notes should give a brief background of the patient, his/her communication disorder and recommending the Speech Generating Device.

What is a face to face sheet?

Free Face Sheet Template for Communicating With Doctors. By Gilbert Guide. A face sheet is a document that gives a patient's information at a quick glance. Face sheets can include contact details, a brief medical history and the patient's level of functioning, along with patient preferences and wishes.

What is the meaning of the idiom face to face?

Definition of face-to-face 1 : within each other's sight or presence met and talked face-to-face a face-to-face consultation. 2 : in or into direct contact or confrontation came face-to-face with the problem.

What is a Medicare WOPD?

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.

What are the documentation guidelines for DME?

Documentation, including pertinent portions of the beneficiary's medical records (e.g., history, physical examination, diagnostic tests, summary of findings, diagnoses, treatment plans), supporting the medical necessity of the prescribed PMD must be furnished to the supplier within 45 days of the examination.

What is a practitioner's standard written order?

Standard Written Order (SWO) All claims for items billed to Medicare require a written order/prescription from the treating practitioner as a condition for payment. This written order/prescription is referred to as the Standard Written Order (SWO). / Beneficiary's name or Medicare Beneficiary Identifier (MBI)

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 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.

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.

Who can perform a face to face encounter?

Who Can Perform a Face-to-Face Encounter? A F2F encounter may be performed by the certifying physician. It may also be performed by a physician who cared for the patient in an acute or post-acute facility directly prior to the home health admission, and who has privileges at the facility.

What is a condition of payment for Medicare home health benefits?

As a condition of payment for Medicare home health benefits, a physician must certify that a patient is confined to the home, needs skilled services, receiving the services under a plan of care established and periodically reviewed by a physician, and under the care of the physician. [1] The Affordable Care Act (ACA) added a requirement that prior to such certification the physician must document that the patient had a face-to-face encounter with an allowed physician or non-physician practitioner (NPP) within a reasonable timeframe as established by the Secretary of the U.S. Department of Health and Human Services. [2]

How often do you have to recertify for home health?

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. [13] . Medicare does not limit the number of continuous episodes for patients who continue to be eligible for the home health benefit.

When is a F2F encounter required?

As a general rule, a F2F encounter is required any time a Start of Care OASIS (Outcome and Assessment Information Set) is completed by the HHA to initiate services for a beneficiary. Thus, a F2F encounter is necessary for a patient’s initial certification for home health services. [12]

Does Medicare require a new F2F encounter?

Recertifications do not require a new F2F encounter. It should be noted, though, that payment will not be made for recertification episodes if F2F requirements are not met for the initial certification episode.

Do you need a new F2F encounter?

Typically, if a home health patient is admitted to the hospital but returns home to resume home health services during the same 60-day episode of care, a new F2F encounter is not required. However, if the patient is admitted to an inpatient facility and returns to home care after the episode ended, then a new F2F encounter is required ...

Is home health certification required?

The regulation has been fully implemented and providers are complying with the requirements. Certification for home health is already required by physicians. The face-to-face encounter for home health care can be included in the certification documentation or on a separate form.

Does Medicare require face to face encounter?

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-physi cian practitioner working with the physician, has seen the patient.

What is the face to face requirement for Medicare?

The Medicare Face-to-Face Home Health requirement, a regulation in accordance with the Affordable Care Act, requires an in-person physician’s visit in order to certify a patient’s home health benefit, according to cms.gov. This means that under the law, a physician must assess and document a patient’s condition and provide a brief narrative verifying their eligibility for the home health Medicare benefit. While revisions to this requirement were later made, some important initial provisions of this requirement are as follows: 1 A physician or allowed non-physician practitioner (NPP) must document having met with a patient face-to-face and certify them for Medicare home health benefits 2 The certification for service eligibility must be related to physician’s assessment of a patient’s clinical condition 3 Patients beginning care on or after January 1, 2011 require this documentation on their certification 4 Visit must occur within 90 days prior to, or within 30 days after beginning of home health care

Who must document having met with a patient face-to-face and certify them for Medicare home health benefits?

