Home Health & Hospice Week

Home health agencies are headed for a spot between a rock and a hard place if the proposed rule on physician face-to-face encounters becomes final as is.

The rule fails to make clear what happens if the patient can't get in to see the physician in the required timeframe (see related story, this page). The Centers for Medicare & Medicaid Services does say in the proposed rule that "if the patient's certifying physician did not document that a face-to-face encounter occurred ... the services would not qualify for payment under the Medicare program."

But consultant Pam Warmack with Clinic Connections in Ruston, La. wonders if that means that agencies have to discharge patients if they don't make the two-week cut-off for the visit.  Despite what CMS believes, the home care patients need the visits," she stresses. "Some are receiving wound care, IV therapy, injections, chemotherapy," etc.

"What will agencies be able to do if the patient does not see the physician?" Judy Adams with Chapel Hill, N.C.-based Adams Home Care Consulting wants to know.

The cumulative effect of the new rule's difficulties is likely to be reduced access to home care services, Adams worries. And that will mean a shrinking census for many agencies.

Small providers will especially feel the provision's financial impact, Warmack predicts. "When you add the loss of admissions and loss of billing for services already provided to the other cuts in the proposed rules, it is obvious that many ... providers will struggle to stay in business," Warmack says.

Warning: "Many homebound home health patients could be deprived of necessary home health services if the pre-certification timeframe is too limiting," the National Association for Home Care  & Hospice says. "Unnecessarily stringent face-to-face requirements that impede access to home health services will result in prolonged hospital stays, increased transfers to post-acute facilities, and increased avoidable re-hospitalizations."