Home Health & Hospice Week

The face to face encounter final rule affirms that non-physician practitioners can perform the FFE visit, but they can't certify the patient for home care or sign the plan of care.

And like referring physicians, the NPPs performing FFEs cannot work for the home health agency,the rule clarifies. "Given the HH program integrity concerns in certain pockets of the country  urrounding the certification of HH eligibility, it is imperative that NPPs be subject to the same financial limitations with the HHA as currently apply to the certifying physician," the Centers for Medicare & Medicaid Services concludes in the rule.

The Affordable Care Act describes NPPs who may perform this FFE as a nurse practitioner or clinical nurse specialist who is working in collaboration with the physician, a certified nurse-midwife, or a physician assistant under the supervision of the physician, CMS says. "If a NPP performed the encounter, the NPP would communicate the patient's clinical information obtained during the encounter to the certifying physician," the rule adds.

Remember: The ACA FFE provision "does not amend the statutory requirement that a physician must certify a patient's eligibility for Medicare's HH benefit," CMS says in the rule.