While revisions to this requirement were later made, some important initial provisions of this requirement are as follows: A physician or allowed non-physician practitioner (NPP) must document having met with a patient face-to-face and certify them for Medicare home health benefits.

What is face to face home health?

What is the Medicare Face-to-Face Home Health Requirement? The Medicare Face-to-Face Home Health requirement, a regulation in accordance with the Affordable Care Act, requires an in-person physician’s visit in order to certify a patient’s home health benefit, according to cms.gov.

Who maintains the written order/prescription?

A supplier must maintain the written order/prescription and the supporting documentation provided by the treating practitioner and make them available to CMS and its agents upon request. CMS may suspend the face-to-face encounter and written order prior to delivery requirements generally, or for a particular item or items, ...

What is a standardized DMEPOS order?

Standardized DMEPOS Written Order/Prescription. Any Medicare provider or supplier that writes DMEPOS orders or prescriptions will now use a standard set of elements that will be applicable to all DMEPOS items. The treating practitioner must submit the complete written order to the supplier prior to submitting a claim for Medicare payment.

Can CMS suspend a face to face meeting?

CMS may suspend the face-to-face encounter and written order prior to delivery requirements generally, or for a particular item or items, at any time and without creating a new rule, except for those items included on the Master List due to statutory mandate.

Do PMDs require face to face encounter?

Some items (such as PMDs) have statutorily imposed requirements. For items that do not have statutory requirements, a face-to-face encounter and written order is required only if the item is selected from the Master List and placed on the Required Face-to-Face and Written Order Prior to Delivery List. Items selected for the list will be published ...

How many licensed counselors are there in Medicare?

By passing the Mental Health Access Improvement Act, and allowing the well over 100,000 licensed counselors and marriage and family therapists to render services to Medicare beneficiaries, legislators have an opportunity to create significant gains in access to mental health care for millions of Americans.

Who is addressed as the honorable?

Be sure you use the correct address and salutation. All Presidential appointees and Federal- and State-elected officials are addressed as The Honorable. (b) All Mayors are addressed as The Honorable. However, as a general rule, county and city officials are not addressed as The Honorable.

Does Medicare require telehealth visits?

New Medicare Law Requires In-Person Visit for Telehealth Coverage. In December 2020, the Consolidated Appropriations Act of 2020 , section 123 includes language that requires behavioral health providers to have seen their client in person during the prior six months before a telehealth visit will be covered by Medicare.

Can a counselor be billed by Medicare?

Under the current Medicare law, counselors continue to be excluded from being reimbursed by Medicare for providing counseling services. Only psychiatrists, psychologists, clinical social workers, and psychiatric nurses are allowed to bill Medicare for counseling services provided to Medicare beneficiaries. Although many attempts to pass Medicare laws to include counselors as Medicare providers have been attempted over the years, none has been successful. On January 21, 2021, however, Rep. Mike Thompson (CA- 05) and Rep. John Kato (NY-24) reintroduced the Mental Health Access Improvement Act, a bipartisan bill that would allow counselors and marriage and family therapists to become Medicare providers. See

Standardized DMEPOS Written Order/Prescription

Consolidated DMEPOS Lists

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

Written Order Prior to Delivery (WOPD) Requirements

Face-To-Face Encounter Requirements Applicable to Certain DMEPOS Items

  1. 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 d...
  2. The encounter must be used to gather subjective and objective information associated with diagnosing, treating, or managing a clinical condition for which the DMEPOS is ordered.
  1. 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 d...
  2. The encounter must be used to gather subjective and objective information associated with diagnosing, treating, or managing a clinical condition for which the DMEPOS is ordered.
  3. The face-to-face encounter must be documented in the pertinent portion of the medical record (for example, history, physical examination, diagnostic tests, summary of findings, progress notes, trea...
  4. If the encounter is performed via telehealth, the requirements for telehealth services and payment for telehealth servicesmust be met.

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