Recent CMS Guidance Clarifies Physician Face-to-Face Home Health Certification Responsibilities

In MLN Matters Number MM9119 issued on April 10, 2015, CMS published manual updates to the physician certification and recertification requirements for home health care.  CMS stated that it is putting the following three changes to the face-to-face requirements in place:

  1. Elimination of the narrative requirement. The date and attestation of the physician’s face-to-face encounter will still be required and there must be supporting documentation in the physician’s or post-acute provider’s medical records.
  2. If an HHA claim is denied the corresponding physician claim for certification or recertification will also be denied.
  3. CMS also clarified that a face-to-face encounter is required for certifications rather than initial episodes; and that a certification (rather than recertification) is needed any time a new start of care assessment is completed to initiate care.

CMS is implementing these changes to the face-to-face encounter requirements for home health episodes beginning on or after January 1, 2015.

In Transmittal 587, dated April 17, 2015, CMS added language to the Program Integrity Manual clarifying that physicians or post-acute providers who do not retain the documentation necessary to support the home health certification (as well as DMEPOS, clinical laboratory, and imaging services) or who do not provide it to CMS as requested may have their enrollment revoked.

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