Home Health & Hospice Week

Lighten your face-to-face load where you can.

The face-to-face physician encounter requirement is a heavy burden on home health agencies, but there are a few spots where you can make it a bit easier — if you know the ropes.

Question: One home health agency asked HHH Medicare Administrative Contractor Palmetto GBA whether the certifying physician must cosign a F2F encounter performed by a Non-Physician Practitioner (NPP). “We thought even though the encounter was performed by the NPP, it would have to be cosigned by the physician,” the agency said in a recent question-and-answer set released based on Palmetto’s March 16 Ask the Contractor Teleconference focusing on F2F and Probe & Educate issues.

Answer: “There is nothing in the guidelines issued by [the Centers for Medicare & Medicaid Services] that says that has to happen,” Palmetto replies. “As far as CMS is concerned, the physician doesn’t need to sign following the allowed NPP.”

Exception: However, “[y]ou may have rules in the conditions of participation or your state rulings that say you do need to have the physician sign following an allowed NPP,” the MAC continues. “If you have stricter regulations from someone else you need to follow the strictest of the regulations.”

And don’t forget that “[t]he certifying physician signs the certification stating the patient meets the Medicare requirements for service,” Palmetto adds.