Delayed Enforcement of Face-to-Face Encounter Requirement for Home Health & Hospice Eligibility Certifications
CMS has announced a delay in enforcement of ACA requirements that a physician have a face-to-face encounter with a patient for purposes of certifying eligibility for Medicare home health services or recertifying hospice eligibility. These requirements were scheduled to apply to home health patients with starts of care on or after January 1, 2011 and hospice recertifications on or after January 1, 2011. Given the agency’s concern that some home health agencies, physicians, and hospices may need additional time to establish operational protocols necessary to comply with this new law, however, CMS states that it expects appropriate documentation of these encounters beginning with the second quarter of 2011.
