Home Health & Hospice Week

As you’re wrapping your head — and your organization — around the new face-to-face physician encounter rules, don’t forget to cover the F2F basics too. Remember, the F2F can be performed by the certifying physician; the physician who cared for the patient in an acute or post-acute care facility (from which the patient was directly admitted to home health); a nurse practitioner or a clinical nurse specialist who is working in collaboration with the certifying or acute/post-acute care physician; or a certified nurse midwife or physician assistant under the supervision of the certifying or acute/post-acute care physician.

However, “the face-to-face encounter cannot be performed by any physician or allowed NPP … who has a financial relationship with the HHA,” the Centers for Medicare & Medicaid Services noted in a December National Provider Call, “Certifying Patients for the Medicare Home Health Benefit.”

“It’s been our longstanding policy that records from providers with a financial interest in the claim outcome are not considered sufficient by themselves for the purpose of determining that the item or service is reasonable and necessary,” CMS’s Jill Nicolaisen said in the forum.