Medicare Compliance & Reimbursement

Physicians must see patient 30 days before or two weeks after start of care -- and sometimes more. Based on a provision in the Patient Protection and Affordable Care Act (PPACA), CMS has proposed requirements for physicians to have a face-to-face encounter with patients before certifying them for home care. Under the regulation in the July 23 Federal Register proposed rule for the 2011 home health prospective payment system, physicians or qualifying non-physician practitioners would have to see the patient 30 days before start of care or within two weeks after SOC. Qualifying NPPs include nurse practitioners, physician assistants, clinical nurse specialists, and certified nursemidwives, CMS says. However, the NPPs (as well as the physicians) can't be employed by the home health facility. Thirty days is a stricter timeframe than the six months suggested in PPACA. "We believe that the face-to-face encounter statutory provision was enacted to strengthen physician accountability [...]