Home Health & Hospice Week

Get ready for Medicaid’s face-to-face physician encounter requirement to hit this summer. The Centers for Medicare & Medicaid Services issued a final Medicaid F2F rule in the Feb. 2 Federal Register. “The final rule aligns with Medicare timeframes for the face-to-face encounter for home health services and medical supplies, equipment, and appliances,” notes the National Association for Home Care & Hospice in its member newsletter.

Exception: CMS set a July 1, 2016 implementation date. But if states must make legislative changes to accommodate the rule, they have until as late as July 2018 to comply.

CMS responded to home care providers’ concerns that the F2F rule would implement a homebound requirement for Medicaid. CMS has revised regs “to codify our longstanding policy that home health services may not be subject to a requirement that the individual be homebound,” the agency confirms in the rule. “A homebound requirement is not permitted,” CMS clarifies.

Why? “While most of the Medicare/Medicaid rules are aligned, this is an area in which there is a statutory difference between the programs,” CMS explains. “As a result, the rules differ. Sections 1814(a) and 1835(a) of the Act impose the Medicare homebound requirement for home health services, but there is no parallel homebound requirement under Medicaid.”

States will also have some leeway in how the requirement is implemented, the rule indicates.

“We have attempted to permit maximum flexibility in how the statutory requirement can be met and believe that the requirement can be accommodated without significant additional burden,” CMS says.

Take action: NAHC “encourages agencies to work closely with their state Medicaid offices to ensure reasonable application of the final rule regarding the F2F encounter requirements,” the trade group says. In other words, to avoid the draconian physician documentation requirements hounding the Medicare F2F requirement (see story, p. 82).