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Today, CMS hosted a Home Health Provider Open Door Forum call to review the new face-to-face documentation requirements that were part of the 2015 Home Health PPS Final Rule. CMS provided responses to several questions posed by VNAA and our members and indicated that CMS leadership is considering delaying implementation of the new requirement. Links to the documents used on today's call can be found at the bottom of this article. Major points from the call include:

  • CMS requires that the documentation justifying the referral for home health benefits include five components:
    • Evidence of beneficiary need for the skilled services
    • Evidence of beneficiary homebound status
    • Date that demonstrates that the face-to-face encounter occurred within the required timeframe
    • Evidence that the face-to-face encounter was related to the primary reason the patient requires home health services, and
    • Evidence that the encounter was performed by an allowed provider type.
  • HHAs may include all of the content required to certify eligibility for the home health benefit in the plan of care for signature by the physician. However, this information will not be enough on its own. The certifying physician's and/or the acute/post-acute care facility's medical record must corroborate the information provided by the HHA and must include a copy of the actual clinical notes from the face-to-face encounter.
  • If requested by CMS' fiscal intermediary or other auditor, HHAs will be required to obtain the necessary information from the certifying physician's and/or the acute/post-acute care facility's medical record.

Pending additional guidance from CMS, VNAA recommends that beginning Jan. 1, 2015 HHAs incorporate evidence of the need for the skilled services, beneficiary homebound status, and date of the face-to-face encounter (if known) in the plan of care for signature by the certifying physician. We also recommend that HHAs request that physicians and/or the acute/post-acute care facilities send a copy of the record for the face-to-face encounter and any other documentation from the medical record needed to document eligibility for home health benefits at the time HHAs send the plan of care for signature. This information can be stored in the HHA's records for use with fiscal intermediaries or other auditors.

VNAA will continue to monitor CMS guidance on the changes related to face-to-face documentation. We will continue to work with CMS to ensure sufficient provider education, including of physicians. Please send any comments or questions to Molly Smith at [email protected] .

Links to the materials from today's call:

. 2121 Crystal Drive, Suite 750, Arlington, VA 22202

. 571-527-1520 / 888-866-8773

. [email protected]